Coalition Seeks Clarity on Advanced Clean Fleets Rule on Private Contractor Fleets 

CSAC has joined a coalition of local government and industry organizations asking the California Air Resources Board (CARB) to provide written clarity on how its Advanced Clean Fleets (ACF) regulation applies to private contractors working with public agencies.  

The request follows clarification from CARB staff, reflected in the regulation’s Final Statement of Reasons, that appears to significantly narrow the rule’s application to private contractor fleets. Under the coalition’s understanding, simply having a contract with a public agency does not subject a contractor’s fleet to the ACF State and Local Government requirements. Instead, the requirements apply when the public agency “dispatches” the contractor’s vehicles. 

CARB defines dispatch as directing or instructing a specific vehicle to travel to a specific destination for a specific purpose. 

For counties, the distinction is important. Contractors that maintain control over their fleet operations — including which vehicles to use, driver assignments and routes — would generally fall outside the State and Local Government fleet requirements. 

The coalition’s letter cites waste hauling, construction, landscaping, maintenance, towing and other contracted services as examples where a contractor may independently control its fleet operations. 

CSAC and its coalition partners are asking CARB for additional written guidance confirming this interpretation to help counties and contractors consistently understand and apply the amended regulation.