CSAC Submitted Comments Noting Concerns CARB’s Advanced Clean Fleets 15‑Day Amendments

CSAC, along with other local government partners, recently submitted formal comments to the California Air Resources Board (CARB) on proposed 15-day amendments that seek major changes to the Advanced Clean Fleets (ACF) regulation. Although there are some promising aspects of the proposed language, CARB introduced many concerning pieces to this draft of the ACF regulations that fall short of addressing the realities counties face in delivering essential public services.  

CSAC will continue to advocate for meaningful exemptions, realistic timelines, and workable compliance pathways that recognize the essential role county fleets play in safeguarding Californians, especially as emergencies become more frequent and severe.  

Notable issues noted in our comments include: 

Dramatic Expansion of Program to Contracted Fleets 

The proposed language negatively impacts a county’s ability to contract with private companies for fleet services by making emissions compliance for private fleets a contractual and administrative responsibility, not just an operational one. 

Under the proposed language, all local governments would be required to: 

• Treat long‑term contractors, including waste hauling fleets, as de facto regulated fleets 
• Add ACF disclosures to contracts
• Actively verify contractor compliance
• Maintain auditable records 

CARB’s effort to extend the ACF to private fleets is concerning, given that they withdrew their request for a waiver from the federal Environmental Protection Agency in January 2025 to apply the ACF to private fleets. If adopted, these regulations will significantly raise utility rates or divert budget funding to pay for the increased costs to their owned or contracted fleets 

Fleet Resiliency Provisions Remain Unworkable 

The proposed “fleet resiliency” provisions acknowledge that zero‑emission vehicles (ZEVs) are not yet feasible for many frontline government functions—a point CSAC has long emphasized. However, the 25 percent cap on resiliency vehicles, coupled with onerous and temporary exemption requirements, ignores real‑world conditions counties face, particularly during emergencies. 

Local fleets must be able to respond immediately and continuously during wildfires, floods, earthquakes, heat emergencies, and other disasters. Artificial caps and short‑term exemptions do not reflect marketplace limitations or the unpredictable nature of emergency response. 

CSAC: Emergency Response Vehicles Must Be Excluded 

In our comments, CSAC reiterated that vehicles reasonably anticipated to respond to emergencies—or that directly support such efforts—must be excluded from the mandate, similar to existing exclusions for snow removal vehicles. 

Emergency response does not begin only when an emergency is formally declared. Counties rely on a wide range of vehicles every day for: 

• Fire prevention and mitigation 
• Public safety and search and rescue 
• Medical and disaster response 
• Utility repair and maintenance (water, power, wastewater, flood control) 
• Disease and vector control 

These vehicles must remain operable when power is unavailable, including during public safety power shutoffs and major disasters, the very circumstances when ZEV dependency presents the greatest risk. 

Cost, Availability, and Infrastructure Barriers Persist with ZEV Adoption 

CSAC also highlighted data from a recent Caltrans report on their efforts to implement the ACF for their fleet vehicles, showing that: 

• ZEVs cost, on average, more than 130 percent more than comparable internal combustion engine vehicles. 
• Charging infrastructure can exceed $210,000 per installation and take up to three years to complete. 
• Even state agencies with dedicated funding face severe limitations in acquiring medium-duty and heavy‑duty ZEVs. 

Critically, the report notes that agencies may need two or three ZEVs to replace the work capacity of a single ICE vehicle due to range and charging constraints—an untenable situation for county emergency operations. 

Protecting Public Safety Must Come First 

CSAC emphasized that county fleets’ primary roles are associated with service delivery, public safety, and community protection. Regulations that compromise emergency readiness, strain already limited county resources, or place frontline workers at risk are unacceptable. We will keep members informed as this rulemaking continues encourage counties to review and submit comments to CARB on the ACF regulations.