(15-day) Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations

Submitted By

232 Results

Search Type

Sort:

Sort Results By

Comment From: City of Los Angeles (Andrew Antwih)

4/17/26 @ 5:47 PM

Attachments:

Download

Comment From: Earthjustice (Yasmine Agelidis)

4/17/26 @ 5:20 PM

Please find attached a comment letter supporting CARB's adoption of the proposed 15-day changes to the Advanced Clean Fleets regulation with the following recommendations.

Attachments:

Download

Comment From: Law Offices of Scott W. Gordon... (Scott Gordon)

4/17/26 @ 5:20 PM

Attachments:

Download

Comment From: Craig A. Corman, Mayor, City o... (Craig Corman)

4/17/26 @ 5:18 PM

Attachments:

Download

Comment From: City of Visalia (Brett Taylor)

4/17/26 @ 5:18 PM

Attachments:

Download

Comment From: Santa Cruz County - Department... (Carolyn Burke)

4/17/26 @ 5:14 PM

Please see attached comment letter from the Santa Cruz County Department of Community Development and Infrastructure.

Attachments:

Download

Comment From: Franchise, Rate, and Business ... (Katelyn Scholz)

4/17/26 @ 5:12 PM

April 17, 2026
Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Submitted via California Air Resources Board Comment Portal

To: Chair Lauren Sanchez and the Members of the California Air Resources Board:
RE: Adva...↓nced Clean Fleets Regulation 15-Day Amendment Comments

Thank you for this opportunity to provide comments on the proposed amendments to the Advanced Clean Fleets (ACF) and Low Carbon Fuel Standard regulations. This letter is being submitted by the Franchise, Rate, and Business Practices Technical Council of the California Resource Recovery Association (CRRA). Our technical council advances effective and innovative strategies in contract administration, rate setting, procurement, negotiation, and business practices for solid waste and recycling services. Our membership includes local government officials, service providers, and industry experts with decades of experience in solid waste and recycling. The opinions expressed in this letter do not necessarily represent those of the CRRA Board or the broader CRRA organization and membership.

We share CARB's overarching goals of reducing emissions and transitioning to cleaner vehicle technologies. However, we have significant concerns with the proposed expansion of the definition of "waste fleet" and the associated compliance structure. We believe this may unintentionally undermine both environmental and public service outcomes if implemented as currently drafted. Our primary concerns relate to the likely impacts on 1) solid waste ratepayers; 2) collection operations; and 3) franchise agreements (contracts between private service providers and local governments).

Impacts on Solid Waste Ratepayers
The proposed amendments would create significant cost burdens for ratepayers. The purchase cost of zero-emissions vehicles can be up twice that of internal combustion vehicles, without taking additional infrastructure and implementation into consideration. In addition, more vehicles will need to be purchased to provide the same amount of work because in most environments zero-emissions vehicles cannot collect from as many customers per day due to range limitations, battery charging times, and the reduced payloads caused by the weight of the batteries. The proposed implementation schedule would require affected fleets to transition future purchases and fleet composition toward ZEVs on a phased timeline, which could cause some vehicles to be replaced before the end of their economic life and likely increase costs." These significant cost increases will ultimately be borne by the ratepayers, and not local governments or their private contractors. This is after many other recent increases in costs affecting this industry, including the significant rate increases that were necessary to reduce the landfilling of organic waste to lessen the impact on climate change.

Impacts on Collection Operations
The proposed amendments would mandate the use of new technologies which have not yet been proven to be reliable for this application. It is too early in the development of zero-emissions waste vehicles to require their common use without risking potential disruptions in waste collection services which are vital to public health and safety and for environmental protection. For example, an electrical blackout could lead to an interruption in waste collection service. In addition, there are currently serious practical barriers to ACF compliance for waste fleets, including limited vehicle availability, long lead times to obtain vehicles, difficulty in securing sufficient electrical service, and the absence of commercially available zero-emission trucks for several mission critical applications.

Impacts on Franchise Agreements
The cost to ratepayers of solid waste franchise agreements is determined in large part by the number and types of vehicles that a private waste service provider must purchase for that agreement and the number of years the service provider will have to depreciate those vehicles. The proposed amendments will require most municipalities in the state to renegotiate their franchise agreements, as the majority of current agreements did not anticipate a rapid shift to zero-emissions vehicles or the need to replace internal combustion vehicles with remaining useful life before they were fully depreciated. Such franchise agreement renegotiations will be highly disruptive to the industry and pose risk of significant rate increases.
Waste collection vehicles have an average useful life of around ten years and are therefore typically depreciated over ten years. The proposed amendments appear to consider this by re-defining "waste fleet" to include only those fleets contracted via a franchise agreement / contract "with either a minimum length of ten years or more, or with a minimum length of three years but includes a renewal provision when satisfying the contract terms." Unfortunately, this definition creates perverse incentives for local governments and service providers to avoid compliance by "gaming" the contract term. A local agency could amend their existing waste collection franchise agreement, (or issue a new one) to be less than ten years long to avoid the zero-emission vehicle transition. This would increase annual costs as the service provider would have fewer years to depreciate the vehicles. Those increased costs would be passed on to the ratepayers without furthering CARB's intended goal of transitioning to zero-emissions vehicles. Franchise agreements with shorter terms create inefficient capital cycles that impact ratepayers and increase the service provider incumbency advantages that frustrate competition in these critical public services.

Conclusion
For these reasons, we respectfully request that the Board reject the newly proposed amendments that burden cities, at least until vehicle availability, reliability, and supporting infrastructure are demonstrably sufficient to support statewide implementation. If the Board decides not to reject the proposed amendments, then please consider relaxing the requirements by extending the timeline, considering exceptions for vehicles with existing useful life that were procured under existing contract terms, providing adequate alternative funding sources, and generally taking a more reasoned and balanced approach that recognizes the unique situations that every California community will face in implementing these regulations.

Sincerely,
Katelyn Scholz
Co-Chair
Franchise, Rate, and Business Practices Technical Council

Attachments:

Download

Comment From: Jurupa Community Services Dist... (Arman Tarzi)

4/17/26 @ 4:47 PM

April 17, 2026

Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, CA 95814

RE: Advanced Clean Fleets 15-Day Comment Period Response – Emergency Support Vehicle Exemption

Chair Liane Randolph and Members of the California...↓

Attachments:

Download

Comment From: County of Riverside (Carolina Herrera)

4/17/26 @ 4:41 PM

April 16, 2026

Mr. Craig Segall
Deputy Executive Officer
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re: Comments on 15-Day Modified Text – Proposed Amendments to Advanced Clean Fleets Regulations for State and Local Governm...↓

No attachments

Comment From: Rancho Santa Fe CSD (Chuck Duffy)

4/17/26 @ 4:40 PM

Please see attached letter.

Attachments:

Download

Comment From: City of Oakland (Liam Garland)

4/17/26 @ 4:35 PM

Please see the attached City of Oakland comments on the 15 Day Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations.

Attachments:

Download

Comment From: City of Thousand Oaks (Nader Heydari)

4/17/26 @ 4:27 PM

See attached comment letter

Attachments:

Download

Comment From: Santa Fe Irrigation District (Teresa Penunuri)

4/17/26 @ 4:21 PM

Attachments:

Download

Comment From: CR&R Environmental Services (Alex Braicovich)

4/17/26 @ 4:20 PM

Attachments:

Download

Comment From: City of Jurupa Valley (Abigail Gomez)

4/17/26 @ 4:14 PM

Attachments:

Download

Comment From: CCEEB - California Council for... (Tim Carmichael)

4/17/26 @ 4:11 PM

Attachments:

Download

Comment From: Sacramento Municipal Utility D... (Patricia Davy)

4/17/26 @ 4:11 PM

Attachments:

Download

Comment From: Wanger Jones Helsley PC (Nicolas Cardella)

4/17/26 @ 4:04 PM

Please see the attached Letter Re: Comments on Notice of Public Availability of Modified Text and Availability of Additional Documents and/or Information for Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations wi...↓

Attachments:

Download

Comment From: Clean Energy (Ryan Kenny)

4/17/26 @ 3:56 PM

Thank you for considering the attached comments on the Advanced Clean Fleets 15-day Notice. Those who signed this letter are:

Michael Boccadoro, Agriculture Energy Consumers Association (AECA)
N. Ross Buckenham, California Bioenergy LLC
Todd Campbel...↓

Attachments:

Download

Comment From: City of Mission Viejo (Wendy Bucknum)

4/17/26 @ 3:47 PM

Attachments:

Download

Comment From: City of Santa Clara (Jōvan Grogan)

4/17/26 @ 3:45 PM

Please see the attached comments from the City of Santa Clara.

Attachments:

Download

Comment From: Teichert Construction (John Lane)

4/17/26 @ 3:37 PM

Please see uploaded file for comments.

Attachments:

Download

Comment From: City of Marysville (Jim Schaad)

4/17/26 @ 3:35 PM

Dear Chair and Members of the California Air Resources Board,

On behalf of the City of Marysville, I write to express strong opposition to the proposed 15-day modifications to the Advanced Clean Fleets (ACF) regulation.

While we recognize and suppo...↓

No attachments

Comment From: City of Bakersfield (Mayor Karen Goh)

4/17/26 @ 3:29 PM

Dear Chair Lauren Sanchez and the Members of the California Air Resources Board,
The City of Bakersfield appreciates the Board's continued efforts to refine the Advanced Clean Fleets (ACF) regulation and the opportunity for us to comment on the 15-da...↓y proposed modifications.
Cities across the state are pursuing robust, environmentally sound strategies to decarbonize their communities. However, cities must also ensure the uninterrupted delivery of critical public services. As currently structured, the proposed modifications do not adequately account for the operational realities of local government fleets, particularly those that support emergency response and essential infrastructure.
Cities serve diverse and often expansive communities, providing vital services that protect public health, safety, and welfare. During emergencies, city fleet vehicles must operate continuously for extended periods, often in extreme conditions, to support fire prevention and response, search and rescue, medical response, and the delivery and maintenance of essential utilities such as water, wastewater, stormwater, and electricity. Without appropriate and durable exemptions, ACF strict requirements risk constraining cities' ability to respond effectively to disasters, maintain critical infrastructure, and safeguard the communities we serve.
The proposed amendments to the ACF regulations significantly expand the scope of local government responsibility by extending compliance obligations beyond publicly owned fleets to include private contractors operating under municipal agreements. By redefining "waste fleets" to include contracted service providers, cities can no longer rely on outsourcing to manage fleet compliance and are instead indirectly responsible for ensuring that contracted operations meet state mandates. This shift effectively converts municipal procurement and service delivery into a vehicle for state enforcement, exposing cities to increased costs, reduced contractor availability, and diminished flexibility in negotiating long-term service agreements, particularly for essential services like waste hauling, street sweeping, construction, and public works.
In addition, the proposal imposes substantial new administrative and legal burdens on cities by requiring ongoing verification of contractor compliance, mandatory contract disclosures, and extensive recordkeeping subject to rapid state audit. These requirements transform routine contracting functions into compliance oversight roles, requiring cities to annually validate contractor status, maintain auditable documentation for multiple years, and respond to CARB inquiries within tight timeframes. Collectively, these changes create unfunded mandates, increase administrative complexity, and elevate legal and procurement risks, while also placing upward pressure on contract costs and potentially limiting competition among vendors unable to meet evolving regulatory thresholds.
While the proposed amendments significantly increase obligations on local municipalities, we appreciate the amendments to provide increased compliance flexibility by delaying the 100 percent zero-emission vehicle purchase requirement from 2027 to 2030 and expanding eligibility for exemptions and extensions related to infrastructure constraints, operational limitations, and emergency response needs.
However, to prevent unintended consequences that could jeopardize life, property, and essential services, we respectfully urge the Board to reject these newly proposed mandates on cities and rather request that CARB establish clear, categorical exemptions, consistent with those in Section 2013(c) of Title 13 of the California Code of Regulations for city vehicles that respond to, support, and recover from emergencies and disasters.

Sincerely,
Mayor Karen Goh

Attachments:

Download

Comment From: Town of Apple Valley (Julie Ryan)

4/17/26 @ 3:25 PM

Attachments:

Download

Comment From: Symbio North America Corporati... (Juan Andres Garza)

4/17/26 @ 3:23 PM

Attachments:

Download

Comment From: Fairfield-Suisun Sewer Distric... (Amanda Roa)

4/17/26 @ 3:20 PM

Attachments:

Download

Comment From: Valley Center Municipal Water ... (Lindsay Leahy)

4/17/26 @ 3:13 PM

See attached comment letter

Attachments:

Download

Comment From: City of Carlsbad (Jason Haber)

4/17/26 @ 3:07 PM

Attachments:

Download

Comment From: City of Rocklin (Gabrielle de Farcy)

4/17/26 @ 3:07 PM

Attachments:

Download

Comment From: De Luz Community Services Dist... (James Emmons)

4/17/26 @ 3:01 PM

Please see attached comments.

Attachments:

Download

Comment From: Resource Conservation District... (Ann Baldridge)

4/17/26 @ 2:52 PM

Attachments:

Download

Comment From: Orange County Fire Authority (Kenneth Piguee)

4/17/26 @ 2:45 PM

See attached letter for comments from the Orange County Fire Authority.

Attachments:

Download

Comment From: Resource Recovery Coalition of... (Veronica Pardo)

4/17/26 @ 2:42 PM

Thank you for the opportunity to submit the attached coalition comment letter regarding CARB's proposed amendments to the State and Local Government Fleet provisions of the Advanced Clean Flets regulation, issued on April 2, 2026 for a 15-day comment...↓

Attachments:

Download

Comment From: City of El Cerrito (Christina Leard)

4/17/26 @ 2:41 PM

The City of El Cerrito supports California's goals of reducing greenhouse gas emissions and advancing zero emission fleet technologies including electrification. However, CARB should not finalize the proposed ACF amendments without further changes to...↓ protect solid waste ratepayers and the essential public services they fund. As drafted, the rule would impose substantial near-term costs and operational burdens on municipality-contracted solid waste fleets, of which the City of El Cerrito operates curbside recycling collection programs, while leaving local communities and ratepayers to absorb the consequences. These costs will not be borne by the private haulers or their municipal agencies - they will be borne by households and businesses through higher solid waste rates. El Cerrito residents already have one of the highest collection rates in the region, and the increased costs will be passed on to them.

This is especially problematic because the solid waste sector is already managing multiple major cost pressures, including recent costs associated with implementing other State mandates intended to reduce greenhouse gas emissions. CARB should take a more reasoned and balanced approach. At a minimum, the Board should: extend compliance timelines where necessary; allow vehicles procured under existing franchise or contract terms to remain in service for their expected useful life; provide clear exceptions or flexibility for fleets facing unique operational, geographic, demographic, or route-related constraints; and ensure adequate funding and supporting infrastructure are available before imposing additional requirements.

A one-size-fits-all mandate is not appropriate for California's diverse communities. Fleet sizes, service territories, population density, topography, route conditions, and contract structures vary significantly across the state. El Cerrito has a very small fleet of recycling collection vehicles which this applies to. Regulations that fail to account for those differences risk serious unintended consequences, including higher rates, reduced service flexibility, disruption of essential public services, and conglomeration of private solid waste enterprises. CARB should revise the proposal to better reflect real-world conditions and avoid shifting disproportionate costs onto ratepayers in communities that have little ability to absorb them.

Thank you for your consideration.

Christina Leard
Acting Environmental Services Manager
City of El Cerrito, Public Works Department

No attachments

Comment From: Rancho California Water Distri... (Tom Greene)

4/17/26 @ 2:35 PM

See attached file.

Attachments:

Download

Comment From: Recology (Julia Mangin)

4/17/26 @ 2:27 PM

Please find Recology's comments on the Advanced Clean Fleets Regulations in the attached letter.

Attachments:

Download

Comment From: City of Foster City (Art Kiesel)

4/17/26 @ 2:27 PM

Attachments:

Download

Comment From: Town of Windsor (Jon Davis)

4/17/26 @ 2:26 PM

The Town of Windsor ("Town") appreciates the opportunity to provide comments on the proposed amendments to the Advanced Clean Fleet ("ACF") and Low Carbon Fuel Standard regulations. The Town supports California's goals of reducing greenhouse gas emi...↓

No attachments

Comment From: California Electric Transporta... (Kristian Corby)

4/17/26 @ 2:08 PM

Attachments:

Download

Comment From: Marin-Sonoma Mosquito and Vect... (Peter Bonkrude)

4/17/26 @ 2:00 PM

Attachments:

Download

Comment From: Local Government and Contracte... (Christine Wolfe)

4/17/26 @ 1:58 PM

Please see the attached comments on the 15-day Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations submitted on behalf of organizations and entities representing local governments and contracted fleets.

Attachments:

Download

Comment From: ReGen Monterey (Kristin O'Hara)

4/17/26 @ 1:53 PM

ACF impacts vehicles Class 2b and above (8,500lbs gross vehicle weight and higher). The vehicles ReGen Monterey believes should be excluded from the ACF regulations
• Vehicles used for fire prevention/mitigation, public safety, search and rescue, med...↓

No attachments

Comment From: City of La Verne (Tim Hepburn)

4/17/26 @ 1:51 PM

On behalf of the City of La Verne, I must oppose the proposed modifications to the Advanced Clean Fleets (ACF) regulation. While we support efforts to reduce emissions, this proposal imposes impractical and unfunded mandates that fail to reflect how ...↓

Attachments:

Download

Comment From: Waste Management of California... (Christine Wolfe)

4/17/26 @ 1:51 PM

Please find attached Waste Management of California, Inc.'s comments on the 15 Day Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations.

Attachments:

Download

Comment From: Beta Analytic LLC (Benjamin Kling)

4/17/26 @ 1:48 PM

Attachments:

Download

Comment From: The Transport Project (Katie Vassalli)

4/17/26 @ 1:35 PM

Please see attached comments in response to the April 2, 2026, 15-day notice regarding proposed amendments to ACF and LCFS standards.

Attachments:

Download

Comment From: Metropolitan Water District of... (Roxana Ramirez)

4/17/26 @ 1:26 PM

Please find attached Metropolitan's comment letter regarding CARB's Advanced Clean Fleets (ACF) April 2, 2026, 15-Day Rulemaking Package.

Attachments:

Download

Comment From: National Waste & Recycling Ass... (Anne Germain)

4/17/26 @ 1:23 PM

Please see attached comments.

Attachments:

Download

Comment From: Selma-Kingsburg-Fowler CSD (Veronica Cazares)

4/17/26 @ 1:23 PM

Attachments:

Download

Comment From: Waste Connections of Californi... (Mark Gingrich)

4/17/26 @ 1:15 PM

Attachments:

Download

Comment From: West Valley Solid Waste Manage... (Robert Hilton)

4/17/26 @ 1:14 PM

Please see letter attached.

Attachments:

Download

Comment From: HF&H Consultants (Robert Hilton)

4/17/26 @ 1:05 PM

Please see letter attached.

Attachments:

Download

Comment From: City of San Jose (Han Kang)

4/17/26 @ 1:00 PM

Please see attached comments from City of San Jose.

Attachments:

Download

Comment From: City of San Ramon - Solid Wast... (Thomas Anderson)

4/17/26 @ 12:57 PM

While I fully endorse California's commitment to slashing greenhouse gas emissions and transitioning to zero-emission vehicle (ZEV) technologies, I believe the California Air Resources Board (CARB) must refine the Advanced Clean Fleets (ACF) amendmen...↓

No attachments

Comment From: Burbank Water and Power (Jason Maruca)

4/17/26 @ 12:55 PM

Attachments:

Download

Comment From: Los Angeles Department of Wate... (Ellis Chiu)

4/17/26 @ 12:46 PM

Attachments:

Download

Comment From: Las Gallinas Valley Sanitary D... (Curtis Paxton)

4/17/26 @ 12:30 PM

Attachments:

Download

Comment From: NAFA Fleet Management Associat... (Michael Taylor)

4/17/26 @ 11:59 AM

April 17, 2026

California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re: NAFA Comments on Implementation Considerations for ACF, LCFS, and Related Amendments

Dear Chair Sanchez and Members of the Board:

On behalf of the NAFA Fleet Man...↓

Attachments:

Download

Comment From: California Water Association (Sarah Musiker)

4/17/26 @ 11:59 AM

Please see the attached comments from CWA on the (15-day) Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations.

Attachments:

Download

Comment From: West County Wastewater Distric... (Justin Lovell)

4/17/26 @ 11:51 AM

Attachments:

Download

Comment From: Sonoma Garbage Collectors (Sydney Simonson)

4/17/26 @ 11:45 AM

Attachments:

Download

Comment From: Coffee Creek VFPD (Steve Renten)

4/17/26 @ 11:36 AM

Attachments:

Download

Comment From: Tri-Valley Cities Coalition (Newell Arnerich)

4/17/26 @ 11:32 AM

Please see the attached letter from the Tri-Valley Cities Coalition, representing the communities of Danville, Dublin, Livermore, Pleasanton, and San Ramon.

Thank you.

Attachments:

Download

Comment From: Jim Pruett (Jim Pruett)

4/17/26 @ 11:13 AM

Attachments:

Download

Comment From: Coastside County Water Distric... (Mary Rogren)

4/17/26 @ 10:55 AM

Please find attached a comment letter Re: Advanced Clean Fleets 15-Day Comment Period Response

Attachments:

Download

Comment From: City of La Mirada (Jorge Orozco)

4/17/26 @ 10:49 AM

The City of La Mirada respectfully opposes the California Air Resources Board's 15-day proposed amendments to the Advanced Clean Fleets (ACF) regulation.

As proposed, the amendments would shift significant regulatory and administrative responsibilit...↓

No attachments

Comment From: City of San Bernardino (Helen Tran)

4/17/26 @ 10:48 AM

Attachments:

Download

Comment From: City of Martinez (Michael Chandler)

4/17/26 @ 10:43 AM

Attachments:

Download

Comment From: Otay Water District (Tenille O... (Tenille Otero)

4/17/26 @ 10:27 AM

Please see the attached comment letter from the Otay Water District on the Proposed 15-Day Amendments to the Advanced Clean Fleets (ACF) Regulation (AB 1594). Thank you.

Attachments:

Download

Comment From: Michael Lewis (Michael Lewis)

4/17/26 @ 10:24 AM

Attachments:

Download

Comment From: City of Upland (Damien Arrula)

4/17/26 @ 10:16 AM

The City of Upland appreciates the Board's continued efforts to refine the Advanced Clean Fleets (ACF) regulation and the opportunity for us to comment on the 15-day proposed modifications.

Cities across the state are pursuing robust, environmental...↓ly sound strategies to decarbonize their communities. However, cities must also ensure the uninterrupted delivery of critical public services. As currently structured, the proposed modifications do not adequately account for the operational realities of local government fleets, particularly those that support emergency response and essential infrastructure.

Cities serve diverse and often expansive communities, providing vital services that protect public health, safety, and welfare. During emergencies, city fleet vehicles must operate continuously for extended periods, often in extreme conditions, to support fire prevention and response, search and rescue, medical response, and the delivery and maintenance of essential utilities such as water, wastewater, stormwater, and electricity. Without appropriate and durable exemptions, ACF strict requirements risk constraining cities' ability to respond effectively to disasters, maintain critical infrastructure, and safeguard the communities we serve.

The proposed amendments to the ACF regulations significantly expand the scope of local government responsibility by extending compliance obligations beyond publicly owned fleets to include private contractors operating under municipal agreements. By redefining "waste fleets" to include contracted service providers, cities can no longer rely on outsourcing to manage fleet compliance and are instead indirectly responsible for ensuring that contracted operations meet state mandates. This shift effectively converts municipal procurement and service delivery into a vehicle for state enforcement, exposing cities to increased costs, reduced contractor availability, and diminished flexibility in negotiating long-term service agreements, particularly for essential services like waste hauling, street sweeping, construction, and public works.

In addition, the proposal imposes substantial new administrative and legal burdens on cities by requiring ongoing verification of contractor compliance, mandatory contract disclosures, and extensive recordkeeping subject to rapid state audit. These requirements transform routine contracting functions into compliance oversight roles, requiring cities to annually validate contractor status, maintain auditable documentation for multiple years, and respond to CARB inquiries within tight timeframes. Collectively, these changes create unfunded mandates, increase administrative complexity, and elevate legal and procurement risks, while also placing upward pressure on contract costs and potentially limiting competition among vendors unable to meet evolving regulatory thresholds.

Upland is actively pursuing and advancing decarbonization through its Climate Action Plan (adopted in 2015), which emphasizes reductions in greenhouse gas emissions via transportation planning, energy efficiency, renewable energy adoption, and improvements to municipal operations. These local strategies align with broader state requirements to reduce emissions through land use, mobility, and infrastructure decisions.

The proposed amendments to the ACF regulations would directly and negatively impact the City of Upland by shifting compliance responsibility onto the City for fleets it does not directly control. By redefining regulated fleets to include contracted service providers, Upland would no longer be able to rely on outsourcing to manage regulatory obligations, instead taking on increased administrative oversight and potential enforcement responsibilities. This change is likely to drive up costs as contractors pass through expenses associated with meeting stricter fleet requirements, while also reducing the pool of qualified vendors, particularly for essential services like waste hauling, street sweeping, and construction. Additionally, the City's flexibility in procurement and long-term service agreements would be constrained, creating budget pressures and increasing the risk of service disruptions, ultimately placing a disproportionate burden on the City without corresponding control over compliance outcomes.

While the proposed amendments significantly increase obligations on local municipalities, we appreciate the amendments to provide increased compliance flexibility by delaying the 100 percent zero-emission vehicle purchase requirement from 2027 to 2030 and expanding eligibility for exemptions and extensions related to infrastructure constraints, operational limitations, and emergency response needs.

However, to prevent unintended consequences that could jeopardize life, property, and essential services, we respectfully urge the Board to reject these newly proposed mandates on cities and rather request that CARB establish clear, categorical exemptions, consistent with those in Section 2013(c) of Title 13 of the California Code of Regulations for city vehicles that respond to, support, and recover from emergencies and disasters.

Again, thank you for allowing us the opportunity to provide written responses to the proposed Advance Clean Fleets Regulations.

Attachments:

Download

Comment From: Joint Public Agencies (CMUA, N... (Derek Dolfie)

4/17/26 @ 10:00 AM

Hello,

Please see the attached response comment letter to the 15-day changes to the ACF regulations from the Joint Public Agencies consisting of the California Municipal Utilities Association (CMUA), the Northern California Power Agency (NCPA), and...↓

Attachments:

Download

Comment From: Linda Reich

4/17/26 @ 9:58 AM

Attachments:

Download

Comment From: Sacramento Suburban Water Dist... (Greg Bundesen)

4/17/26 @ 9:45 AM

Attachments:

Download

Comment From: California Association of Sani... (Sarah Deslauriers)

4/17/26 @ 9:33 AM

Please find attached the California Association of Sanitation Agencies' comments on the proposed amendments to the Advanced Clean Fleets Regulation. We appreciate the opportunity to comment and are happy to answer any questions you have.

Regards,
S...↓

Attachments:

Download

Comment From: Sacramento County Department o... (Kerry Schmitz)

4/17/26 @ 9:32 AM

See attachment

Attachments:

Download

Comment From: City of Tustin (Michael Grisso)

4/17/26 @ 9:31 AM

See attached comment letter.

Attachments:

Download

Comment From: Solano Irrigation District (Jeff Sullivan)

4/17/26 @ 9:30 AM

Attachments:

Download

Comment From: City of Belmont (Afshin Oskoui, City Manager)

4/17/26 @ 9:22 AM

One Twin Pines Lane,
Belmont, CA 94002
650-595-7408, belmont.gov

April 16, 2026

The Honorable Lauren Sanchez Chair, California Air Resources Board

1001 I Street
Sacramento, CA 95814

RE: Advanced Clean Fleets 15-Day Comment Period Response

Dear ...↓

Attachments:

Download

Comment From: City of Hanford City Manager (Chris Tavarez)

4/17/26 @ 9:18 AM

Please see the attached letter

Attachments:

Download

Comment From: Calleguas Municipal Water Dist... (Charlotte Holifield)

4/17/26 @ 9:17 AM

Attachments:

Download

Comment From: San Diego Humane Society (Julianna Tetlow)

4/17/26 @ 9:06 AM

Attachments:

Download

Comment From: Clean Water SoCal (David Rothbart)

4/17/26 @ 9:06 AM

Attached are comments on behalf of Clean Water SoCal

Attachments:

Download

Comment From: Town of Windsor (Kristina Owens)

4/17/26 @ 9:03 AM

The Town of Windsor supports California's goals of reducing greenhouse gas emissions and advancing zero emission fleet technologies including electrification. However, CARB should not finalize the proposed ACF amendments without further changes to pr...↓otect solid waste ratepayers and the essential public services they fund. As drafted, the rule would impose substantial near-term costs and operational burdens on municipality-contracted solid waste fleets, while leaving local communities and ratepayers to absorb the consequences. These costs will not be borne by the private haulers or their municipal agencies - they will be borne by households and businesses through higher solid waste rates.

This is especially problematic because the solid waste sector is already managing multiple major cost pressures, including recent costs associated with implementing other State mandates intended to reduce greenhouse gas emissions. CARB should take a more reasoned and balanced approach. At a minimum, the Board should: extend compliance timelines where necessary; allow vehicles procured under existing franchise or contract terms to remain in service for their expected useful life; provide clear exceptions or flexibility for fleets facing unique operational, geographic, demographic, or route-related constraints; and ensure adequate funding and supporting infrastructure are available before imposing additional requirements.

A one-size-fits-all mandate is not appropriate for California's diverse communities. Fleet sizes, service territories, population density, topography, route conditions, and contract structures vary significantly across the state. Regulations that fail to account for those differences risk serious unintended consequences, including higher rates, reduced service flexibility, disruption of essential public services, and conglomeration of private solid waste enterprises. CARB should revise the proposal to better reflect real-world conditions and avoid shifting disproportionate costs onto ratepayers in communities with limited ability to absorb them. This is especially true for the Town of Windsor, whereas the solid waste franchise agreement is limited to a ten-year term with no option for extension, therefore requiring a competitive bidding process to occur, as approved by a citizen initiative in 1996.

Sincerely,
Kristina Owens
Government Operations Manager
Town of Windsor

No attachments

Comment From: Association of California Wate... (Nick Blair)

4/17/26 @ 9:00 AM

ACWA Comments in response to 15-day changes to Advanced Clean Fleets Regulation

Attachments:

Download

Comment From: Joey Hejnowicz

4/17/26 @ 8:55 AM

I support California's goals of reducing greenhouse gas emissions and advancing zero emission fleet technologies including electrification. However, CARB should not finalize the proposed ACF amendments without further changes to protect solid waste r...↓

Attachments:

Download

Comment From: City of Oakley (Danielle Navarro)

4/17/26 @ 8:33 AM

To prevent unintended consequences that could jeopardize life, property, and essential services, the City of Oakley respectfully urges the Board to reject these newly proposed mandates on cities and rather request that CARB establish clear, categoric...↓

Attachments:

Download

Comment From: Las Virgenes Municipal Water D... (Joe McDermott)

4/17/26 @ 8:27 AM

Please see attached letter with comments. thank you for your consideration.

Attachments:

Download

Comment From: City of Murrieta (Isaac Bravo)

4/17/26 @ 8:21 AM

Attachments:

Download

Comment From: Julie Bryant

4/17/26 @ 8:16 AM

No attachments

Comment From: Western Municipal Water Distri... (Craig Miller)

4/17/26 @ 7:53 AM

Attachments:

Download

Comment From: Elsinore Valley Municipal Wate... (Erin Sasse)

4/17/26 @ 7:46 AM

Attachments:

Download

Comment From: Jill Tucker

4/17/26 @ 7:16 AM

Attachments:

Download

Comment From: Nicole Rinauro

4/16/26 @ 9:06 PM

No attachments

Comment From: City of Imperial Beach (Tyler Foltz)

4/16/26 @ 7:48 PM

The City of Imperial Beach supports California's climate goals and appreciates efforts to refine the Advanced Clean Fleets regulation, but is concerned that the proposed changes fail to account for the operational realities of municipal fleets, parti...↓