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

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Comment From: Midpeninsula Regional Open Spa... (Joshua Hugg)

4/16/26 @ 5:40 PM

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Comment From: City of Concord (Justin Ezell)

4/16/26 @ 5:24 PM

City of Concord is opposed to these amendments; please see attached letter of opposition.

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Comment From: West Valley Water District (Socorro Pantaleon)

4/16/26 @ 5:20 PM

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Comment From: Brett Sanders (Brett Sanders)

4/16/26 @ 5:05 PM

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Comment From: City of Loma Linda (T. Jarb Thaipejr)

4/16/26 @ 5:05 PM

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 Chair Lauren Sanchez and the Members of the California Air Resour...↓

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Comment From: Truckee Donner Public Utility ... (Steven Poncelet)

4/16/26 @ 5:05 PM

Please find the uploaded comments From Truckee Donner Public Utility District on the CARB April 2, 2026, 15-day Notice of Modified Text for the Advanced Clean Fleets regulation. TDPUD also supports the joint comments submitted by CMUA, NCPA, and SCPP...↓

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Comment From: Monte Vista Water District (Kelley Donaldson)

4/16/26 @ 4:55 PM

Please see attached letter with comments on proposed amendments to the Advanced Clean Fleet regulation.

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Comment From: City of Seal Beach (Lauren Barich)

4/16/26 @ 4:49 PM

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Comment From: Tehama Conservation Fund & El ... (Kristen Lamkin)

4/16/26 @ 4:39 PM

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Comment From: City of Menifee (Philip Southard)

4/16/26 @ 4:36 PM

Please see the attached letter on behalf of the City of Menifee regarding the proposed amendments to the Advanced Clean Fleets (ACF) and Low Carbon Fuel Standard (LCFS) regulations.

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Comment From: Imperial Irrigation District (Jennifer Goodsell)

4/16/26 @ 4:31 PM

Please accept this updated comment letter from Imperial Irrigation District. Thank you.

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Comment From: City of Upland (Darren Chan)

4/16/26 @ 4:27 PM

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Comment From: City of Sacramento (Consuelo Hernandez)

4/16/26 @ 4:17 PM

Attached please find a letter from the City of Sacramento regarding the proposed amendments to the Advanced Clean Fleets regulation.

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Comment From: Eastern Municipal Water Distri... (Pacal Cornejo-Reynoso)

4/16/26 @ 4:12 PM

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Comment From: Janet Jernigan (Janet Jernigan )

4/16/26 @ 3:55 PM

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Comment From: Garrett Toy

4/16/26 @ 3:48 PM

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Comment From: California Fuels and Convenien... (Gebriel Saleh)

4/16/26 @ 3:46 PM

Please see attached regarding CFCA's comments.

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Comment From: City of San Marcos (Michelle Bender)

4/16/26 @ 3:35 PM

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Comment From: City of Pico Rivera (Jesus Garcia)

4/16/26 @ 3:22 PM

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Comment From: City of Palm Desert (Anthony Mejia)

4/16/26 @ 3:00 PM

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Comment From: Fresno Irrigation District (Bill Stretch)

4/16/26 @ 3:00 PM

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Comment From: Sweetwater Authority (Michelle Musgrave)

4/16/26 @ 2:51 PM

Please see the uploaded response document for comments from Sweetwater Authority.

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Comment From: Brian Weber (Brian Weber)

4/16/26 @ 2:35 PM

San Mateo County Mosquito and Vector Control District supports California's emissions‑reduction goals but remains concerned that the Advanced Clean Fleets (ACF) and Low Carbon Fuel Standard (LCFS) requirements continue to create unintended challenges...↓

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Comment From: California Waste Haulers Counc... (Luis Sanchez)

4/16/26 @ 2:27 PM

California Air Resources Board
1001 I Street
Sacramento, CA 95814

Comments on 15-Day Modifications to the Advanced Clean Fleets Regulation
Docket: ACF 15-Day Change Package (Released April 2, 2026)

Chair Sanchez and Members of the Board:
On behalf ...↓

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Comment From: Modesto Irrigation District (Dana Ferreira)

4/16/26 @ 2:03 PM

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Comment From: Cucamonga Valley Water Distric... (Eric Grubb)

4/16/26 @ 1:43 PM

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Comment From: Liz Pharis (Kristin Griffith)

4/16/26 @ 1:41 PM

The City of Brea pursues environmentally sound strategies to decarbonize our community. However, we must also ensure the uninterrupted delivery of critical public services. As currently structured, the proposed modifications do not adequately account...↓

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Comment From: Damon Conklin (Damon Conklin)

4/16/26 @ 1:30 PM

Dr. Steven Cliff
Executive Officer
California Air Resources Board
1001 I Street
Sacramento, CA 95814

RE: Strong Opposition to 15-Day Proposed Amendments to the Advanced Clean Fleets (ACF) Regulation – Unlawful Expansion of Local Government Obligatio...↓

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Comment From: Union Public Utility District (Jessica Self)

4/16/26 @ 1:21 PM

See attached letter.

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Comment From: Alameda County Water District (Robert Marsheck)

4/16/26 @ 1:01 PM

Please see attached letter requesting fleet vehicles utilized by Water Agencies be categorically exempted in same manner as those in part(c) of section 2013 of title 13. Thank you.

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Comment From: Santa Margarita Water District (Alyson Piguee)

4/16/26 @ 12:40 PM

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Comment From: Pixley Irrigation District (Mark Greenall)

4/16/26 @ 12:25 PM

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Comment From: Lower Tule River Irrigation Di... (Mark Greenall)

4/16/26 @ 12:23 PM

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Comment From: Imperial Irrigation District (Jennifer Goodsell)

4/16/26 @ 12:17 PM

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Comment From: City of Los Alamitos (Ron Noda)

4/16/26 @ 12:15 PM

The City of Los Alamitos is submitting the attached comment letter regarding the proposed 15-day modification to the Advanced Clean Fleet regulations. While the City fully supports statewide decarbonization goals and continues to implement meaningful...↓

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Comment From: Fresno Mosquito and Vector Con... (Ryan McNeil)

4/16/26 @ 12:03 PM

Please see attached letter, thank you.

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Comment From: City of Highland (Carlos Zamano)

4/16/26 @ 11:49 AM

Response letter is attached regarding the proposed amendments to the Advanced Clean Fleets and Low Carbon Fuel for consideration by Chair Lauren Sanchez and the Members of the California Air Resources Board. Respectfully submitted by Carlos Zamano, ...↓

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Comment From: City of Stanton (David Shawver)

4/16/26 @ 11:24 AM

April 16, 2026

The Honorable Lauren Sanchez
Chair, California Air Resources Board
1001 I Street
Sacramento, CA 95814

SUBJECT: Advanced Clean Fleets 15-Day Comment Period Response

Dear Chair Lauren Sanchez and the Members of the California Air Res...↓ources Board,

The City of Stanton 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, 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's 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.

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

Sincerely,

David J. Shawver
Mayor
City of Stanton

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Comment From: Mt. View Sanitary District (Lilia Corona)

4/16/26 @ 11:14 AM

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Comment From: Nevada County (Josh Hylinski)

4/16/26 @ 11:09 AM

Nevada County recognizes the intent of CARBs Advanced Clean Fleets Rule (ACF) to reduce emissions and transition fleets toward cleaner technologies with reduced emissions. However, compliance presents significant operational and financial hardships f...↓or our county, particularly for medium and heavy-duty public works vehicles.

While the ACF rule provides exemptions for emergency vehicles equipped with lights and sirens, low use equipment, and certain permanent snow removal equipment, it does not extend similar consideration to many public works vehicles. In practice, these vehicles often serve critical emergency functions. They are routinely deployed for snow removal, wildfire evacuation response, roads closures, storm damage, and wastewater operations. From an operational standpoint, they function as emergency response assets, even if they do not meet the exemption criteria.

A key concern is the ACF requirement that all new vehicle purchases over 8,500 pounds and above be zero-emission starting in 2029. At present, there are no widely available, proven zero-emission options for Class 2b and above trucks that can meet the demands of Nevada County's terrain, climate, and duty cycles. Existing electric vehicle options have limited range and require extended charging times, which are not compatible with continuous operations such as 24-hour snow removal shifts, and vehicles being staged off site.

Geography further compounds these challenges. Our crews must travel significant distances often into remote and mountainous areas such as the town of Washington, North San Juan, Hobart Mills, Soda Springs, and Cascade Shores, before work even begins. This results in substantial energy consumption simply reaching job sites, reducing operational effectiveness for battery-electric vehicles.

Additionally, many of the currently available zero-emission heavy-duty vehicles are produced by newer or startup manufacturers. These companies often lack established service networks, parts availability, and warranty support in our region. This creates unacceptable risks for maintaining critical fleet readiness.

Cost is another major barrier. Electric heavy-duty vehicles can cost nearly twice as much as their internal combustion counterparts. While the ACF rule allows for backup vehicles, maintaining duplicate fleets to ensure operational reliability during emergencies would significantly increase both capital and ongoing maintenance costs, placing an unsustainable burden on our rural county and the taxpayer.

Nevada County currently lacks the infrastructure needed to support widespread deployment of zero-emission heavy-duty vehicles. Charging infrastructure is limited, and hydrogen fueling infrastructure is nonexistent. Until these systems are developed, large-scale adoption is not feasible.

While we support the transition to cleaner technologies, particularly for light-duty vehicles, the current requirements for 8500lb and above vehicles are not yet practical for our operations. A more flexible approach, including consideration of hybrid technologies or alternative fuels, would better support both environmental goals and the critical services we provide to the public.

Finally, successful implementation of the CARB Advanced Clean Fleets Rule depends on the availability of reliable, cost effective, and operationally functional vehicles. OEM manufacturer readiness is critical to ensure that fleets are not required to adopt technologies that do not yet meet the performance, serviceability, and lifecycle cost needs of Nevada County.

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Comment From: John Levi

4/16/26 @ 11:02 AM

You must exempt a broader range of emergency vehicles so that California can respond to emergencies especially when the power is out. Support vehicles such as trucks that tow fuel to water pumps must be exempt. We need vehicles that can operate aroun...↓

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Comment From: City of Roseville (Noelle Mattock)

4/16/26 @ 9:43 AM

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Comment From: San Joaquin County Mosquito & ... (Omar Khweiss)

4/16/26 @ 9:29 AM

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Comment From: Albion-Little River Fire Prote... (Michael Rees)

4/16/26 @ 9:24 AM

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Comment From: Inland Empire Utilities Agency (Joe Sturges)

4/16/26 @ 9:15 AM

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Comment From: Garth Schultz

4/16/26 @ 8:45 AM

While I am in support of fleet electrification generally, and believe it is appropriate for governments to take action to reduce greenhouse gas emissions, having studied this issue professionally I am very concerned about the near term cost and opera...↓

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Comment From: City of Vacaville Public Works... (Courtney Lee)

4/16/26 @ 7:14 AM

The City of Vacaville Public Works Department appreciates the opportunity to provide input on the proposed modified text for the Advanced Clean Fleet regulation. We submit the attached comments in good faith to assist CARB in developing regulatory la...↓

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Comment From: Placer County Water Agency (Anthony Firenzi)

4/15/26 @ 4:36 PM

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Comment From: Mesa Water District (Stacy Taylor)

4/15/26 @ 4:25 PM

Mesa Water District (Mesa Water) respectfully submits the attached response to the CARB ACF 15-Day Comment Draft, specifically to request amendments to the ACF exemptions to allow our vehicles that support emergency services to continue serving our c...↓

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Comment From: City of Fremont (Anthony Choi)

4/15/26 @ 4:08 PM

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Comment From: Town of Discovery Bay (Dina Breitstein)

4/15/26 @ 4:02 PM

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Comment From: City of Folsom (Justin Raithel)

4/15/26 @ 3:48 PM

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Comment From: TEHAMA COUNTY BOARD OF SUPERVI... (TEHAMA COUNTY)

4/15/26 @ 3:42 PM

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Comment From: City of Buena Park (Mayor Connor Traut )

4/15/26 @ 3:28 PM

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Comment From: City of Citrus Heights (Danielle Jones)

4/15/26 @ 3:25 PM

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Comment From: Soquel Creek Water District (Melanie Schumacher)

4/15/26 @ 3:07 PM

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Comment From: City of Mountain House (Andy Su)

4/15/26 @ 3:07 PM

Please see attached letter

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Comment From: Union Sanitary District (Jose Rodrigues)

4/15/26 @ 2:53 PM

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Comment From: Utility Global Inc. (Cory Shumaker)

4/15/26 @ 2:41 PM

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Comment From: Fern Valley Water District (Victor Jimenez)

4/15/26 @ 1:50 PM

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Comment From: Mountain Counties Water Resour... (Justin Caporusso)

4/15/26 @ 1:44 PM

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Comment From: Fire Chief Napier

4/15/26 @ 12:49 PM

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Comment From: Paradise Irrigation District (Kevin Phillips)

4/15/26 @ 12:10 PM

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Comment From: East Orange County Water Distr... (David Youngblood)

4/15/26 @ 11:38 AM

Local agencies like ours continue to do our part in achieving the State's climate and emissions goals. Our proposed amendments will enable us to better meet this challenge and effectively navigate the current Advanced Clean Fleets (ACF) mandates and ...↓

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Comment From: San Diego County Water Authori... (Daniel Gaytan)

4/15/26 @ 10:32 AM

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Comment From: Henry Miller Reclamation Distr... (John Wiersma)

4/15/26 @ 10:19 AM

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Comment From: PW Henderson (PW Henderson)

4/15/26 @ 10:13 AM

We agree with the bulk of the regulations. The timeframe seems reasonable. No reason for emergency support vehicles to poison breathing air as they drive to a site. Ridiculous that there is any pushback on this. Fleets that are purposely "deletin...↓

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Comment From: Ben Dewell – Director, S... (Ben Dewell)

4/15/26 @ 10:12 AM

Clerk of the Board
California Air Resources Board 1001 I Street
Sacramento, CA 95814
RE: Advanced Clean Fleets 15-Day Comment Period Response
Chair Lauren Sanchez and the Members of the California Air Resources Board:

April 15, 2026

We greatly appr...↓eciate the time and effort that has gone into the 15-day comment draft that has been published for public comment. While the goals of these regulations are laudable, the reality remains that we cannot safely serve our communities unless emergency support vehicles are exempted.

At the Stallion Springs Community Services District, we serve a very small rural community of just 3,139 residents. The cost associated with replacing our support vehicles would place a sig- nificant financial hardship on the District and, ultimately, on the community we serve. These ex- penses would divert limited funds away from essential operations and compromise the resources necessary to ensure the continued availability of critical emergency services for our residents.
To prevent unnecessary loss of life and property in the communities we serve, please reconsider the amendments respectfully requested in the October 7th letter submitted by the California Spe- cial Districts Association, League of California Cities, and California State Association of Coun- ties, collectively representing our state's 5,000 local agencies and 40 million residents.

Local agencies like ours continue to do our part in achieving the State's climate and emissions goals. Our proposed amendments will enable us to better meet this challenge and effectively nav- igate the current Advanced Clean Fleets (ACF) mandates and their associated ambitious compli- ance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating unnecessary challenges in complying while maintaining the many critical
services Californians rely upon for their most essential daily needs as well as during emergencies and disasters.

Specific considerations for Community Service Districts include:
1) Stallion Springs, as many limited funded Community Service Districts in California, struggles to balance its budget under the strain unfunded state mandates and current constraints of limited property tax funding
2) Replacement e-vehicles are still expensive and for the most part lack sufficient power for many tasks required to maintain critical infrastructure in a rural environment.
3) E-vehicles are becoming less available both at affordable prices and in sufficient numbers due to the President's turn away from renewable energy technology.
Vehicles that that need to be categorically exempted from the regulations the same manner as those found in part (c) of § 2013 of title 13 of the California code of regulations to include those vehicles that respond to, assist in and recover from disasters and emergencies to include: water utility vehicles, flood protection vehicles, sewer utility vehicles, electric utility vehicles, fire prevention vehicles, fire protection vehicles, search and rescue vehicles, and disease and vector control vehicles.

We respectfully request that you amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most.

Sincerely,
Ben Dewell
Director, Stallion Springs Community Service District
27800 Stallion Springs Dr.
Stallion Springs, CA 93561
661-822-3268
board4@stallionspringscsd.com

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Comment From: Councilmember Drew Bessinger (Drew Bessinger)

4/15/26 @ 9:41 AM

Please find attached the written comment from Clovis City Councilmember Drew Bessinger.

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Comment From: Palmdale Water District (Judy Shay)

4/15/26 @ 9:40 AM

Palmdale Water District (PWD) greatly appreciates the time and effort that has gone into the 15-day comment draft that has been published for public comment. While the goals of these regulations are laudable, the reality remains that we cannot safely...↓ serve our communities unless emergency support vehicles are exempted.

PWD serves a community in the Antelope Valley located in north Los Angeles County, that spans approximately 187 square miles. Our community of more than 127,000 people relies on us daily for clean, safe water for potable use and for providing water during fire emergencies. We provide essential 24/7 services, including water supply, water distribution, mutual aid to other agencies, and emergency response during wildfires, earthquakes, floods and droughts. During emergencies, PWD fleet vehicles must travel within our service boundaries and beyond. These vehicles must be capable of operating 24 hours a day and need to be refueled quickly for us to be able to meet emergency needs.

To prevent unnecessary loss of life and property in the communities we serve, please reconsider the amendments respectfully requested in the October 7 letter submitted by the California Special Districts Association, League of California Cities, and California State Association of Counties, collectively representing our state's 5,000 local agencies and 40 million residents.

Local agencies like ours continue to do our part in achieving the State's climate and emissions goals. Our proposed amendments will enable us to better meet this challenge and effectively navigate the current Advanced Clean Fleets (ACF) mandates and their associated ambitious compliance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating unnecessary challenges in complying while maintaining the many critical services Californians rely upon for their most essential daily needs as well as during emergencies and disasters.

Vehicles that need to be categorically exempted from the regulations in the same manner as those found in part (c) of § 2013 of title 13 of the California code of regulations are to include those vehicles that respond to, assist in and recover from disasters and emergencies, include: water utility vehicles, flood protection vehicles, sewer utility vehicles, electric utility vehicles, fire prevention vehicles, fire protection vehicles, search and rescue vehicles, and disease and vector control vehicles.

Palmdale Water District respectfully requests that you amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most.

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Comment From: City of Los Alamitos (Eleanor Granflor)

4/15/26 @ 9:25 AM

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Comment From: Stallion Springs CSD (jeff stock)

4/15/26 @ 9:23 AM

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Comment From: Tahoe City Public Utility Dist... (Dan Lewis)

4/15/26 @ 9:10 AM

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Comment From: Stallion Springs Community Ser... (Laura Lynne Wyatt)

4/15/26 @ 9:09 AM

We respectfully request that you amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most.

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Comment From: Rincon del Diablo Municipal Wa... (Jeff Umbrasas)

4/15/26 @ 9:03 AM

Please find the attached Comment Period Response Letter from Rincon del Diablo Municipal Water District, respectfully requesting amendments to ACF exemptions to include various water and wastewater vehicles that respond to emergencies and disasters. ...↓

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Comment From: City of Tulare (Melissa Wilcox)

4/15/26 @ 6:47 AM

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Comment From: Leucadia Wastewater District (Paul J. Bushee)

4/15/26 @ 12:00 AM

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Comment From: Beaumont-Cherry Valley Water D... (Dan Jaggers)

4/15/26 @ 12:00 AM

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Comment From: Crestline Lake Arrowhead Water... (Jennifer Spindler)

4/14/26 @ 4:29 PM

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Comment From: City of Kerman, Fresno County (John Jansons)

4/14/26 @ 4:01 PM

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, co...↓

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Comment From: Inverness Public Utility Distr... (Shelley Redding)

4/14/26 @ 3:19 PM

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Comment From: El Dorado Irrigation District (Pravani Vandeyar)

4/14/26 @ 3:14 PM

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Comment From: City of Cypress (Jason Machado)

4/14/26 @ 2:09 PM

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Comment From: Big Bear City Community Servic... (Glenn Jacklin)

4/14/26 @ 1:30 PM

Big Bear City Community Services District respectfully requests that you consider the proposed exemptions for emergency support vehicles. Please include this letter as part of the growing number of comments from local agencies supporting the Californ...↓

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Comment From: Fallbrook Public Utility Distr... (Jack Bebee)

4/14/26 @ 1:28 PM

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Comment From: Helen Barber

4/14/26 @ 11:47 AM

None of these changes are going to make California safer for Californians.Most Californians reject these ridiculous standards as a whole. The elected officials arent doin the bidding of the people. Theyre doing the bidding of special interests. Every...↓

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Comment From: Ca Special Districts Assoc, Ca... (Brittney Barsotti)

4/14/26 @ 11:17 AM

April 14, 2026
Clerk of the Board
California Air Resources Board
1001 I Street, Sacramento, CA 95814

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

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Comment From: City of Encinitas/ San Dieguit... (Isam Hireish)

4/14/26 @ 11:07 AM

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Comment From: North Tahoe Public Utility Dis... (Bradley Johnson)

4/14/26 @ 10:40 AM

April 14, 2026

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

RE: Advanced Clean Fleets 15-Day Comment Period Response

Chair Lauren Sanchez and the Members of the California Air Resources Board:

On behal...↓f of the North Tahoe Public Utility District (NTPUD), we appreciate the time and effort that has gone into the 15-day comment draft that has been published for public comment.

While the goals of these regulations are laudable, the reality remains that we cannot safely serve our communities unless emergency support vehicles are exempted from the proposed Advanced Clean Fleets (ACF) regulations.

The NTPUD provides water and wastewater services to the communities of Kings Beach, Tahoe Vista, Brockway Vista, Carnelian Bay, Cedar Flat, and Agate Bay. We serve nearly 4,000 water customers with 52 miles of water pipelines and over 5,200 sewer customers through 75 miles of sewer pipe, maintaining over 370 fire hydrants, 20 pumping stations, and 4.65 million gallons of water storage.

The NTPUD operates at elevations above 6,200 feet, where heavy snowfall, freezing temperatures, and limited road access are common in the winter. During emergencies, our vehicles must travel steep, snow-covered roads, run for hours at a time in sub-zero temperatures, and reach remote infrastructure sites. Our vehicles are essential to maintaining water pressure for fire suppression efforts and keeping our sewer collection systems operational under heavy demand, at all hours of the day.

To prevent unnecessary loss of life and property in the communities we serve, we request your reconsideration of the amendments respectfully requested in the October 7th letter submitted by the California Special Districts Association, League of California Cities, and California State Association of Counties on behalf of the state's 5,000 local agencies and 40 million residents.

Specifically, we urge the Board to categorically exempt emergency support vehicles in the same manner as those found in part (c) of § 2013 of title 13 of the California Code of Regulations.

This exemption should extend to all vehicles that respond to, assist in, and recover from disasters and emergencies, including water utility vehicles, sewer utility vehicles, flood protection vehicles, electric utility vehicles, fire prevention and protection vehicles, search and rescue vehicles, and disease and vector control vehicles.

Vehicles that that need to be categorically exempted from the regulations the same manner as those found in part (c) of § 2013 of title 13 of the California code of regulations to include those vehicles that respond to, assist in and recover from disasters and emergencies to include: water utility vehicles, flood protection vehicles, sewer utility vehicles, electric utility vehicles, fire prevention vehicles, fire protection vehicles, search and rescue vehicles, and disease and vector control vehicles.

Local agencies like ours continue to do our part in achieving the State's climate and emissions goals. These proposed amendments will enable us to better meet this challenge and effectively navigate the current ACF mandates and their associated ambitious compliance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating unnecessary challenges in complying while maintaining the many critical services Californians rely upon for their most essential daily needs as well as during emergencies and disasters.

We respectfully request that you amend the ACF exemptions to allow our water and sewer utility vehicles that support emergency services to continue serving our communities when we need them most.
Thank you for your consideration,

Bradley A. Johnson, P.E.
NTPUD General Manager  

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Comment From: Burbank Paradise Fire Departme... (Chief Peter Golling)

4/14/26 @ 9:52 AM

Burbank Paradise Fire Protection District
Stanislaus County, California

Date: 4/14/2026

To: California Air Resources Board (CARB)
Subject: URGENT: Request for Full Emergency Vehicle Exemption – Advanced Clean Fleets Regulation

Dear Members of the ...↓

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Comment From: Kern Mosquito and Vector Contr... (La Thao)

4/14/26 @ 9:26 AM

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Comment From: West Stanislaus County Fire Pr... (Jeff Frye)

4/14/26 @ 9:22 AM

April 14, 2026

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

RE: Advanced Clean Fleets 15-Day Comment Period Response

Chair Lauren Sanchez and the Members of the California Air Resources Board:

We great...↓ly appreciate the time and effort that has gone into the 15-day comment draft that has been published for public comment. While the goals of these regulations are laudable, the reality remains that we cannot safely serve our communities unless emergency support vehicles are exempted.

At West Stanislaus County Fire Protection District, We serve a community spanning 620 square miles. Our community relies on us for fire suppression, rescue mitigation, and emergency medical services . During emergencies our vehicles must travel and run for several hours at a time, in all weather conditions, often in remote areas.

To prevent unnecessary loss of life and property in the communities we serve, please reconsider the amendments respectfully requested in the October 7th letter submitted by the California Special Districts Association, League of California Cities, and California State Association of Counties, collectively representing our state's 5,000 local agencies and 40 million residents.

Local agencies like ours continue to do our part in achieving the State's climate and emissions goals. Our proposed amendments will enable us to better meet this challenge and effectively navigate the current Advanced Clean Fleets (ACF) mandates and their associated ambitious compliance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating unnecessary challenges in complying while maintaining the many critical services Californians rely upon for their most essential daily needs as well as during emergencies and disasters.
Vehicles that need to be categorically exempted from the regulations in the same manner as those found in part (c) of § 2013 of title 13 of the California code of regulations include those vehicles that respond to, assist in and recover from disasters and emergencies to include: water utility vehicles, flood protection vehicles, sewer utility vehicles, electric utility vehicles, fire prevention vehicles, fire protection vehicles, search and rescue vehicles, and disease and vector control vehicles.
We respectfully request that you amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most.
Thank you for your consideration.

Respectfully,

Jeff Frye
Fire Chief

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Comment From: Leann Verdick (Leann Verdick)

4/14/26 @ 9:06 AM

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Comment From: Bryan Bravo

4/14/26 @ 8:48 AM

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Comment From: County of Riverside Transporta... (Richard Miller)

4/14/26 @ 7:53 AM

I would like to see some consideration for counties due to the square miles (7200) they need to cover and the lack of range on class 6,7,8 trucks. One more note, the only "in production" BEV pickup has a 5'11" and the Max range battery combination pa...↓

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Comment From: Honey Lake Valley Resource Con... (Kelsey Siemer)

4/13/26 @ 5:24 PM

Please see attached letter.

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Comment From: Ronald Berg

4/13/26 @ 5:16 PM

04/13/26

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

RE: Advanced Clean Fleets 15-Day Comment Period Response

Chair Lauren Sanchez and the Members of the California Air Resources Board:

The 15-day com...↓ment draft that has been published for public comment is too short. While the goals of these regulations are laughable, the reality remains that electric vehicles are good only for specific situations and purposes.

Electric vehicles are not a good fit for emergency vehicles  
To prevent unnecessary loss of life and property in the communities we serve, please eliminate the amendments respectfully requested in the October 7th letter submitted by the California Special Districts Association, League of California Cities, and California State Association of Counties, collectively representing our state's 5,000 local agencies and 40 million residents.

Local agencies like ours continue to do our part in achieving the State's climate and emissions goals. Our proposed amendments will enable us to better meet this challenge and effectively navigate the current Advanced Clean Fleets (ACF) mandates and their associated ambitious compliance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating unnecessary challenges in complying while maintaining the many critical services Californians rely upon for their most essential daily needs as well as during emergencies and disasters.

Vehicles that that need to be categorically exempted from the regulations the same manner as those found in part (c) of § 2013 of title 13 of the California code of regulations to include those vehicles that respond to, assist in and recover from disasters and emergencies to include: water utility vehicles, flood protection vehicles, sewer utility vehicles, electric utility vehicles, fire prevention vehicles, fire protection vehicles, search and rescue vehicles, and disease and vector control vehicles and every other vehicle on the road.
We respectfully request that you amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most.

Thank you for your consideration,
Ron Berg
  
  

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Comment From: Michael Thornton

4/13/26 @ 4:41 PM

Vehicles supporting water and wastewater operations are essential for protecting public health, safety, and environmental compliance, particularly during emergencies such as system failures, flooding, and contamination events. These vehicles must be ...↓

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Comment From: East Niles Community Services ... (Timothy Ruiz)

4/13/26 @ 4:14 PM

See attached letter.

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Comment From: City of Oceanside (Terry Gorman Brown)

4/13/26 @ 4:06 PM

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