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

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Comment From: South Tahoe Public Utility Dis... (Paul Hughes)

4/13/26 @ 3:29 PM

Thank you for the time and effort that has gone into the 15-day comment draft. While the goals of these regulations are commendable, the reality remains that we cannot safely serve our community unless emergency support vehicles are exempted.

At So...↓uth Tahoe Public Utility District, we supply drinking water and provide sewage collection, treatment, and export to protect Lake Tahoe's delicate ecosystem. Managing this complex operation requires an uncommon environmental sensitivity. Our community relies on us for reliable and safe water supply and sewage collection, even during blizzards and extended power outages. Our operators work during extreme winter conditions and power outages to refuel generators to keep our 80 water and sewer field stations operating. Failure means a sewage spill into Lake Tahoe.

The Porter-Cologne Act requires that all recycled water be exported out of the Tahoe Basin. That means that every drop of water that goes down the drain in South Lake Tahoe, must be pumped 26 miles up and over a mountain pass. As such, we rely on a large pump station to export over 3.9 million gallons per day of recycled water. We need to be able to always access this facility. Cold temperatures, deep snow, and frequent power outages make reliable transportation critical for our operations.

To prevent unnecessary loss of life and property in the communities we serve, please reconsider the amendments 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.

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,
Paul Hughes
General Manager

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