Ed Staub & Sons is a family-owned fuel distributor serving customers across California and the broader Western United States. Our company supplies fuel to a wide range of essential sectors, including agriculture, commercial transportation, emergency ...↓
We are writing to express concern with the emergency rulemaking submitted by the California Air Resources Board (CARB), as it directly impacts how we plan, purchase, and operate our fleet. From an operator’s perspective, the proposal does not meet the requirements for emergency rulemaking under the California Administrative Procedure Act (APA) and introduces significant uncertainty into an already complex regulatory environment.
NO CLEAR “EMERGENCY”
The uncertainty CARB cites—related to federal actions affecting California’s vehicle emissions standards—is not new or unexpected. It is part of an ongoing legal and regulatory situation that fleet operators like us have been monitoring and planning around for some time. While the situation may be evolving, it does not rise to the level of a sudden or unforeseen emergency requiring immediate regulatory action.
Equally important, the proposed rule does not actually resolve this uncertainty. Instead, it formalizes a structure in which two different regulatory standards may apply at the same time. From our perspective, this approach risks prolonging confusion rather than addressing it, leaving fleet operators without a clear understanding of what standards will ultimately govern our operations.
NOT THE LEAST BURDENSOME APPROACH
Fleet operators make long-term capital investments based on clear and consistent regulatory signals. Decisions about vehicle purchases, replacement cycles, and infrastructure investments are made years in advance and require a high degree of certainty.
The proposed dual-standard framework—allowing both older and newer emissions standards to operate simultaneously—adds unnecessary complexity and risk to these decisions. Instead of simplifying compliance, it forces businesses to evaluate multiple potential regulatory outcomes and hedge against future legal developments.
A more practical and less burdensome approach would be to establish a single, consistent standard. Aligning with federal vehicle emissions standards would provide a clear compliance pathway, reduce administrative complexity, and allow fleet operators to move forward with greater confidence in their investment decisions.
LACK OF CLARITY FOR FLEET PLANNING
Maintaining two parallel regulatory systems creates real and immediate challenges for fleet planning. It is unclear which standards should guide vehicle procurement decisions today, how compliance will be evaluated if legal conditions change, and whether decisions made under one framework could expose us to enforcement risk in the future.
Fleet planning operates on multi-year timelines and involves significant financial commitments. Without clear guidance, businesses are left to make high-cost decisions in an environment where the rules may shift after those decisions are made. This undermines our ability to responsibly manage fleet turnover, budget for new equipment, and invest in supporting infrastructure.
In practice, this level of uncertainty discourages proactive compliance and leads to more cautious, delayed decision-making, which is counterproductive to both business and regulatory goals.
REAL-WORLD IMPACTS ON OPERATIONS
For fleets like ours, regulatory uncertainty translates directly into operational challenges. When the compliance pathway is unclear, vehicle purchases are often delayed as businesses wait for additional guidance or legal clarity. At the same time, manufacturers may adjust production or pricing strategies in response to regulatory complexity, limiting availability and increasing costs.
These dynamics slow fleet turnover and can force operators to retain older equipment longer than planned. This not only increases operating and maintenance costs but can also reduce overall efficiency.
The dual-standard framework also increases the risk of stranded investments. Vehicles purchased to comply with one standard may later be deemed insufficient if regulatory requirements change, creating financial losses that are difficult to absorb—particularly for family-owned businesses operating with limited margins.
CONCLUSION
For these reasons, we respectfully urge the California Office of Administrative Law to disapprove the proposed emergency regulation. Fleet operators need clear, stable, and predictable rules to make responsible long-term investment and operational decisions, and the current proposal does not provide that certainty.
We appreciate the opportunity to provide these comments and look forward to continued engagement on policies that support both environmental progress and a reliable, affordable fuel supply.
Thank you,
Jason Cole
Director of Sales | Retail Supply
530-524-1850
877-879-5792
jason.cole@edstaub.com
www.edstaub.com | www.myfastbreak.com
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