(2nd 15-Day) Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations

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Comment From: Lll D

6/16/26 @ 9:35 PM

As a CALIFORNIAN and longtime environmentally concerned individual....
I have concerns with changes to "clean fleets and low carbon standards " being altered and or erased by any attempts from the Trump administration/Republican party to deregulate f...↓

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Comment From: Associated General Contractors... (Tresten Keys )

6/16/26 @ 8:30 PM

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Comment From: CMUA/SCPPA/NCPA (Derek Dolfie)

6/16/26 @ 7:45 PM

Please see the attached comments submitted on behalf of the California Municipal Utilities Association (CMUA), the Southern California Public Power Authority (SCPPA), and the Northern California Power Agency (NCPA). Thank you.

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Comment From: Dan Sunseri

6/16/26 @ 7:34 PM

Out of 342 million Americans, 99.9% rely entirely on public utilities for daily survival. While CA ACF rules rightly exempt police and fire vehicles, excluding utility trucks from these same exemptions is a critical oversight. Utility vehicles are fr...↓

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Comment From: Recology (Julia Mangin)

6/16/26 @ 6:09 PM

Please see attached Recology comments.

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Comment From: Crescenta Valley Water Distric... (James Lee)

6/16/26 @ 5:46 PM

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Comment From: Hurner Government Relations an... (Greg Hurner)

6/16/26 @ 5:34 PM

Please see attached comments from Miller Industries.

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Comment From: Inland Empire Utilities Agency (Joe Sturges)

6/16/26 @ 5:24 PM

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Comment From: City of Lakewood (Paolo Beltran)

6/16/26 @ 4:58 PM

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Comment From: Clean Energy (Ryan Kenny)

6/16/26 @ 4:56 PM

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Comment From: WM of California (Christine Wolfe)

6/16/26 @ 4:41 PM

Please see attached WM's comments on the 2nd 15-Day ACF State and Local Government package.

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

6/16/26 @ 4:05 PM

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

6/16/26 @ 4:01 PM

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Comment From: National Waste & Recycling Ass... (Kirk M. Sander)

6/16/26 @ 3:58 PM

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Comment From: Sacramento Municipal Utility D... (Nicole Looney)

6/16/26 @ 3:54 PM

SMUD Comments Re Proposed Second 15-Day Amendments to the Advanced Clean Fleets Regulation.

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Comment From: CalCIMA (Suzanne Seivright-Sutherland)

6/16/26 @ 3:34 PM

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Comment From: Teichert (Nicholas Armstrong)

6/16/26 @ 3:28 PM

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Comment From: The Transport Project (Katie Vassalli)

6/16/26 @ 3:00 PM

Please see attached letter.

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Comment From: Vallejo Flood and Wastewater D... (Jennifer Harrington)

6/16/26 @ 2:58 PM

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Comment From: NRDC/CCA/UCS/EDF/Earthjustice (Bill Magavern)

6/16/26 @ 2:48 PM

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Comment From: City of Fairfield (David Renschler)

6/16/26 @ 2:32 PM

The City of Fairfield would like to submit the attached letter commenting on the 2nd 15-day proposed amendments to the ACF.

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Comment From: Alameda County Water District (Rangarajan Sampath)

6/16/26 @ 2:24 PM

The Alameda County Water District (ACWD) appreciates the opportunity to submit comments on the California Air Resources Board (CARB) proposed Second 15-Day Modifications to the Advanced Clean Fleets ("ACF") regulations amendments. ACWD requests cons...↓

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Comment From: Eric Grubb (Eric Grubb)

6/16/26 @ 2:05 PM

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Comment From: Construction Industry Air Qual... (Michael Lewis)

6/16/26 @ 1:55 PM

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Comment From: City of Roseville (Noelle Mattock)

6/16/26 @ 1:54 PM

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Comment From: Dublin San Ramon Services Dist... (Sara Tom)

6/16/26 @ 1:47 PM

Please see our attached letter. Thank you.

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Comment From: Los Angeles Department of Wate... (Andrea Villarin)

6/16/26 @ 1:41 PM

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Comment From: Southern California Contractor... (Clayton Miller)

6/16/26 @ 1:31 PM

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Comment From: City of Stanton (Cesar Rangel)

6/16/26 @ 1:20 PM

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Comment From: Hannah Abdoo

6/16/26 @ 1:14 PM

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

6/16/26 @ 12:41 PM

Metropolitan's Comments on the Second 15-Day Rulemaking Package for the Advanced Clean Fleets Regulation

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Comment From: San Diego County Water Authori... (Eva Plajzer)

6/16/26 @ 12:35 PM

Please find attached the San Diego County Water Authority's comments on the second 15-day proposed amendments to the Advanced Clean Fleets Regulations.

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Comment From: Calaveras County Water Distric... (Damon Wyckoff)

6/16/26 @ 12:20 PM

June 16, 2026
Comment letter submitted via electronic commenting system

Clerk's Office
California Air Resources Board
1001 I Street, Sacramento, California 95814

RE: Comment Letter – Advanced Clean Fleets Regulation Amendments/Additional 15...↓

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Comment From: City of Sacramento (Consuelo Hernandez)

6/16/26 @ 11:34 AM

Attached please find comments from the City of Sacramento in opposition to the Proposed Second 15-Day Amendments to the Advanced Clean Fleets Regulation.

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Comment From: Las Virgenes Municipal Water D... (David Pedersen)

6/16/26 @ 11:32 AM

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

6/16/26 @ 11:31 AM

Attached are ACWA comments to the latest 15 day changes to the Advanced Clean Fleets regulation.

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

6/16/26 @ 11:30 AM

Please see the attached letter with comments from the Otay Water District on (2nd 15-Day) Proposed Amendments to the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations. Thank you.

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Comment From: De Luz Community Service Distr... (James Emmons)

6/16/26 @ 11:29 AM

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Comment From: Benjamin Lu

6/16/26 @ 11:29 AM

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

6/16/26 @ 11:19 AM

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Comment From: Sacramento Area Sewer District (Rosario Cortés)

6/16/26 @ 11:12 AM

June 16, 2026

Submitted electronically via https://ww2.arb.ca.gov/lispub/comm/bclist.php

Clerks' Office
California Air Resources Board
1001 I Street
Sacramento, CA 95814

RE: Comments on the Second 15-Day Amendments to the Advanced Clean Fleets R...↓

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

6/16/26 @ 11:05 AM

Please find attached the California Association of Sanitation Agencies (CASA) comments on the second 15-Day Changes to the Advanced Clean Fleets (ACF) Regulation. We are committed to working with CARB staff to ensure our members can continue providin...↓

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Comment From: Burbank Water and Power (Jason Maruca)

6/16/26 @ 10:38 AM

Please see our attached comment letter

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

6/16/26 @ 10:09 AM

Resource Recovery Coalition of California Comments on Second 15-Day Notice of
Proposed Changes to the Advanced Clean Fleets Regulation – State and Local Government
Fleet (SLG) Provisions

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Comment From: Fontana Mayor and City Council... (Acquanetta Warren)

6/16/26 @ 10:01 AM

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Comment From: Clean Water SoCal (David L. Rothbart)

6/16/26 @ 9:33 AM

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Comment From: Eastern Municipal Water Distri... (Joe Mouawad)

6/16/26 @ 9:04 AM

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Comment From: Clean Water SoCal (David Rothbart)

6/16/26 @ 8:48 AM

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Comment From: Yuima Municipal Water District (Amy Reeh)

6/16/26 @ 8:28 AM

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Comment From: Encina Wastewater Authority (Scott McClelland)

6/16/26 @ 7:17 AM

Encina Wastewater Authority strongly requests the CARB Board require further changes to the Proposed 15-day Amendments, as reflected in comment letters submitted by the CA Association of Sanitation Agencies along with the joint comments from CA Speci...↓

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

6/16/26 @ 7:10 AM

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Comment From: City of Artesia (Carmen Zambrano)

6/15/26 @ 4:42 PM

The City of Artesia respectfully submits the attached letter commenting on the Second 15-Day Rulemaking Package for the Advanced Clean Fleets and Low Carbon Fuel Standard Regulations. While the City remains committed to transitioning its fleet and ac...↓

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Comment From: Zone 7 Water Agency (Alameda C... (Carol Mahoney)

6/15/26 @ 4:18 PM

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Comment From: Placer County Water Agency (Anthony Firenzi)

6/15/26 @ 3:22 PM

Chair Sanchez and Members of the California Air Resources Board:
On behalf of the Placer County Water Agency (PCWA), we appreciate the opportunity to comment on the second 15-day proposed amendments to the Advanced Clean Fleets (ACF) Regulation.
Plac...↓er County Water Agency serves a region spanning 1,500 square miles. We serve drinking water to a population of about a quarter million people and agricultural water to thousands of acres of land along a 170-mile-long canal system. Most pertinent to the proposed regulations, PCWA operates a hydropower system in the headwaters of the American River watershed. This hydropower system begins with large dams and powerhouses near the summit of the Sierra but is operated out of headquarters in Auburn and Foresthill. Both our canal system and our hydropower system necessitate hours of driving with duty trucks, and thousands of feet in elevation gain for the hydropower system. These trips are necessary in all seasons, including dangerously hot and cold temperatures.
In our April 15, 2026, comment letter, PCWA requested that our utility vehicles 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. In addition, we requested a firm commitment from CARB to reevaluate the ACF regulation through a public process before 2030. A scheduled reevaluation would allow the Board and staff to assess whether the regulation accurately reflects real-world Zero Emissions Vehicle (ZEV) market conditions. These concerns remain unresolved.
Unfortunately, the second 15-day amendments move the regulation further away from a workable framework. Rather than addressing longstanding concerns raised by local governments, water agencies, and other essential service providers, the latest amendments introduce significant new requirements that expand the scope of the regulation in ways that were neither contemplated in the original proposal nor adequately vetted through the public process.
Expansion of "Fleet Owner" Definition and Inclusion of Contracted Services
PCWA is concerned with the revised definition of "fleet owner" and related provisions that extend compliance obligations to vehicles associated with contracted services and entities performing work on behalf of public agencies.
By including vehicles operated under contracts, and contracted services utilizing vehicles, CARB has introduced a substantial policy change that reaches far beyond the direct ownership and operation of public agency fleets. This change effectively extends regulatory obligations to contractors, vendors, consultants, construction firms, emergency service providers, and other entities that support essential public services.
Contracted services are not optional for PCWA to fulfill its public service. We routinely rely on outside contractors to perform:
• Emergency pipeline and infrastructure repairs
• Vegetation management and fuel reduction projects
• Specialized maintenance and construction services
• Emergency response and disaster recovery activities
• Delivery of chemicals and other supplies
• Routine services like landscaping and equipment maintenance
Many of these services require specialized vehicles and equipment that are not currently available in zero-emission configurations suitable for rugged terrain, remote locations, or emergency response conditions.
The practical effect of the proposed amendments is to hold public agencies responsible for the compliance status of vehicles over which they have little or no operational control. This creates significant uncertainty for existing service agreements and future procurements and may discourage contractors from bidding on critical public works and emergency response projects.
In addition, the amendments create new questions regarding reporting, compliance verification, and potential enforcement responsibilities. Public agencies should not be placed in the position of tracking contractor fleet compliance, collecting and maintaining compliance records, or assuming liability for vehicles they do not own, operate, or control. These new administrative burdens and compliance obligations have not been adequately analyzed and represent a significant departure from the original scope of the regulation.
Significant New Regulatory Language Cannot Be Adopted Through a 15-Day Process
PCWA is equally concerned with the procedural implications of these amendments.
The inclusion of contracted vehicles and services utilizing vehicles represents a significant expansion in regulatory scope that affects an entirely new class of stakeholders. Contractors, vendors, service providers, equipment operators, and construction firms that were not previously understood to be directly regulated by these provisions now face potentially substantial compliance obligations and business impacts.
These stakeholders deserve a meaningful opportunity to review, analyze, and comment on the proposal.
The purpose of the 15-day review process is to provide public review of modifications that are sufficiently related to the original proposal. It is not intended to serve as the vehicle for introducing significant new regulatory concepts that materially expand the scope of regulated entities.
PCWA believes the latest amendments raise substantial questions regarding whether affected stakeholders have received adequate notice and opportunity for comment. At a minimum, the changes warrant a broader stakeholder engagement process and additional opportunities for public review.
Request for Additional Review and Stakeholder Engagement
Given both the unresolved concerns identified in the previous comment period and the significant new issues introduced through the second 15-day amendments, PCWA respectfully request that you return to the first version of 15-day language to not include "contracting vehicles or services using vehicles," amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most, and that you evaluate the ZEV market conditions ahead of the due date for compliance.

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Comment From: CSDA, CSAC, RCRC, Cal Cities, ... (Brittney Barsotti)

6/15/26 @ 1:52 PM

June 15, 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 2nd 15-Day Amendment Commen...↓

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Comment From: Town of Truckee (Hilary Hobbs)

6/15/26 @ 1:47 PM

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

The Town of Truckee supports California's goals of red...↓ucing greenhouse gas emissions and advancing zero emission fleet technologies including electrification. The Town has adopted aggressive targets to reduce emissions to 40% below 2008 levels by 2030, to 80% by 2040 and to achieve carbon neutral by 2045. Our Climate Action Plan includes measures supporting the transition to electric vehicles both in the community and in our own fleet. However, we want to respectfully share some concerns that the proposed amendments would significantly expand the practical reach of the ACF regulation, creating significant operational challenges, adding administrative burdens and increasing costs.

Local governments, including the Town of Truckee, rely on contractual arrangements to provide essential services, including waste collection, public works construction, and infrastructure maintenance. Incorporating CARB-specific requirements into municipal contracts, as contemplated by these amendments, will very likely increase procurement costs, reduce competition, and ultimately increase costs borne by taxpayers. Additionally, we are concerned that under the proposed amendments, cities would be required to incorporate CARB-specific requirements into municipal contracts, take on significant recordkeeping, and assume responsibility for monitoring compliance by third-party fleets. 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.

We are also concerned that the proposed modifications do not adequately account for the operational realities of local government fleets, particularly those that support emergency response. During emergencies, local government fleet vehicles must operate continuously for extended periods, often in extreme conditions, to support fire prevention and response, search and rescue, winter storm recovery, and the delivery and maintenance of essential utilities. Emergency preparedness requires maintaining vehicles that can respond immediately to these critical events and often requires 24/7 operation. Zero-emission alternatives are not yet available or operationally suitable for some of the specialized applications essential to emergency response, preparedness, and recovery. At a minimum, we request that CARB provide categorical exemptions for specialized vehicles supporting emergency response and preparedness operations that are critical to our community safety.

The Town of Truckee is deeply committed to advancing the State's climate objectives. We believe that these objectives are best achieved through policies that are aggressive, yet also practical and reflective of the operational realities facing local governments. We believe the current proposal falls short of that standard and respectfully request that CARB reconsider the proposed amendments.

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Comment From: Soquel Creek Water District (Melanie Schumacher)

6/15/26 @ 1:44 PM

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

6/15/26 @ 12:57 PM

Please see attached regarding CFCA's comments.

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Comment From: San Francisco Public Utilities... (Scott Ammon)

6/15/26 @ 11:08 AM

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Comment From: Turlock Irrigation District (Austin Avery)

6/15/26 @ 11:07 AM

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Comment From: Kings River Conservation Distr... (Charlotte Gallock)

6/15/26 @ 9:11 AM

Please see the attached 2 page letter. Thank you for the opportunity to comment.

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

6/15/26 @ 8:06 AM

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Comment From: Big Bear Area Regional Wastewa... (David Lawrence)

6/15/26 @ 12:00 AM

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Comment From: Western States Trucking Associ... (John Kinsey)

6/12/26 @ 5:15 PM

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Comment From: Padre Dam Municipal Water Dist... (Kyle Swanson)

6/12/26 @ 2:50 PM

June 12, 2026

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

RE: Advanced Clean Fleets 2nd 15-Day Comment Period Response

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

We appreci...↓

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Comment From: Jon Curry (Jon Curry)

6/12/26 @ 12:31 PM

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Comment From: Jason Martin (Jason Martin)

6/12/26 @ 11:24 AM

Rancho Water recommends submitting the 1st April 2026 15-day version of the ACF revisions, and postponing these latest revisions for more development and refinement of appropriate language and procedures for successful implementation.

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Comment From: Twain Harte Community Services... (Tom T)

6/12/26 @ 9:54 AM

We appreciate the effort that has gone into the second 15-day comment period draft (June 1, 2026) of the Advanced Clean Fleets (ACF) regulations. The goals of the draft regulations are lofty and admirable; however, the reality remains that Twain Hart...↓e Community Services District (THCSD) and many other critical local agencies will not be able to keep our communities safe unless emergency support vehicles are exempted. The exemptions in the current regulation and draft amendments remain wholly and dangerously insufficient.

THCSD serves provides water, sewer, fire and park services to the small mountain community of Twain Harte where severe winter storms and extended power outages are normal during winter months. For example, in February, heavy snows and winds knocked down hundreds of trees, causing 6-day power outages and a nearly 3-week water supply outage. Our entire 8-vehicle water/sewer fleet was utilized around the clock to make sure our community continued to have access to water for drinking and sanitation (the human right to water) and for firefighting (house fires are more frequent during winter power outages when people must rely on wood stoves for heat). Our fleet also worked to prevent sewer overflows, which threaten public health and safety (these are more common during storms where stormwater infiltrates and overwhelms sewer lines). It would have been impossible to keep a ZEV fleet continuously charged and operational during this extended power outage and the proposed ACF amendments do not exempt most of our small water/sewer fleet as emergency vehicles. With the proposed ACF amendments in place, we would not have been able to keep water flowing to our community or prevented sewer overflows, creating a serious public health and safety situation.

To prevent unnecessary loss of life and property, we respectfully request:
Vehicles need to be categorically exempted from the ACF regulations in the same manner as those found in part (c) of § 2013 of title 13 of the California Code of Regulations, which include vehicles that respond to, assist in and recover from disasters and emergencies (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).

Please amend the ACF exemptions to allow our vehicles that support emergency services to continue serving our communities when we need them most. Public safety depends on it.

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Comment From: City of Glendale, Public Works... (Daniel Hernandez)

6/12/26 @ 9:43 AM

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Comment From: Valley Center Municipal Water ... (Alisa Nichols)

6/12/26 @ 8:31 AM

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Comment From: Jason Cole

6/12/26 @ 4:34 AM

[Date: June 12, 2026]

Office of Administrative Law

300 Capitol Mall, Suite 1250

Sacramento, California 95814

RE: Comments on the Proposed Readoption of Emergency Vehicle Emissions Regulations

I am writing to share my concerns regarding the Calif...↓ornia Air Resources Board's (CARB) proposal to readopt the "Emergency Vehicle Emissions Regulations" for an additional 90 days.

While I recognize the importance of long-term environmental goals, I am concerned about the continued reliance on emergency rulemaking. Extending these regulations for successive 90-day periods creates a cycle of uncertainty that complicates planning for businesses and residents alike. Regular, predictable regulatory processes are essential for economic stability and for building public trust in how these policies are implemented.

I am particularly troubled by how these requirements, specifically as they apply to government contractors, are stifling competition in the marketplace. By requiring that private fleets—which are often contracted to perform essential public services—meet strict zero-emission vehicle (ZEV) mandates, the state is inadvertently creating a significant barrier to entry.

For many smaller, local, or highly specialized contractors, the transition to ZEVs is not merely an operational choice; it is an immense financial hurdle that requires access to capital and infrastructure that these businesses simply do not possess. When public agencies force these requirements into their procurement and bidding processes, they are unintentionally narrowing the field of qualified vendors. The result is a system where only the largest, most well-capitalized firms can afford to bid on government contracts. This limits healthy competition, potentially drives up costs for taxpayers, and forces out smaller, reliable service providers who play a critical role in our local economy.

The current approach lacks the transparency and broad public consultation that a permanent rulemaking process would provide. These policies have far-reaching impacts on the cost and availability of services we rely on daily, and they should not be managed through continuous stopgap measures that inadvertently disadvantage smaller businesses.

I respectfully urge the Office of Administrative Law to consider these impacts. Please encourage a transition toward a framework that avoids perpetual emergency status, allows for more stability, and ensures that the transition to new technology does not come at the expense of fair and open competition in government contracting.

Thank you for your time and for the opportunity to comment.

Sincerely,

Jason Cole

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Comment From: Vallecitos Water District (Chris Robbins)

6/11/26 @ 5:18 PM

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Comment From: City of Encinitas (Isam Hireish)

6/11/26 @ 4:00 PM

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Comment From: Santa Margarita Water District (Alyson Piguee)

6/11/26 @ 3:39 PM

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Comment From: League of California Cities (Damon Conklin)

6/11/26 @ 1:47 PM

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Comment From: South Tahoe Public Utility Dis... (Shelly Thomsen)

6/11/26 @ 10:57 AM

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Comment From: Olivenhain Municipal Water Dis... (Kimberly Thorner)

6/10/26 @ 4:14 PM

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Comment From: Consolidated Mosquito Abatemen... (Jodi Holeman)

6/10/26 @ 3:32 PM

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Comment From: Leucadia Wastewater District (Paul Bushee)

6/09/26 @ 3:40 PM

See Attached Letter.

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Comment From: Mission Springs Water District (Brian Macy)

6/09/26 @ 8:52 AM

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

6/08/26 @ 3:48 PM

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Comment From: Vista Irrigation District (Brett Hodgkiss)

6/04/26 @ 6:19 AM

See attached for comments on the Proposed Amendments to the Advanced Clean Fleets Regulations.

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Comment From: Delano Mosquito Abatement Dist... (Thai Thao)

6/03/26 @ 2:48 PM

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Comment From: San Miguel Consolidated Fire P... (Andy Lawler)

6/03/26 @ 12:05 PM

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

We greatly appreciate the time and effort that has gone into the second 15-day comment period draft of the Advanced Clean Fleets (ACF) regulation published June 1, 2026 for pub...↓lic comment. While the goals of these regulations are laudable, the reality remains that we cannot safely serve our communities unless emergency support vehicles are excluded from the regulation.

At San Miguel Fire & Rescue, we serve over 150,000 residents and businesses across more than 50 square miles, responding to over 15,000 9"1 calls annually for emergency medical services and fire suppression. Emergency response vehicles must idle for extended periods to support critical functions, including emergency lighting, communications, onboard computers, water pumping during firefighting, and refrigeration of temperature-sensitive medications. Continuous engine operation is also essential to maintain heating and cooling systems necessary for both equipment functionality and personnel readiness.

To prevent unnecessary loss of life and property in the communities we serve, please reconsider the amendments respectfully requested in the April 14th 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 ACF regulation and its ambitious compliance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating untenable and 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.

The exemptions in the current regulation and draft amendments remain wholly and dangerously insufficient.

In the same manner as the vehicle categories currently identified in part (c) of § 2013 of title 13 of the California code of regulations, we respectfully request a categorical exclusion for vehicles that respond to, assist in and recover from disasters and emergencies, including: 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.

Thank you for your consideration,
Andy Lawler, Fire Chief

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Comment From: Tuolumne Utilities District (Abby Parcon)

6/03/26 @ 7:20 AM

We greatly appreciate the time and effort that has gone into the second 15-day comment period draft of the Advanced Clean Fleets (ACF) regulation published June 1, 2026, for public comment. While the goals of these regulations are laudable, the reali...↓ty remains that we cannot safely serve our communities unless emergency support vehicles are excluded from the regulation.

Tuolumne Utilities District serves a geographically dispersed rural service area spanning approximately 1,400 square miles, encompassing mountainous and remote terrain. Our customers rely on the District for continuous water and wastewater services that are essential to public health, fire protection, and emergency response. During emergency events—including wildfires, severe storms, flooding, and extended power outages—District vehicles must travel long distances to access critical infrastructure and are required to operate continuously for extended periods, often away from the main TUD yard for 12-24 hours at a time, under rugged terrain, limited access, and adverse weather conditions. The reliability, range, and refueling flexibility of these vehicles are critical to maintaining uninterrupted service and protecting life and property during emergency response operations.

To prevent unnecessary loss of life and property in the communities we serve, please reconsider the amendments respectfully requested in the April 14th 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 ACF regulation and its ambitious compliance deadlines. Of critical concern to our community, the ACF mandates on local agencies are creating untenable and 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.

The exemptions in the current regulation and draft amendments remain wholly and dangerously insufficient.

In the same manner as the vehicle categories currently identified in part (c) of § 2013 of title 13 of the California code of regulations, we respectfully request a categorical exclusion for vehicles that respond to, assist in and recover from disasters and emergencies, including: water and wastewater (sewer) utility vehicles.

Thank you for your time and consideration,

Don Perkins
General Manager