Comment Letter: Advanced Clean Fleets Regulation Amendments/45 Day Changes

Agency: California Air Resources Board

Subject: Advanced Clean Fleets Regulation Amendments/45 Day Changes

Letter Excerpt:

The Association of California Water Agencies (ACWA) appreciates the opportunity to provide comments on the proposed 45-day change amendments to the Advanced Clean Fleets (ACF) regulation (45-day changes) as required by Assembly Bill 1594 (Garcia, 2023) [AB 1594]. ACWA represents approximately 470 public water agencies that collectively deliver approximately 90 percent of the water in California for domestic, agricultural, and industrial uses. ACWA has participated in ACF since its conception, throughout its development, and now into the amendment stage. We support the state's goals that ACF aspires to reach; however, our members want to ensure that our role as essential public service providers is not jeopardized by ACF requirements. The 45-day changes proposed by California Air Resources Board (CARB) staff are a first step towards reflecting the additional flexibility needed by public agency utilities discussed in 2024. However, much more work is needed to ensure necessary changes are made to promote medium-and-heavy duty (MHD) fleet electrification, where feasible, without compromising public agency utilities from being able to maintain essential public services and critical operations, including during emergency events. The comments provided below respond directly to the 45-day changes proposed, and more crucially to where ACWA believes additional work needs to be accomplished through supplemental ACF amendments.

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