CARB Regulation: Flexibility for Vehicles Needed for Emergencies

Wildfire Prevention

Image of a Tehama County Resource Conservation District chip truck.

The horrific Park Fire of 2024 would have been even worse if CARB’s mandate on public agencies to use only ZEVs had been in effect. Work by Tehama County Resource Conservation District to reduce fuels – made possible by diesel-powered vehicles that have no equivalent in the ZEV marketplace – was instrumental to saving lives and property in the Mill Creek community. Countless other communities depend on similar work by local agencies throughout the state.

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Towing Emergency Equipment

Image of a Soquel Creek Water District truck towing a generator.

Soquel Creek Water District and other local agencies rely on vehicles capable of towing equipment that can weigh up to five tons while responding to emergencies (emergency water pumps, generators, compressors, etc.). Specifications for comparable electric vehicles are rated for less than half of that, and most models available in the US are not rated for towing at all. These constraints put public safety and water reliability at risk in emergency situations.

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Operating Critical Infrastructure

Image of a Olivenhain Municipal Water District workers repairing a water line.

Olivenhain Municipal Water District and other local agencies keep water flowing during emergencies – for residents as well as for firefighting efforts – by deploying operators to manually operate the water system and re-fuel generators over a wide-ranging service area. In these situations, gasoline-powered vehicles provide immediate readiness and operational duration that zero-emission alternatives cannot provide, especially when power is shut off.

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On September 25, 2025, CARB approved Resolution 25-6-8 related to proposed amendments to ACF, which among other things, repealed or provided clarity to those provisions related to private fleets that may not be entirely enforceable today due to the changes in federal law and withdrawal of certain waivers. The Board approved the resolution and directed staff to pursue further amendments that will have a future 15-day comment period. The totality of these two comment periods includes:

  • Defining “traditional utility-specialized vehicle”
  • Extending AB 1594 flexibility, such as those tied to the daily usage exemption, to all state and local fleets.
  • Extending the 50 percent purchase requirement to 2030 vs. the current date of 2027 where 100 percent of purchases would have had to been ZEV going forward and allow small fleets and those located in designated counties to continue to wait until 2030 before they need to purchase any ZEVs at all.
  • Streamlining the process for exemptions generally, including reducing barriers to applying for the Mutual Aid exemption, which currently requires an agency to already have 25 percent of their fleet ZEV in order apply for the exemption.
  • Further discussion and potential amendments on issues such as certain Renewable Natural Gas vehicles, and animal control vehicles

In advance of the coming 15-day comment period in which CARB will consider further amendments to its Advanced Clean Fleets regulation, CSDA and other organizations representing thousands of local agencies providing water, sewer, flood protection, fire protect, fire prevention, and other essential services, are calling upon CARB to ensure our frontline workers have the tools they require to perform their dangerous jobs under any conditions.

Emergency Response Vehicles Should Be Excluded from the ACF Mandate 

Vehicles reasonably anticipated to respond to emergency situations, or that support those efforts, should be excluded from the regulations in the same manner as the current regulation excludes snow removal vehicles.

Some examples of vehicles called upon to preserve public health and safety beyond those currently exempted:

  • Vehicles used for purposes of fire prevention/mitigation, public safety, search and rescue, medical response, and poacher prevention should be excluded.
  • Vehicles that are essential to the delivery, repair, and maintenance of electricity, water, wastewater, stormwater, and flood protection should be excluded.
  • Vehicles used to prevent and respond to the spread of disease and dangerous vector outbreaks should be excluded.

New Poll Released: Voters Support More Flexibility in ZEV Regulation

A new survey from Probolsky Research shows a vast majority of California voters – Republicans and Democrats – support exempting a broader range of emergency vehicles from the California Air Resources Board’s (CARB) Advanced Clean Fleets (ACF) zero emissions vehicle (ZEV) regulation.

Fire trucks, ambulances, and police cars are currently exempt from the regulation, which requires a transition to ZEVs for all state and local government medium-duty and heavy-duty vehicle fleets. Voters were asked whether this exemption should extend to all additional support vehicles anticipated to respond in emergencies like wildfires, floods and earthquakes. An overwhelming 75 percent of voters said they would support this change.

Support is strong among all voters with more than 70 percent of Democratic, nonpartisan, and Republicans in agreement. Given the importance to voters, the California Special Districts Association (CSDA) is calling on CARB to enact these exemptions, which would help protect lives and property.

Additional Background on CARB Advanced Clean Fleets Regulation

The Zero Emission Vehicle (ZEV) marketplace and regulations have seen dramatic changes in 2025 including those stemming from the successful passage of  (Garcia) in 2023, the California Air Resources Board (CARB) withdrawing its request for a federal Clean Air Act waiver for the Advanced Clean Fleets (ACF) regulation, and three successful Congressional Review Act resolutions that terminated the State of California’s waivers for Advanced Clean Trucks, Advanced Clean Cars II, and Heavy-Duty Omnibus. Generally, the remaining enforceable ACF regulations mandate the transition to zero-emission vehicles (ZEV) for state and local fleets.

CARB’s proposed regulatory changes were approved following a 45-day comment period, to which CSDA and its partners submitted comments that the proposed regulations do not go far enough to provide relief to local agencies given the numerous challenges that they face in the marketplace to meet the ambitious timelines of the current mandate, particularly regarding vehicles anticipated to respond to emergency situations.

CSDA and many partner organizations and member agencies testified before the Board. Transcripts and video of the September 25 meeting will be posted in the near future on CARB's website.

CARB’s proposed regulations follow the successful passage AB 1594 (Garcia) in 2023, which aimed to ensure that California’s ZEV regulations, such as the ACF rules, provide practical flexibility for public agency utilities. The measure dealt with issues such as certain utilities’ ability to replace specialized medium- and heavy-duty vehicles that have reached the end of their service life—regardless of model year—when those replacements are necessary to maintain reliable service or to respond quickly to major events like wildfires, severe storms, natural disasters, or other large-scale emergencies.

AB 1594 also requires CARB to update how it measures daily vehicle usage. Instead of relying on minimal-use data or excluding high-use days, utilities will be able to submit more representative fleet data that reflects real-world operations.