By @Aaron Avery
In late April, CARB approved its Advanced Clean Fleet (ACF) regulation which will require local government medium and heavy-duty fleets to begin transition to zero emission vehicles (ZEVs) as soon as January 1, 2024. On June 13, CARB submitted its rulemaking package to the Office of Administrative Law (OAL) for review and on July 26 withdrew the rulemaking package from OAL. On August 4, 2023, CARB posted a Second Notice of Public Availability of Modified Text and Availability of Additional Documents (Second 15-Day Notice) for the ACF regulation. CARB summarizes the proposed modifications as follows:
· Make revisions to the ACF’s five-day pass provision.
· Make minor clarifications to various reporting, recordkeeping, and compliance requirements (including exemptions).
· Remove language providing a sunset to provisions of the Advanced Clean Trucks (ACT) regulation at the end of the 2035, which did not need to be finalized as part of the ACF.
· Make specified reference corrections.
· Add to the administrative record, including a response to a comment alleging that CARB misrepresented emissions benefits from the ACF regulation.
· Make corrections to grammar and punctuation.
Special Districts wishing to provide comments on the Second 15-Day Notice must submit them so that they are received no later than August 21 at midnight, as follows:
· Electronic Submittal here.
· By mail to: Clerk of the Board, California Air Resources Board, 1001 I Street, Sacramento, California 95814.
Only comments related to the modified text will be considered. The modified text is contained in in Appendices A-1 through A-4 of the Second 15-day Notice, which can be viewed here.
CSDA has been significantly engaged with the ACF regulation. Prior to CARB’s approval of the ACF, CSDA provided public testimony, partnered with Cal Cities and the California State Association of Counties on joint comment letter, met with CARB staff, organized several virtual roundtables with CSDA members and CARB board members to share local examples of implementation concerns, and spoke with reporters covering the issue, gaining coverage in CalMatters and the Sacramento Bee.
View the coalition letter submitted by CSDA, Cal Cities, and CSAC. The local government joint comment letter pointed out inherent flaws with the proposed regulation and asked for additional time, resources, and exemptions to protect the health and safety of the communities special districts and other local agencies serve.
In consultation with its coalition partners, CSDA will continue to analyze and monitor the ACF, including the modifications proposed by the Second 15-Day Notice. Look for updates in Advocacy News and eNews if CSDA formally comments further on the ACF.
REMINDER: Respond to Critical ZEV Mandate Survey
As announced last week, CSDA is working with the Institute for Local Government, California State Association of Counties, and League of Cities to survey our members on this very important regulation. We realize how busy you are so this survey is only 11 questions. It is imperative we receive this information to help prepare for next steps of implementation.
Please take this short survey by August 18. You may direct any questions to Roberto C. Torres (rtorres@ca-ilg.org).
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