On December 13, 2019, RCRC submitted a letter to the California Air Resources Board (CARB) following a public workshop on the Advanced Clean Trucks (ACT) Proposed Rulemaking. During the six-hour workshop, CARB staff clarified that the “Large Entity” one-time reporting requirements extend to all local government municipalities – regardless of fleet size – to collect data for future regulations to increase the use and procurement of heavy-duty zero-emission vehicles (ZEVs).
An example of the reporting requirements as currently proposed for a county’s fleet, as well as all transportation services contracted for, can be accessed here. These reports are expected to be due to CARB in April 2021, pending CARB’s approval.
In September 2019, Governor Newsom issued an Executive Order requiring CARB to increase demand and new markets for ZEVs to achieve necessary greenhouse gas (GHG) reductions in the transportation sector. In turn, CARB has fast-tracked ACT regulations with limited public outreach to local government and business sectors alike. RCRC has concerns with ZEVs, particularly around CARB’s ambitious future procurement mandates it is proposing, the lack of infrastructure and state investment for heavy-duty ZEVs, and the inability to simultaneously comply with other costly state mandates, such as the Senate Bill 1383 organic waste diversions from landfills. SB 1383 implementation relies on effective organic waste diversion such as the conversion of methane from landfills into low carbon renewable natural gas. An all-electric fleet, for example, would exacerbate the insurmountable challenges already being pushed by a competing state agency and create more conflict with the limited investments local governments can make into its public fleets. RCRC also has serious concerns with the lack of outreach to local governments during the ACT rulemaking process, particularly since the applicability to municipal fleets has been unclear from the start.