Comment Letter: Advanced Clean Fleets Regulation/AB 1594 Amendments May 2, 2025 Comment Letters To: Ms. Liane Randolph, Chair, California Air Resources Board Subject: Comment Letter: Advanced Clean Fleets Regulation/AB 1594 Amendments Letter Excerpt: The Association of California Water Agencies (ACWA) appreciates that the California Air Resources Board (CARB) is taking additional time in the AB 1594 process to amend the Advanced Clean Fleets regulation (ACF) to better reflect additional flexibilities needed by public agency utilities to maintain critical operations and comply with ACF. ACWA represents approximately 470 public water agencies that collectively deliver approximately 90 percent of the water in California for domestic, agricultural, and industrial uses. We encourage taking the time to hear additional input from public agency utilities, including water and wastewater agencies, to ensure necessary changes are made to promote fleet electrification, where feasible, without compromising public agency utilities from being able to maintain essential public services and critical operations, including during emergency events. ACWA will work to provide examples to CARB staff that detail how water and wastewater agency fleet operations have been impacted by emergency events that impact the ability to comply with ACF. Download Comment Letter