Public Fleet Requirements Regarding “Commercially Available”

  • Oct 18, 2022
  • Comment Letters

Agency: California Air Resources Board (CARB)

Subject: Proposed Advanced Clean Fleets Regulation Public Fleet Requirements regarding “Commercially Available”

Letter excerpt:

The signatories to this letter appreciate the opportunity to provide public comments regarding the fundamental concept of ‘commercially available’ for medium and heavy-duty vehicles necessary to fulfill our fleets’ water, wastewater, and electric utility responsibilities in the California Air Resources Board’s (CARB) proposed Advanced Clean Fleets Regulation (Draft ACF) documents released on August 30, 2022. Our fleets provide essential public services that millions of Californians rely upon daily.

The undersigned Coalition requests that CARB formally define “Commercially Available” in the Draft ACF prior to requiring fleets to make future purchases of new medium- and heavy-duty vehicles starting as early as 2024. Without stakeholder and CARB agreement on what is commercially available, we have great concern that CARB will enforce new purchase requirements when in practice vehicles do not exist to perform our essential public service fleet operations. Progress and innovation are advancing in medium-and-heavy duty vehicle technologies, but infrastructure for and application of many vehicle configurations are still several years away from being commercially available.

Download Comment Letter