CARB’s Clean Fleets Regulation increases risk to Californians

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OPINION – The California Air Resources Board (CARB) is set to approve the Advanced Clean Fleets (ACF) Regulation within the next few weeks, introducing unprecedented uncertainty to public agencies that provide essential services and leaving utility ratepayers to foot the bill.

While California’s water and wastewater utilities fully support the goals of reducing air pollution and mitigating climate impacts, the regulations are unworkable and fail to meet the objectives of Assembly Bill 1594 (2023): ensuring public agencies have access to vehicles that can reliably maintain water systems and respond to emergencies while giving the zero-emission vehicle (ZEV) market time to develop and demonstrate reliability.

Some of this turmoil results from shifting federal and state dynamics on climate policy and ZEVs. Since 2025, the Trump Administration engaged in efforts to thwart CARB’s transition to ZEVs, including  disapproving CARB regulations aimed at transitioning all California fleets to ZEVs. Despite this shift, CARB maintains authority over a small portion of California’s vehicles: state and local government public agency fleets, which are ratepayer-funded and represent less than 7% of all medium- and heavy-duty vehicles.

In the wake of a narrowed state regulatory scope and the current federal approach to ZEVs, a key question arises: will a ZEV market exist solely to serve California’s state and local government agency fleets? Answer: resounding no.

In 2025, Ford announced it was halting production of the F-150 Lightning immediately due to low demand for battery electric vehicles (BEVs), and in 2026, General Motors announced plans to scale back production of their truck BEVs. The remaining two Class 2b/3 ZEV trucks approved by CARB include a Rivian that cannot accommodate the modifications required for utility operations.

This combination of reduced CARB authority, federal hostility toward ZEVs, and commercial pullback from production of medium- and heavy-duty ZEVs has created a “mandate without a market” that is functionally unachievable.

Similarly, challenges with hydrogen fuel cell vehicles (HFCV) have surfaced, revealing HFCV fleets are struggling to maintain market demand due to technical issues at fueling stations, high expenses and safety issues at storage and handling sites. At times, only 30% of California’s hydrogen fueling stations are operational. Furthermore, there is uncertainty surrounding the electrical grid capacity that must serve residential vehicle electrification, data centers and medium- to heavy-duty vehicle electrification. Data center growth is quickly outpacing grid development and electric utilities indicate that data center projects could add 10 gigawatts of electricity demand over the next decade. This is approximately four times the generating capacity of the Diablo Canyon nuclear plant, and more than three times the electricity that the entire Sacramento region uses at peak times. This reality raises serious questions about the grid’s ability to support a surge in ZEV adoption.

A broad swath of water sector advocates has been raising these issues since the introduction of the ACF regulations. Our collective goal is to ensure public agencies have access to vehicles capable of performing essential functions while helping achieve the state’s NOx and climate goals. ZEVs available today are not functionally equivalent to traditional vehicles and come at a much higher cost to ratepayers. In some cases, battery capacity lasts only 55 minutes, while crews need to operate for 12 to 16 hours.

Public agencies can support CARB’s emissions reduction goals while protecting critical functions by using ZEVs where appropriate and feasible, but supplemented by low NOx internal combustion engines available today, fueled with renewable biomethane. Unfortunately, the current ACF regulation does not practically allow this option and is simply not feasible.

Given the circumstances, CARB must reopen the ACF regulatory process, reexamine the realities of the ZEV market and collaborate with local governments to ensure that critical services remain functional, affordable and reliable to protect all Californians.

Adam Link is the executive director of the California Association of Sanitation Agencies, a statewide trade association that advocates for the wastewater sector on key regulatory and legislative issues in California.

Marwan Khalifa is the interim executive director of the Association of California Water Agencies, a statewide association representing approximately 470 public water agencies.