Proposed zero-emission fleet regulations place heavy burden on cities, ignore market realities
Regardless of the size, available resources, and existing infrastructure, every city in California will be impacted by the proposed regulations.
The California Air Resources Board recently proposed an iteration of new regulations that would accelerate the number of medium- and heavy-duty zero-emission vehicles purchased and used by cities. The rule would require vehicles over 8,500 pounds that are used for waste, water, and other essential services to be free of greenhouse gas emissions by 2045.
The League of California Cities supports efforts to reduce greenhouse gas emissions in the transportation sector and many cities are already facilitating transportation electrification. However, the California Air Resources Board’s aggressive proposal places a heavy financial burden on cities, many of which are still recovering from the economic impacts of COVID-19 and other large-scale emergencies, such as wildfires.
What would these regulations do?
The proposed regulations would require cities, counties, and special districts with more than 50 vehicles in their fleets to annually inventory their fleet vehicles starting Jan. 1, 2024. By March 1, 2024, they would be required to submit an inventory report to the board.
Additionally, for applicable local authorities, 50% of all new motor vehicle purchases in each calendar year would need to be zero-emission starting Jan. 1, 2024. That percentage would increase to 100% by 2027. This includes all vehicle classifications, from class 2b to class 8.
The proposed regulations ignore existing market realities and the time needed to develop and ramp up an infrastructural system that can support an electrified fleet of waste, water, and sewer utility vehicles.
For example, existing zero-emission technology limits a garbage truck’s range to 100 miles or less, with a payload loss of 6,000 to 7,000 pounds. This reduction in payload capacity, combined with the time needed to charge a truck, means that agencies would need two garbage trucks for every one in service, significantly increasing costs for both vehicle infrastructure and labor.
Many of these vehicles are not commercially available. If a city has planned for supporting infrastructure and budgeted for such purchases, it should be provided credit instead of being penalized for vehicles not yet available. The proposed regulations should also be modified to ensure that established and reliable manufacturers can adequately produce and service these vehicles for years to come.
Additionally, ensuring a reliable electricity supply is vital to the success of transportation electrification. The proposed regulations are silent in this regard.
How to submit public comment
City officials can provide public comment during an Oct. 27 hearing at the California Environmental Protection Agency in Sacramento. Public testimony may also be provided remotely via Zoom or online before Oct. 17. Cal Cities is developing its comments on behalf of cities, and will be providing a sample letter, along with additional information, within the next week.For more information or help requesting an exemption from the California Air Resources Board, please contact Legislative Affairs Lobbyist Damon Conklin.