Summary
May 29th, 2026
Chair Lauren Sanchez
California Air Resources Board
Sacramento, CA
RE: Advanced Clean Fleet requirement amendments
Dear Chair Sanchez,
On behalf of the Marin County Board of Supervisors, I write to provide comments on your Board’s consideration of proposed Advanced Clean Fleet (ACF) amendments.
The County of Marin supports California’s goals of reducing greenhouse gas emissions and advancing zero emission fleet technologies including electrification. The County’s Climate Action Plan 2030 has set targets to reduce emissions to 40% below 1990 levels by 2030 and to reach carbon neutral by 2045. The Plan includes measures supporting the transition to electric vehicles both in the community and in our own fleet. However, we want to respectfully share some concerns with finalizing the proposed ACF amendments without changes to protect solid waste ratepayers and the essential public services they fund. As drafted, the rule would impose substantial near-term costs and operational burdens on contracted solid waste fleets, leaving local communities and ratepayers to absorb the impacts.
We propose consideration of changes to the approach to: extend compliance timelines where necessary; allow vehicles procured under existing franchise or contract terms to remain in service for their expected useful life; provide clear exceptions or flexibility for fleets facing unique operational, geographic, or route-related constraints; and ensure adequate funding and supporting infrastructure are available before imposing additional requirements.
As you know, fleet sizes, service territories, population density, topography, route conditions, and contract structures vary significantly across the state. Regulations that do not account for those differences risk unintended consequences, including higher rates, reduced service flexibility, disruption of essential public services, and conglomeration of private enterprises.
Thank you for your leadership in advancing greenhouse gas emission reduction and we would welcome the opportunity to work collaboratively on a balanced approach to meeting our shared goals while managing cost pressures.
Sincerely,
Eric Lucan, President
Marin County Board of Supervisors
CC: Marin County Board of Supervisors
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