EUNICE M. ULLOA KAREN C. COMSTOCK
Mayor CHRISTOPHER FLORES
MARC LUCIO
Council Members
CURTIS BURTON DR. LINDA REICH
Mayor Pro Tem City Manager
CITY of CHINO
Mailing Address: P.O. Box 667, Chino, California 91708-0667 (909) 334-3250 • (909) 334-3720 Fax
Web Site: www.cityofchino.org
April 16, 2026
The Honorable Lauren Sanchez
Chair, California Air Resources Board
1001 I Street
Sacramento, CA 95814
RE: Advanced Clean Fleets 15-Day Comment Period Response Dear Chair Sanchez and the Members of the California Air Resources Board, The City of Chino appreciates the Board’s continued efforts to refine the Advanced Clean Fleets (ACF) regulation and the opportunity for us to comment on the 15-day proposed modifications.
Cities across the state are pursuing robust, environmentally sound strategies to decarbonize their communities. However, cities must also ensure the uninterrupted delivery of critical public services.
As currently structured, the proposed modifications do not adequately account for the operational realities of local government fleets, particularly those that support emergency response and essential infrastructure.
Cities serve diverse and often expansive communities, providing vital services that protect public health, safety, and welfare. During emergencies, city fleet vehicles must operate continuously for extended periods, often in extreme conditions, to support fire prevention and response, search and rescue, medical response, and the delivery and maintenance of essential utilities such as water, wastewater, stormwater, and electricity. Without appropriate and durable exemptions, ACF strict requirements risk constraining cities’ ability to respond effectively to disasters, maintain critical infrastructure, and safeguard the communities we serve.
The proposed amendments to the ACF regulations significantly expand the scope of local government responsibility by extending compliance obligations beyond publicly owned fleets to include private contractors operating under municipal agreements. By redefining “waste fleets” to include contracted service providers, cities can no longer rely on outsourcing to manage fleet compliance and are instead indirectly responsible for ensuring that contracted operations meet state mandates. This shift effectively converts municipal procurement and service delivery into a vehicle for state enforcement, exposing cities to increased costs, reduced contractor availability, and diminished Hon. Lauren Sanchez
April 16, 2026
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flexibility in negotiating long-term service agreements, particularly for essential services like waste hauling, street sweeping, construction, and public works.
In addition, the proposal imposes substantial new administrative and legal burdens on cities by requiring ongoing verification of contractor compliance, mandatory contract disclosures, and extensive recordkeeping subject to rapid state audit. These requirements transform routine contracting functions into compliance oversight roles, requiring cities to annually validate contractor status, maintain auditable documentation for multiple years, and respond to CARB inquiries within tight timeframes. Collectively, these changes create unfunded mandates, increase administrative complexity, and elevate legal and procurement risks, while also placing upward pressure on contract costs and potentially limiting competition among vendors unable to meet evolving regulatory thresholds.
While the proposed amendments significantly increase obligations on local municipalities, we appreciate the amendments to provide increased compliance flexibility by delaying the 100 percent zero-emission vehicle purchase requirement from 2027 to 2030 and expanding eligibility for exemptions and extensions related to infrastructure constraints, operational limitations, and emergency response needs.
However, to prevent unintended consequences that could jeopardize life, property, and essential services, we respectfully urge the Board to reject these newly proposed mandates on cities and rather request that CARB establish clear, categorical exemptions, consistent with those in Section 2013(c) of Title 13 of the California Code of Regulations for city vehicles that respond to, support, and recover from emergencies and disasters.
Again, thank you for allowing us the opportunity to provide written responses to the proposed Advanced Clean Fleets Regulations.
Sincerely,
Linda Reich
City Manager
cc: Hon. Senator Susan Rubio
Hon. Assembly Member Michelle Rodriguez
Laura Varela, League of California Cities Regional Public Affairs Manager (via email) League of California Cities, [email protected]