Public agencies urge CARB not to ban trucks needed for emergencies

Local government leaders representing fire protection, water, resource conservation and hundreds of other public agencies across California on Thursday called on the California Air Resources Board (CARB) to exclude a broader range of emergency support vehicles from its Advanced Clean Fleets Zero Emission Vehicle (ZEV) regulation, currently open for a 15-day comment period. Leaders are urging CARB to act on the concern that its mandate will hobble the ability of public agencies to respond to and mitigate emergencies or disasters, placing untold lives and property at risk. A case in point is the Paradise fire, which might have been even more catastrophic had CARB's regulation been in place at the time. "CARB's fleet requirement, while well intentioned, would have hindered our ability to respond to the Camp Fire in 2018," said Kevin Phillips, manager of the Paradise Irrigation District. Water and irrigation districts across the state, which often support first responders in emergencies, share similar concerns. "As California leads the nation in climate policy, we must ensure progress toward a cleaner future doesn't come at the expense of public safety," said Melanie Mow Schumacher, general manager of the Soquel Creek Water District. "Our response capability must not be compromised by limitations in vehicle availability, charging times and limited charging capacity when seconds count." CARB's mandate requires public agencies to transition to ZEVs despite the lack of infrastructure or vehicles on the market that can serve and protect the public in emergencies. Fire trucks, ambulances and police cars, along with snow removal vehicles and historic vehicles are currently excluded from CARB's mandate; however, there are a wide variety of support vehicles needed in emergencies – especially during power outages – that are not. "A vehicle towing a generator to power a well, a water tender truck or vehicles with tools to restore a failing system may not look like a fire truck or ambulance, but they are just as vital," said Dave McQuead, Rancho Santa Fe Fire District Chief. "A water tender truck is as essential to emergency response as the fire engine it replenishes. CARB should define essential service based on the actual purpose of a vehicle, not just what it is." Disaster emergencies often bring blackouts Compounding the need for flexibility is the fact that natural disaster events can last for days or weeks, and power may be unavailable. CARB acknowledges this, calling to evaluate whether a mobile fast-charging option even exists to respond when the power is out. CARB also acknowledges the threat to resiliency the regulation poses by establishing a temporary "resiliency" exemption. However, it caps this exemption at no more than 25 percent of a fleet and the exemption expires in 2030. During emergencies, public agencies often need more vehicles than they have access to in their fleet, not a 75-percent reduction in their resiliency capabilities. "Our emergency response required the full deployment of our fleet, not just a limited percentage," said Phillips, describing his agency's experience during the 2018 Camp Fire. "ZEV limitations related to range, charging infrastructure and power availability would have further delayed response times." "Water and other utility trucks are critical during earthquakes and other natural disasters, such as the horrific Palisades and Eaton fires last year," said Neil McCormick, chief executive officer of the California Special Districts Association. "Those trucks run internal combustion engines and can be refueled in minutes. How many more lives might have been lost, how many more homes and buildings destroyed – and at what cost – if fire crews had to wait for utility trucks to recharge? What if recharging was impossible due to an outage?" No viable ZEV alternatives available Another concern raised by local agencies is that the vehicles essential to supporting emergency equipment have absolutely no counterpart in the ZEV marketplace. Even if they did, California lacks the ZEV infrastructure necessary for the ongoing operational reliability local agencies need. When the Olivenhain Municipal Water District needed to replace a Class 7 dump truck, for example, it received responses from two dealers that an equivalent ZEV was not available as a replacement. CARB provided a list of startup companies online that said they could produce ZEV dump trucks. Four of those companies are out of business, and one that CARB specifically referred was being sued for misstating its production capacity. Jon Barret with the Resource Conservation District of Tehama County added it can take more than five years to plan, permit and construct infrastructure needed to support a fleet of medium and heavy-duty ZEVs that do not exist, and are less likely to ever exist now that market demand has shrunk with the elimination of the private sector regulation. California voters support more exemptions CARB's ZEV mandate was unveiled in 2023 in response to state laws calling for California to meet aggressive carbon reduction goals by 2045. While these goals have broad public support, California voters actually prefer the flexibility these local agencies are urging. Response to a recent statewide CSDA survey of voters was nearly uniform regardless of political preference, with more than 70 percent of Democratic, nonpartisan and Republican voters in agreement these exemptions would be a good idea. "We cannot and must not leave Californians defenseless against the very climate-related events CARB is striving to mitigate with its mandate," McCormick said. "Protecting our environment and protecting lives and property are not mutually exclusive – we can do both with thoughtful policy that reflects real operational needs for public fleets, as well as market realities." CARB's current regulation excludes snow removal vehicles. Local leaders are requesting the state amend the regulation to additionally exclude local government vehicles used for water utility, flood protection, sewer utility, electric utility, fire prevention, fire protection, search and rescue, and disease and vector control. The 15-day public comment period is set to conclude Friday, April 17, after which CARB may consider making amendments to its ZEV rule. More information on the need for flexibility in CARB's ZEV mandate is available at csda.net/advocate/take-action/zev-flexibility.