Comments of Clean Air Task Force in Support of California Waiver Request for Advanced Clean Fleets Regulation

The document argues that the Advanced Clean Fleets (ACF) regulation is feasible due to extensive state and federal funding and the availability of fuel cell electric vehicles (FCEVs) for long-haul and drayage trucking. It outlines the ACF's ZEV requirements for government, high-priority, and drayage fleets, and lists numerous financial incentives such as the HVIP and the Inflation Reduction Act. CATF emphasizes that FCEVs are critical for routes over 300 miles where battery electric vehicles (BEVs) are less efficient, and notes that California is actively building the necessary hydrogen refueling infrastructure.

• The Advanced Clean Fleets (ACF) regulation mandates a 100 percent zero emission vehicle (ZEV) sales requirement for medium- and heavy-duty truck manufacturers in California starting with the 2036 model year.
• The ACF regulation sets specific ZEV purchase schedules for different fleet types: state and local government fleets must reach 50 percent ZEVs by January 1, 2024, and 100 percent by January 1, 2027; high-priority and federal fleets must ensure any new vehicle added to the California fleet is a ZEV as of January 1, 2024; and all drayage trucks registering in the CARB system must be ZEVs starting January 1, 2024, with a total transition by 2035.
• California provides substantial state-level funding for ZEV adoption, including the Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP), which has funded over $1.4 billion in vouchers, and the Clean Transportation Program (CTP), which supports refueling infrastructure.
• Federal funding mechanisms such as the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) provide billions for ZEV infrastructure, including $7.5 billion for charging infrastructure and $2.5 billion for the National Alternative Fuel Corridors Program.
• Fuel cell electric vehicles (FCEVs) are identified as a critical diesel replacement for long-haul and drayage trucks, particularly for routes exceeding 300 miles where they offer a range of 350-500 miles and fueling times similar to diesel.
• Current FCEV market availability includes Class 8 models from Hyzon, Hyundai, and Nikola, with further development from OEMs like Mercedes-Benz, Honda, PACCAR, and Toyota.
• Hydrogen refueling infrastructure in California is being scaled, with a California Transportation Commission assessment suggesting that one hydrogen refueling station every 270 miles would be sufficient to support priority freight corridors.

APA

Clean Air Task Force (2024). Comments of Clean Air Task Force in Support of California Waiver Request for Advanced Clean Fleets Regulation. https://cdn.catf.us/wp-content/uploads/2024/09/25151728/catf-comments-ca-acf-waiver-request.pdf

Chicago

Clean Air Task Force. Comments of Clean Air Task Force in Support of California Waiver Request for Advanced Clean Fleets Regulation. 2024. https://cdn.catf.us/wp-content/uploads/2024/09/25151728/catf-comments-ca-acf-waiver-request.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Comments of Clean Air Task Force in Support of California Waiver Request for Advanced Clean Fleets Regulation |date=16 September 2024 |url=https://cdn.catf.us/wp-content/uploads/2024/09/25151728/catf-comments-ca-acf-waiver-request.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2024comments, author = {{Clean Air Task Force}}, title = {{Comments of Clean Air Task Force in Support of California Waiver Request for Advanced Clean Fleets Regulation}}, publisher = {Clean Air Task Force}, year = {2024}, month = sep, url = {https://cdn.catf.us/wp-content/uploads/2024/09/25151728/catf-comments-ca-acf-waiver-request.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }