California Air Resources Board

Dear Governor Newsom, Chair Randolph, Secretary Omishakin, and President Reynolds,

President Trump and Congressional Republicans have undermined American competitiveness, economic opportunity, and climate progress by illegally revoking California’s clean air waivers. We commend Governor Newsom’s administration for your sustained commitment to greenhouse gas reductions through Executive Order N-27-25. We’re also grateful to Attorney General Bonta for leading the lawsuit to defend California’s clean air authority, and applaud Governor Newsom for spearheading the Affordable Clean Cars Coalition. These clean air waivers are critical to decarbonizing the transportation sector and meeting our climate goals. They also mitigate the significant harmful health impacts of diesel- and gas-powered cars and trucks for both drivers and communities near highways.

The undersigned eleven organizations, all members of the Clean RIDES Network, submit these comments today in response to the California Air Resources Board request for comments on advancing zero-emission vehicle (ZEV) deployment in California. The Clean RIDES Network brings together organizations dedicated to building sustainable transportation systems that cut costs for families, curb air pollution, and shorten commutes.

Our analysis finds that in order to meet emissions reduction commitments while making transportation more affordable and accessible for all, states must both scale up ZEV deployment while reducing overall vehicle miles travelled. That requires committing to sustainable funding for public transit operations, more housing near transit, and infrastructure that supports safe walking and biking. It also means prioritizing highway maintenance over new highway expansion. The CEQA VMT Mitigation Bank is one key tool to meet these critical transportation decarbonization and affordability needs.

ZEV deployment is essential, but insufficient to ensure that California meets climate, economic development, and affordability goals. The following recommendations are concrete, near-term actions to accelerate ZEV deployment in the absence of the California clean air waivers:

* Activate Flex Funding: California has the authority as a state to transfer Federal-Aid Highway Program funding, such as National Highway Performance Program dollars, into programs that support expanding electric vehicle charging infrastructure, including the Surface Transportation Block Grant and Congestion Mitigation and Air Quality Improvement Program. California is already using flexible state and federal dollars in the Trade Corridor Enhancement Program to invest in ZEV infrastructure, as recently approved by the California Transportation Commission. The state should further leverage available flexible federal dollars to support public transit, including the purchase of new electric buses and charging infrastructure.

* Strengthen Public Procurement Requirements: The California State Transportation Agency should work with the Department of General Services to ensure that the State of California stops procuring internal combustion engine vehicles, including (but not limited to) those for the California Highway Patrol. Instead, the state should exclusively procure ZEVs, and only from manufacturers that continue to certify and comply with California’s Advanced Clean Cars II and Advanced Clean Trucks regulations.

* Expand Indirect Source Rules: The South Coast Air Quality Management District’s Warehouse Actions and Investments to Reduce Emissions Program (Rule 2305) serves as a model for other non-attainment areas and for a statewide indirect source rule. We urge Governor Newsom to support the swift passage of the Pollution Hotspots Solutions Act (AB 914, Garcia). Additionally, the California Air Resources Board should eliminate barriers that prevent other air quality management districts in non-attainment areas, such as the San Joaquin Valley Air Pollution Control District, from advancing their own indirect source rules.

* Eliminate Barriers to User-Pay Fees: California should advance revenue-generating pricing strategies that reduce congestion and emissions. That includes supporting fee-per-mile programs like a statewide road user charge for medium- and heavy-duty vehicles and encouraging regional congestion pricing and tolling programs.
Preserve Low Carbon Fuel Standard (LCFS) ZEV Incentives: The Governor must continue to defend and strengthen LCFS incentives that support the adoption of electric cars and trucks.

* Stop PG&E Rate Case: The California Public Utilities Commission should reject PG&E’s proposed increase in electricity prices for its Business EV Rates proposed in its General Rate Case Phase II Application (A.24-09-014). This proposal would eliminate fuel cost savings that accompany the use of commercial electric trucks, transit fleets, and school buses, and further raise the cost of public fast charging for passenger vehicles. Governor Newsom should also support measures to mitigate electricity bill increases, including using non-ratepayer funding sources to offset customer bills and pay for wildfire mitigation.

California has a critical opportunity to lead the nation once again. We call on state leaders to boldly and swiftly act to implement these recommendations and keep California on the path to a future where everyone can access cleaner, more affordable transportation options.

Respectfully submitted,

American Council for an Energy-Efficient Economy
Central Maryland Transportation Alliance
Clean Air Council
ClimatePlan
Ecology Center (MI)
Evergreen Collaborative
Greenlining Institute
Natural Resources Defense Council
Pittsburghers for Public Transit
Sierra Club California
Union of Concerned Scientists