California Air Resources Board

To: Honorable Chair, Liane M. Randolph, Dr. Steven Cliff, Ethan N Elkind, California Air Resources Board
From: Georgina Landecho, Executive Director
Date: Monday, July 21, 2025
Subject: Public Comment Submittal for CARB Consideration Regarding ZEV Public Dialogue Session

VISALIA, CA – CalVans: Driving Less, Achieving More, Miles Never Traveled—By Design

CalVans is a public agency with a mission to make commuting safer, greener, and more accessible—especially for those who’ve historically had limited transit options. CalVans, which provides vanpool transportation for farmworkers across California, is facing significant challenges in converting its agricultural fleet to electric vehicles (EVs). CalVans is already doing some seriously impressive work—especially for rural and agricultural communities across California so that no community or Californian is left behind. Here’s some of what already makes CalVans awesome.

Built for Rural & Agricultural Communities and Cost-Effective
•Provides safe, affordable transportation to support agricultural workers mobility and productivity while meeting all safety and state compliance standards
•CalVans covers fuel, maintenance, repairs, and insurance—riders only pay for their seat, saving families up to $1,500 annually compared to driving alone
•Vans are specially equipped with water storage, toolboxes, and trailer hitches to support off-road field access for a variety of non-traditional outdoor occupations

Smart Fleet Management & Hassle-Free Maintenance
•Vans receive routine on-site service every 6,000 miles or six months
•If a van breaks down, CalVans delivers a replacement van within hours—no need to pay extra for breakdown insurance
•Real-time GPS tracking ensures safety and accountability

Emergency Support
•Offers seven-day emergency response, including holidays and weekends
•Includes an emergency ride-home program for riders who miss their vanpool

No Long-Term Commitment
•Zero-commitment policy—if it’s not working out, CalVans will pick up the van with no strings attached
Community-Driven Model
•Vanpools are volunteer-led, with drivers taking vehicles home and managing daily operations
•No commercial license required—just a Class C license and a Class B exam
•CalVans is a public transit agency, not a private company
•Funded through passenger fares, and voluntary employer partnerships
•No long-term rider commitment: vanpools are self-managed and dissolvable as needed

Environmental Benefits
•Helps employers meet AB32 emissions mandates and reduce parking demand
•Each 15-passenger vanpool removes up to 14 single-occupant vehicles from the road removing over 100 million miles from ever occurring on California roadways.
•These are miles never driven, supporting reductions in congestion, air pollution, and road wear.

How the Numbers Add Up
•Each 15-passenger CalVans vanpool typically replaces up to 14 individual cars.
•With over 600 vanpools operating daily, and an average 60-mile round trip per rider, the program prevents more than 300,000 vehicle miles per day from being driven.
•Over the course of a year, this adds up to over 100 million vehicle miles never traveled—a massive reduction in traffic volume and greenhouse gas emission.
•Reduced emissions: Less fuel burned means lower CO₂ and smog-forming pollutants.
•Less road wear: Fewer vehicles on the road means less maintenance and longer pavement life.
•Lower resource consumption: Fewer tires, oil changes, and vehicle replacements needed.
•Improved air quality: Especially critical in agricultural regions with vulnerable populations to improve public health in underserved agricultural regions.

Regulatory Alignment

CalVans directly supports:
•SB 743 – Prioritizes reduced VMT in transportation planning
•AB 32 – Advances statewide GHG emissions targets
•AB 1800 – Addresses mobility equity and infrastructure gaps in rural regions

CalVans is a climate-smart, budget-conscious solution for California’s mobility challenges—especially where traditional transit can't go. With strategic support, this model can scale to meet the evolving demands of sustainable transportation across the state. This kind of VMT reduction already aligns with California’s Clean Transportation goals under SB 743 and AB 32, which prioritize sustainable transportation and reduced reliance on single-occupancy vehicles. CalVans isn’t just a rural transit solution—it’s already a strategic tool for environmental stewardship and rural mobility.

Key Issues with EV Conversion for CalVans

These issues are deeply tied to the realities of rural infrastructure, vehicle design, and regulatory mandates. Here's a breakdown:
•Lack of Suitable EV Models No automaker currently produces electric vans, without expensive retrofitting, that seat 8–15 passengers and meet CalVans’ unique requirements—vehicles must be large enough for crews but not require commercial licenses.
•Charging Infrastructure Gaps Rural areas where farmworkers live, and work often lack EV charging stations. Drivers take vans home, not to depots, making overnight charging impractical.
•Limited Range and Long Charging Times The electric vans CalVans is piloting have a maximum range of about 120 miles, which can be exceeded in just two days of commuting. Charging can take up to two hours, adding strain to already long workdays. On a positive note, the Tesla charging infrastructure allows these same 87 kWh vehicles to charge in under 1 hour.
•High Costs Each electric van costs over $98,000, to procure, and close to $116,000 to get into service. This is more than double the price of gas-powered models.
•Driver Burden Volunteer drivers, who are fellow farmworkers, already donate their time. Asking them to manage charging logistics without compensation risks burnout and program dissatisfaction.
•Hybrid Pilot Failures A previous hybrid vanpool pilot funded by CARB in 2019 showed that hybrid conversions couldn’t withstand the wear-and-tear of rural, off-road use. The program was discontinued. EV’s appear to be an even less suitable option for off road use.
•Unclear Regulatory Compliance CalVans may be subject to California’s zero-emission fleet mandate, but its classification is ambiguous. Exemptions exist, but clarity is lacking to help determine if already exempt for ICT, will it still be mandated by ACT.

In response to the live question about what non-financial incentives would work better than current regulation to help CalVans transition to EV, great question—especially since CalVans faces unique rural and agricultural challenges that financial incentives alone can’t solve. Here are some non-financial strategies that we feel could better support EV transition than the state’s current regulation.

Regulatory Flexibility & Exemptions
•Vanpool-specific carve-outs from zero-emission fleet mandates, recognizing CalVans’ public agency status and rural service model
•Extended compliance timelines for agricultural vanpools, allowing infrastructure and vehicle technology to catch up
•Streamlined permitting for installing home-based or rural charging stations

Public-Private Partnerships
•Manufacturer collaboration to co-design EVs tailored for farmworker transport (e.g., high-capacity, off-road capable vans)
•Utility partnerships to prioritize grid upgrades and charging access in underserved areas
•Local employer engagement to host outreach events or provide open parking/charging space

Recognition & Visibility
•State-level designation as a “Rural EV Innovation Pilot” to attract attention and policy support
•Awards or certifications for agencies that demonstrate creative EV adoption strategies
•Inclusion in statewide planning documents as a model for rural transit electrification

Training & Technical Support
•Driver education programs focused on EV operation and charging logistics
•Maintenance training for local mechanics to promote education and EV vehicle service
•Dedicated CARB liaison to assist CalVans with compliance, reporting, and grant navigation

Policy Alignment & Advocacy
•Integration with AB 32 and SB 743 goals, showing how CalVans reduces VMT and emissions
•Legislative support for rural transit exemptions or pilot programs
•Data-sharing agreements to demonstrate impact and influence future CARB rulemaking

These approaches shift the focus from mandates to collaboration, flexibility, and recognition—giving CalVans the tools to lead rather than struggle. CalVans is a climate-smart, budget-conscious solution for California’s mobility challenges—especially where traditional transit can't go. With strategic support, this model can scale to meet the evolving demands of sustainable transportation across the state.

Will CalVans continue operating in the agricultural sector without fully transitioning to EVs? The short answer is: not indefinitely, but yes—for now, without strategic planning and regulatory flexibility however, the unique nature of CalVans faces various challenged ahead. The immediate impacts, without exemptions or tailored support, CalVans faces:

• Reduced service availability for farmworkers already faced with a challenging immigration climate
• Non-compliance penalties despite best efforts
• Loss of 36 million miles of rural mobility options, increasing VMT and emissions for the state and 100 million annually for all trips
• Strained volunteer driver participation as CalVans is self-funded, the program could collapse as participation and existence of the program is tied 100% to rider fares.

CalVans isn’t just removing cars—it’s removing the need for those trips altogether, especially where public transportation doesn’t reach. CalVans is rural resiliency, environmental and social responsibility, and climate strategy rolled into one.

Respectfully,

Georgina Landecho, M.P.A. | Executive Director
California Vanpool Authority | CalVans
Email: glandecho@calvans.gov | Mobile: 1.530.383.9348
Web: www.calvans.gov | Toll Free: 1.866.655.5444 ext. 101
Physical/Mailing: 8444 W. Doe Avenue, Visalia, Ca. 93291