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California’s Air Resources Board (CARB) is considering proposed amendments to the Advanced Clean Fleets (ACF) and Low Carbon Fuel Standard regulations, with a public comment deadline of Friday, April 17, 2026.

HF&H Consultants will be submitting a formal comment letter to CARB expressing serious concerns about the proposed regulatory changes and their unintended consequences for local governments, ratepayers, and solid waste service delivery. 

 

Why This Matters to Local Agencies and Ratepayers

The proposed amendments substantially expand the definition of “waste fleet,” which would newly subject private franchise solid waste fleets to requirements intended for state and local government fleets. 

Based on HF&H’s decades of experience advising local governments on solid waste franchise agreements, this approach raises multiple red flags:

• Zero‑emission refuse vehicles currently cost roughly twice as much as conventional internal-combustion vehicles, placing immediate and material pressure on customer rates if mandated prematurely.
• Many refuse fleet applications do not yet have commercially available zero‑emission vehicle options, making compliance technically impracticable in the near term.
• Performance limitations—particularly vehicle weight and duty‑cycle constraints—can require more vehicles to do the same work, further increasing costs for communities. 

 

Contract Term Definitions Create Unintended Incentives

HF&H raised concerns about how CARB has defined contract terms within the proposed amendments. While the intent appears to be ensuring sufficient time to depreciate fleet assets, the practical outcome may be the opposite.

As written, the regulations could incentivize agencies to:

• Shorten franchise terms (e.g., five‑year contracts) to avoid triggering zero‑emission vehicle requirements.
• Create inefficient capital replacement cycles.
• Increase costs to ratepayers while reducing competition and reinforcing incumbency advantages in essential public services.

Recent fleet investments could be stranded prematurely, forcing contract renegotiations at significantly higher cost.

 

HF&H Supports Clean Fleet Goals — With Practical Implementation

HF&H shares CARB’s overarching objective of reducing emissions and accelerating the transition to cleaner technologies. However, regulatory timelines and compliance structures must align with real‑world fleet availability, infrastructure readiness, and public‑service constraints

Absent these considerations, the proposed amendments risk undermining both environmental outcomes and the reliability of solid waste collection services that California communities depend on every day.

 

Public Comment Deadline: April 17, 2026

The public comment period for these proposed amendments closes Friday, April 17, 2026. HF&H has submitted comments through CARB’s official comment portal and encourages impacted agencies and stakeholders to review the proposed changes carefully and submit their perspectives.

HF&H will continue to monitor developments and provide guidance to our clients as CARB considers next steps. 

For more information or to subscribe to HF&H’s updates, send an email to admin@hfh-consultants.com or call (925) 977-6950.