Advanced Clean Fleets

Policy Engagement Overview

Advocacy on the Transportation Freedom Act: The automobile industry has largely supported the Transportation Freedom Act, which would stop enforcement of Advanced Clean Fleets in all participating states. General Motors, Stellantis, and Toyota Motor all supported the Transportation Freedom Act in March 2025 statements issued in a press release on US Senator Moreno’s website. The CEO of the Alliance for Automotive Innovation, John Bozzella, also supported the bill in statements on the same press release.

• The oil and gas industry opposed a waiver of preemption for the Advanced Clean Fleets rule in September 2024 regulatory comments. The American Petroleum Institute, American Fuel and Petrochemical Manufacturers Association, and Western States Petroleum Association, strongly advocated that the EPA deny CARB’s request for a waiver of preemption to enforce the rule, claiming that the EPA lacked authority to grant the waiver. Chevron and Valero also independently requested that the EPA deny the California Air Resources Board’s request for a federal waiver of preemption.

• The Truck and Engine Manufacturers Association did not appear to support or oppose the adoption of the rule in its comments, but advocated against the retroactive enforcement of the rule. ZF Friedrichshafen, an auto parts manufacturer, supported the waiver in its comments and stated that from the perspective of suppliers, the Advanced Clean Fleets regulation is aligned with parts suppliers’ manufacturing plans for the future.

• Electric utilities and transportation companies were supportive of the waiver, and requested that EPA approve it. The Zero Emission Transportation Association (ZETA), representing utilities and transportation companies, advocated for the EPA to approve the waiver and allow CARB to enforce the Advanced Clean Fleets rule. Pacific Gas & Electric (also a member of ZETA) independently commented on the rule and advocated in support of the waiver.

• The US Chamber of Commerce advocated against approving the waiver. The association claimed the rule goes “too far, too fast.” Airlines for America, an industry group representing major airlines, requested the waiver be postponed unless the rule was delayed, weakened, and exemptions were carved out for the airline industry.

Engagement Prior To Waiver

• Prior to the Clean Trucks Partnership Agreement, the heavy-duty vehicle industry exhibited unclear and negative engagement. The Truck and Engine Manufacturer’s Association (EMA) and its key member, Daimler Truck, both appeared to strongly oppose the ACF rule in April 2023 consultation responses, including CARB’s proposal to move the 100% ZEV sales mandate forward from 2040 to 2036. General Motors, also a member of the EMA, appears to have taken an unclear position in its October 2022 consultation response.

• The wider automotive industry showed mixed to negative engagement. In its April 2023 consultation response, Ford appeared to support maintaining the 2040 100% ZEV mandate rather than moving it forward to 2036. Moreover, in their respective October 2022 consultation responses, Toyota appeared unsupportive of the ACF rule more broadly, while Mercedes-Benz took an unclear position.

• The oil and gas industry strongly opposed the ACF regulation. Major industry associations including the Western States Petroleum Association (WSPA), American Fuel & Petrochemical Manufacturers (AFPM), and American Petroleum Institute (API) appear to strongly oppose the ACF rule, including the 2036 100% ZEV mandate. Valero also appeared to strongly oppose the regulation in its April 2023 consultation response, suggesting that it is illegal.

• Progressive automotive organizations showed positive engagement. Both the Zero Emission Transportation Association (ZETA) and its key member, Tesla, strongly supported CARB's earlier proposed 2036 100% ZEV sales mandate and called for even more stringency in April 2023 consultation responses.

• The aviation industry sought exemption from ACF regulation. Airlines for America (A4A) appeared to oppose CARB’s proposed ACF regulation, seeking exemption for the aviation industry and emphasizing concerns around issues such as grid capacity.

• A range of cross-sector organizations and individual companies took positions that were unsupportive of the regulation. The California Chamber of Commerce (CalChamber) appeared unsupportive of the ACF rule in its October 2022 consultation response. Air Liquide called for trucks powered by 'renewable natural gas' to be counted as ZEVs in the policy, while Cummins also called for the inclusion of trucks powered by renewable fuels. Air Products and Pacific Gas & Electric Company (PG&E) both appeared unsupportive, advocating for a number of exemptions and flexibilities.