August 1, 2025

Public Citizen Letter to California Air Resources Board on Zero Emissions Vehicle Policy

Download the PDF here.

August 1, 2025
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Dear Chair Randolph and Members of the Air Resources Board,

As an organization committed to advancing a zero-emission transportation future, Public Citizen commends CARB’s steadfast leadership in protecting Californians’ right to clean air, especially as the Trump administration moves to revoke vehicle emissions waivers and dismantle key Electric Vehicle tax credits and infrastructure funding.

These federal actions threaten not only California’s climate progress but national progress on air quality, public health, and equitable access to clean transportation. California must respond with bold state policy that upholds its authority and accelerates equity-centered Zero Emission Vehicle (ZEV) adoption across communities and sectors.  We ask that CARB consider the following policy options:

• Codify and Strengthen California’s ZEV Rules

1. 1. 1. Accelerate the implementation timeline for Advanced Clean Cars II, Advanced Clean Trucks, and Advanced Clean Fleet rules.
      2. Codify these standards via state legislation or executive orders to safeguard against future rollbacks.
      3. Broaden compliance pathways to prioritize workforce development, equitable deployment, and community-based infrastructure.

• Expand and Secure State-Level ZEV Incentives

1. 1. 1. Reopen and boost funding for the Clean Vehicle Rebate Project (CVRP), prioritizing low-income, rural, Tribal, and pollution-burdened communities.
      2. Create state-level replacements for lost federal EV tax credits for passenger and commercial vehicles.
      3. Adopt feebate systems to penalize high-pollution vehicle purchases while lowering costs for ZEVs.
   2. Mandate Fleet Transitions
      1. Require all state and municipal fleets to meet aggressive ZEV procurement schedules.
      2. Extend clean fleet mandates to high-impact private sectors (e.g. delivery, ride-hailing, drayage companies).
      3. Exclude automakers who are not aligned with California’s leadership on ZEV policy from public procurement.

• Drive Equitable Charging Infrastructure

1. 1. 1. Prioritize deployment of chargers in communities facing elevated pollution burdens or access gaps.
      2. Urge utilities to adopt equity-based infrastructure targets within grid modernization plans.
      3. Expand rebates for EV charging in multi-unit dwellings, workplaces, and homes in overburdened communities.

• Enact Indirect Source Rules & Clean Delivery Zones

1. 1. 1. Empower air districts to limit vehicle pollution from logistics centers, warehouses, and ports via indirect source rules.
      2. Create ZEV-only delivery zones or congestion pricing zones to incentivize emissions reduction at urban logistics hubs.

• Uphold Fuel Standards, Off-Road/Port Electrification, and Broader Mobility Reform

1. 1. 1. Strengthen California’s Low Carbon Fuel Standard to accelerate cleaner alternatives and reduce emissions from existing vehicles.
      2. Expand electrification further to off-road equipment (e.g. forklifts, port equipment, construction vehicles).
      3. Encourage holistic mobility and land-use reforms, such as zoning updates, transit-oriented development, and multimodal options, to reduce auto dependence while boosting clean mode share.

• Mobilize State-Level Coalitions and Hold Industry Accountable

1. 1. 1. Convene a “Clean Cars and Trucks Compact” of Section 177 states via networks like the US Climate Alliance to reaffirm shared commitment to strong standards.
      2. Require automakers and corporate actors to uphold commitments to zero-emission targets aligned with California’s timelines.
      3. Exclude from state contracts or incentives companies actively lobbying to dismantle state or federal clean vehicle protections.

• Advance Legal Defense & Strategic Outreach

1. 1. Support ongoing litigation and legal strategies to defend California’s waiver authority under the Clean Air Act.
   2. Publish annual benchmarking reports comparing progress of states who mirror California’s leadership versus those succumbing to federal backsliding.

California’s leadership under the Clean Air Act has driven national progress for decades. Now, in the face of an administration actively undermining EV standards and climate investments, California must double down— through codifying its clean vehicle rules, and electrifying public and private fleets.

Thank you for your leadership. We look forward to accelerating clean transportation access for all Californians.

Sincerely,

Will Anderson
ZEV Policy Advocate
Public Citizen