CARB Advanced Clean Truck (ACT) Regulation Update & Register for CARB Workshop on Reporting Requirements for Large Entities and Fleets under the Advanced Clean Truck Regulation

At its June 25, 2020, meeting the CARB Board adopted the first phase of an Advanced Clean Truck Rule (ACT) to take effect with the 2024 model year trucks. The current Truck and Bus Regulation requires all trucks 26,000 GVWR or greater to be 2010 or newer and pre-1996 should have been replaced by 2015. By 2023 all trucks must be 2010 or newer to operate in California. Trucks with a GVWR of 14,000-26,000 must also be 2010 or newer by 2023. The ACT applies for the period 2024-2045. It sets sales percentages for manufacturers and establishes a large-fleet reporting requirement. Phase 2 of the ACT currently being drafted will set fleet turnover requirements. Phase 1 is intended to push manufacturers to sell zero emission trucks (electric or fuel cell) in California. It also lowers the GVWR to 8501, which will draw in trucks in the range of an F-250 into the regulation. The ACT establishes sales percentages for each weight category 8,500-14,000; 14,001-16,000 and 16,001+ ranging from 5% of sales in 2024 to as high as 75% by 2035.

The large-fleet reporting requirement is invasive and extensive for fleet owners. It requires reporting in 2021 by a) any entity with $50 million or more in annual revenue with at least one truck; b) any fleet owner that has 50 or more vehicles greater than 8,500 GVWR; c) any broker that dispatched 50 or more vehicles 8500 GVWR or more; d) any government agency that has one or more vehicles over 8,500 GVWR. A partial list of information requested for each vehicle includes: type of vehicle, operating characteristics, fuel type, miles per day, time retained at facility, average annual mileage, age of vehicle, GPS devices, on-site fueling, number of contracts for delivery, subhaulers, vehicles operated by subhaulers, usage pattern, etc.

Phase 2 of the regulation is currently in the drafting stage. It is designed to create a market for the vehicle sales numbers established in Phase 1. The stated goal is to have 100% of drayage trucks zero emission vehicles (ZEV) by 2035, all utility and government fleets 100% ZEV by 2040 and all refuse trucks and buses 100% ZEV by 2040.

The ZEV requirement is problematic for construction fleets. There is seldom power at a construction site for charging electric vehicles. The purchase price and operating costs for ZEV vehicles make them less cost effective; their longevity and reliability is uncertain and unproven; Public Safety Power Shutoffs limit access to charging when and where it is most needed and the cost of electricity in California is 50% higher than the rest of the nation. Further, construction vehicle usage tends to be highly specialized for maintenance or heavy haul applications where batteries are not a suitable propulsion option. Also, it does not appear that there will be any incentive dollars from CARB to make the transition as there has been in the past.

CARB expects to release language soon for the Phase 2 regulation and adoption is scheduled for early 2022.

CIAQC has submitted numerous comments to CARB on behalf of the construction industry and we will alert the industry when the first draft of phase 2 is released.

To register for the CARB Workshop on Reporting Requirements for Large Entities and Fleets Under the Advanced Clean Truck Regulation:
https://register.gotowebinar.com/register/2790509243454743564?utm_medium=email&utm_source=govdelivery

About CIAQC
The Construction Industry Air Quality Coalition (CIAQC) was founded in 1989 to help their members understand and navigate the ever-increasing web of government environmental regulation under which they operate their businesses and build our communities, our infrastructure and the environmental systems that will enhance California’s future.