Daily Usage Exemption Checklist
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This checklist is a tool to assist fleet owners in submitting a complete application for a Daily Usage Exemption in CARB’s Advanced Clean Fleets regulation, title 13, CCR, sections 2015.3(b) and 2013.1(b). The use of this checklist is not required, however, it does cover all documentation required to be submitted. This checklist complements the Daily Usage Exemption frequently asked questions document.
If your fleet can comply with the next applicable compliance date specified in the Advanced Clean Fleets (ACF) regulation without an exemption, there is no reason to apply for an exemption. If you need assistance in understanding the flexibility in the regulation, please contact us at ZEVFleet@arb.ca.gov. If your fleet cannot comply with the flexibility provided in the ACF regulation, you may request an exemption if you meet applicable exemption criteria.
Fleet owners may request a daily usage exemption to purchase a new internal combustion engine (ICE) vehicle of the same configuration as an ICE vehicle being replaced if no new battery electric vehicle (BEV) is available to purchase that can meet the demonstrated daily usage needs of any existing vehicles of the same configuration in the fleet. This exemption only applies when purchasing a replacement for a vehicle of the same configuration that is already in the fleet.
Application Basics
To apply for a daily usage exemption, your California fleet must comply with all applicable requirements in the ACF regulation, including the reporting requirements. Reporting must be done in the Truck Regulation Upload, Compliance, and Reporting System (TRUCRS). One means of demonstrating compliance is to indicate the TRUCRS ID for your fleet in your application for the Daily Usage Exemption.
Your California fleet must be comprised of 10% zero-emission vehicles (ZEVs) or near-zero emission vehicles (NZEVs) to apply for the exemption. The following are other key requirements that depend on the compliance method you are using:
- Model Year Schedule (Federal and High Priority Fleets), Section 2015.1(c)(5):
- The application for the exemption is submitted no later than one year prior to the compliance date for the vehicle.
- The application for the exemption is submitted no earlier than when the vehicle, that is otherwise required to be replaced, reaches 16 years old, or when the vehicle reaches 700,000 miles, whichever occurs first.
- ZEV Purchase Schedule (State and Local Government), Section 2013(n)(4):
- The application for the exemption is requested no earlier than when the model year of the ICE vehicle being replaced reaches 13 years old.
- ZEV Milestones Option (Government and High Priority Fleets), Section 2015.2(f)(5):
- The application for the exemption is submitted no later than one year before the next applicable ZEV Milestone compliance date, and
- The application for the exemption demonstrates the next applicable upcoming ZEV Fleet Milestone cannot be reached without requesting and obtaining exemptions for all other ICE vehicles in the California fleet
Required Information Checklist
The following information is required to be submitted to apply for a Daily Usage Exemption. You can compile this information in several formats, but an Excel table that lists VIN or license plates is recommended if your application includes multiple vehicles:
Replacement Vehicle
Submit the following information about the eligible ICE vehicle being replaced:
| ☐ | Vehicle weight class: Select from [2b, 3, 4, 5, 6, 7, or 8] |
| ☐ | Vehicle make [e.g., Ford, Isuzu, Freightliner, etc] |
| ☐ | Vehicle model [e.g., F350 Super Duty, 6500HD, M.2, etc] |
| ☐ | Configuration [e.g., stakebed, flat bed, crane, box truck, sewer jetter, bucket truck, service truck, utility truck, day cab tractor, dump truck, refuse front loader compactor truck, etc] |
| ☐ | A photo of the vehicle being replaced |
Vehicle Daily Usage
Submit the following information about each vehicle in the California fleet of the same weight class and configuration as the eligible ICE vehicle being replaced:
| ☐ | Submit a daily usage report for a period of at least 30 consecutive workdays from within the last 12 months using telemetry data or other data collection system that tracks daily mileage and energy use (e.g. diesel or gasoline gallons used for ICE vehicles or kWh for ZEVs), and hours of vehicle operation if applicable, for all ICE vehicles of the same weight class and configuration of the vehicle to be replaced. You can compile this information in several formats, but an Excel table that lists VIN or license plates is recommended if your application includes multiple vehicles. Fleet owners that have a mutual aid agreement to send vehicles to assist other entities during a declared emergency event may alternatively submit the report from within the last 60 months. For vehicles that operate equipment while stationary, the daily usage report must include: ☐ Energy used while operating integrated or truck-mounted equipment while stationary (if applicable) ☐ Number of hours the integrated, or truck-mounted equipment is operated each day (if applicable) |
| ☐ | Submit a description of the daily assignments or routes used by vehicles of the same weight class and configuration in the California fleet with an explanation of why all BEVs available to purchase of the same weight class and configuration cannot be charged or fueled during the workday at the depot, within one mile of the routes, or where ZEV fueling infrastructure is available. The explanation must include a description of why charging could not be managed during driver rest periods or breaks during the workday. |
Comparable Battery Electric Vehicle
Submit the following information about the BEV the fleet owner has identified that is available to purchase in the same weight class and configuration as the eligible ICE vehicle being replaced:
| ☐ | Vehicle weight class: Select from [2b, 3, 4, 5, 6, 7, or 8] |
| ☐ | Vehicle make [e.g., Ford, GreenPower, Battle Motors, etc.] |
| ☐ | Vehicle model [e.g., eM.2, EVStar,] |
| ☐ | Configuration [e.g., stakebed, flat bed, crane, box truck, sewer jetter, bucket truck, service truck, utility truck, day cab tractor, dump truck, refuse front loader compactor truck, etc] |
| ☐ | Highest available rated energy capacity [e.g., 350kWh, 179kWh, etc] |
| ☐ | Calculated range or documented energy usage (e.g., 350 miles, 250kWh, etc). See sections 2015.3(b)(3) and 2015.3(b)(3)(a) or sections 2013.1(b)(3) and 2013.1(b)(3)(a) of the applicable regulation language for required calculation or documentation method. |
Submit Your Application
When you have verified that you need an exemption to remain in compliance and your application is complete, you can submit your application to TRUCRS@arb.ca.gov with the subject line “Daily Usage Exemption”. You must also show that your California fleet complies with all applicable requirements in the ACF regulation, including the reporting requirements. One means of demonstrating compliance is to indicate the TRUCRS ID for your fleet. CARB will review the application and respond via email whether the application is approved within 45 calendar days.
This document is provided to assist regulated entities in complying with the Advanced Clean Fleets regulation. In the event any discrepancy exists between this document and the Advanced Clean Fleets regulation, the regulatory text of the Advanced Clean Fleets regulation applies.