What is the Daily Usage Exemption?

The Daily Usage Exemption is available to address situations where a fleet owner cannot comply with the Advanced Clean Fleets regulation due to circumstances beyond their control. Specifically, if no new ZEV is available to meet the demonstrated daily mileage or energy usage needs of existing vehicles of the same configuration being replaced in the fleet. The exemption considers whether the daily mileage (or energy usage) of an available battery-electric vehicle (BEV) of the needed configuration can meet the daily mileage or usage needs of the fleet when no other type of ZEV is available. The exemption does not apply to a vehicle configuration that is available as a fuel cell electric vehicle or as a near-zero emission vehicle (NZEV) with minimum all-electric range until the 2035 model year, or if a BEV with a high battery energy capacity is available. If approved, this exemption allows a fleet owner to purchase a new internal combustion engine (ICE) vehicle of the same configuration as the subject vehicle, instead of a ZEV.

What is a BEV with a high battery energy capacity?

A BEV with a high battery energy capacity is a manufacturer’s rated battery energy capacity in kilowatt-hours (kWh) as specified:

• Class 2b-3 vehicle with at least 150 kWh
• Class 4-6 vehicle with at least 325 kWh
• Class 7-8 vehicle with at least 450 kWh that is not a tractor nor a 3-axle bus
• Class 7-8 tractor or 3-axle bus with at least 1,000 kWh

When can a fleet owner apply for the Daily Usage Exemption?

A fleet owner may request a Daily Usage Exemption if the fleet is in compliance and at least ten percent of their California fleet are ZEVs or NZEVs, regardless of compliance method used. In addition, the following basic requirements must be met:

• A State or local government fleet that complies with the ZEV Purchase Schedule may apply no earlier than when the vehicle model year of the ICE vehicle being replaced reaches 13 years old.
• A High Priority Fleet that complies with the Model Year Schedule may apply no earlier than when the model year of the ICE vehicle being replaced reaches 16 years or when the vehicle reaches 700,000 miles, whichever occurs first, and no later than one year before the vehicle being replaced must be removed from the California fleet pursuant to the ICE vehicle removal requirement of section 2015.1(b).
• Any fleet owner that elects to comply with the ZEV Milestones Option may apply if the fleet owner demonstrates the next applicable upcoming ZEV Fleet Milestone cannot be reached without requesting and obtaining exemptions for all other ICE vehicles in their California fleet and no later than 1 year before the next applicable ZEV Fleet Milestone compliance date.

How does a fleet owner apply for the Daily Usage Exemption?

A fleet owner that can show the fleet is in compliance and that all available ZEVs cannot be placed in the fleet while meeting the conditions specified in the Daily Usage Exemption, must submit the following information by email to TRUCRS@arb.ca.gov to apply for the exemption.

• Demonstrate the California fleet complies with all applicable requirements, including the reporting requirements. This can be done by identifying the TRUCRS ID.
• Which ICE vehicle is to be replaced by submitting the make, model, weight class, configuration, and photograph of the vehicle.
• Which comparable BEV in the same weight class and configuration has the highest available manufacturer’s rated energy capacity. Submit the make, model, weight class, configuration, and rated energy capacity of the identified BEV. 
• The calculated range of the BEV in miles, per section 2015.3(b)(3), or measured energy usage as specified in section 2015.3(b)(3)(A), of a BEV operated on similar assignments. For vehicles that operate truck-mounted or integrated equipment while stationary, such as a power take-off unit or other equipment that taps into the battery to perform the vehicle’s intended function, the information must also include the energy used while stationary and number of hours such truck-mounted or integrated equipment is operated each day.
• A daily usage report for each ICE vehicle of the same configuration for 30 consecutive workdays within the past 12 months of daily mileage, and energy used if applicable. Fleets with mutual aid agreements may select a 30-day period from within the last 5 years. The vehicle mileage (or energy usage) in determining eligibility for the exemption will exclude the 3 highest daily readings.
• Description of daily assignments or routes of existing vehicles of the applicable configurations and explanation of why BEVs cannot be charged during the workday or during driver rest periods.

These are summaries of the detailed requirements, which may be found in the State and Local Government (Section 2013.2(b)) or High-Priority and Federal Fleet (Section 2015.3(b)) regulation language.

What happens when a fleet owner is approved for the Daily Usage Exemption?

Exemptions will be approved only if the fleet owner demonstrates they cannot comply with the next applicable compliance date without the exemptions. Fleets that meet the eligibility requirements and have vehicles approved for the Daily Usage Exemption must place their new ICE vehicle orders within 180 calendar days, and government fleet owners must place their new ICE vehicle orders within 1 year, from the date the exemption is granted. Any new ICE vehicle purchased must have an engine that is compliant with the ICE engine purchase requirements.

Where can I find more information?

Detailed Daily Usage Exemption requirements may be found in the State and Local GovernmentorHigh-Priority and Federal Fleet regulation language. Information about the ACF Regulation and upcoming meetings, workshops, and events is available at the ACF website. Information about all medium- and heavy-duty zero-emission regulations, funding, and background can be found at ZEV TruckStop.

If you have questions or wish to obtain this document in an alternative format or language, call (916) 323-2927. For TTY/TDD/Speech-to-Speech users, dial 711 for the California Relay Service.

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.