California Air Resources Board

Background

The California Air Resources Board (CARB) hosted the third public Truck Regulation Implementation Group (TRIG) meeting to discuss the Advanced Clean Fleets (ACF) rule provisions. The meeting included discussion of the following topics:

• Lessons learned from received zero-emissions vehicle (ZEV) Purchase Exemption requests.
• Manufacturer/dealer responses when ZEVs are not available in the configuration needed.
• Daily Usage Exemption presentation and discussion.

The meeting was recorded and is available on You Tube https://youtu.be/8MCmR3uU4mw

Meeting Summary

The meeting focused on the ZEV Purchase Exemption process and the Daily Usage Exemption. Staff provided TRIG panelists with a handout  prior to the meeting that provided a brief overview of the ZEV Purchase Exemption requests received, some of the common issues with applications, and highlighted other issues related to the application process. Staff also provided TRIG panelists with a draft ZEV Purchase Exemption checklist  for review and comment. The checklist is intended to assist fleet owners with submitting complete applications for the ZEV Purchase Exemption. Additionally, a presentationcovering the key points of the Daily Usage Exemption  was given to facilitate the initial discussion and to lay the foundation for discussing it in more detail at that next meeting.

The following are summaries of comments about each primary topic discussed during the meeting.

ZEV Purchase Exemption

• How many ZEV Purchase Exemption applications have been submitted and how many have been approved?
• It would be helpful to see a copy of a successful application.
• How will exemption/extension approvals be reflected in TRUCRS?
• Suggestion for CARB to attach exemption/extension approval notices as a file to the VIN in TRUCRS.
• Discussion about lack of manufacturer obligations related to fleet requests for written manufacturer statements?
• Stated concerns that the ZEV Purchase Exemption language is silent about a theoretical scenario where the upfitted configuration could void a manufacturer’s warranty even though the scenario is also possible with ICE vehicles?
• Discussion about the ZEV Purchase Exemption addresses when a new ZEV is not commercially available in the needed configuration where the Daily Usage Exemption considers daily mileage or energy usage when a ZEV is available in the needed configuration?
• Some discussion about how CARB is receiving vehicle purchase information for state and local government fleets (SLG) through phone calls or meetings to determine their compliance requirements and if they will be already complying with the 50% ZEV purchase requirement?
• Discussion about compliance options for a SLG fleet, looking to expand the fleet compared to the exemption process when purchasing a replacement vehicle if no ZEVs are available?
• Stated concerns about funding obstacles for ZEV purchase and compliance options for an SLG fleet if ZEV funding is denied after purchasing some ICE vehicles that year?

ZEV Purchase Exemption checklist

• The checklist is missing the requirement for a written statement from at least two manufacturers.
• The summary at the end of the checklist page makes it seem as if CARB is the only entity that needs to reach out to dealers and manufacturers to determine if ZEVs/NZEVs are available.
• Suggest that CARB and fleets need to be mindful of the differing driver license requirements between Class 6 and Class 7 vehicles since the regulation specifies that the next higher weight class must be considered.
• Discussion about when applications are denied is can applicants have time to review CARB’s decision before the decision is finalized? Discussion followed about CARB having 45-days to respond to ZEV Purchase Exemption applications and to review and solicit manufacturer feedback. In situations where CARB denies an application that should have been approved, CARB will rectify any mistake.
• More discussion followed about supplemental material in applications: that applicants can include more information than required by the regulation to demonstrate the requirements are met, but supplemental information or documentation that is in direct contradiction to the regulation is not helpful and should not be included.
• Suggest including additional space in the checklist to allow for fleets to add supplemental information to describe specialized equipment.
• Are there any CARB qualifications/certifications that an upfitter must meet to ensure that they are meeting the appropriate engineering and safety standards?

Daily Usage Exemption:

• Discussion about towing and its impact on battery capacity and performance fit into the Daily Usage Exemption?
• Suggestion that a larger battery capacity increases the weight of a vehicle and limits the equipment/attachments that can be added to the vehicle.
• How does a fleet deal with ZEV weight concerns?
• How does a fleet address mileage variability of future dispatches?

Future Meetings

Members were asked for feedback and to provide suggestions for future meetings. Those comments and suggestions included:

• Future meeting topics include continuing discussion on the Daily Usage Exemption.

Action Items

• Schedule the next Rule Provisions TRIG meeting and send out a listserv notice.
• CARB to update and publish the ZEV Purchase Exemption checklist.
• CARB to post the updated list of available ZEVs.
• CARB will send out a poll to the panelists on the next three topics the group would like to cover and discuss.
• Co-chairs Bradley or Rebecca will send out a meeting reminder two weeks before each TRIG meeting.

Members In Attendance

• Rebeca Schenker, Gladstein, Neandross & Associates a TRC Company, co-chair
• Gerald Berumen, CARB, co-chair
• Tony Brasil, CARB
• Dorothy Fibiger, CARB
• Chris Franceschi, CARB
• Matt Kasjaka, CARB
• Bret Stevens, Daimler Trucks
• David Clifford, Ventura Transfer Company
• Don Jones, City and County of San Francisco
• Emily Lemei, Northern California Power Agency
• Jaimie Levin, Center for Transportation, and the Environment
• Kristian Corby, California Electric Transportation Coalition
• Lacy Robertson, Rush Enterprises
• Michael Lewis, Construction Industry Air Quality Coalition
• Mike Tunnell, American Trucking Associations
• Morgan Mitchell, Westside Water Authority
• Nick Blair, Association of California Water Agencies
• Peter Okurowski, California Council for Environmental and Economic Balance
• Rick Albertini, Phenix Truck Bodies & Van Equipment
• Sarah Deslauriers, California Association of Sanitation Agencies
• Steve Nelson, Local regional trucking based in Monterey County
• Suzanne Seivright-Sutherland, California, and Industrial Materials Association
• William Ryder, Brinks Inc