ZEV Milestones Option Fact Sheet

Which vehicles are included or excluded in the ZEV Milestones Option?

Only vehicles that have a gross vehicle weight rating (GVWR) greater than 8,500 lbs., are light-duty package delivery vehicles, or are yard tractors, and that are operated in California are included in the ZEV Milestones Option.

Light duty vehicles and ZEVs, other than light-duty package delivery vehicles as defined in the regulation and below, are not included in the California fleet count nor do they count towards ZEV Milestones Option compliance.

Certain vehicle types are excluded from the regulation as follows::

• School buses as defined in California Vehicle Code (CVC) section 545(a);
• Emergency vehicles defined in CVC 165;
• Vehicles awaiting sale;
• Military tactical vehicles;
• Historical vehicles;
• Dedicated snow removal;
• Two-engine vehicles;
• Heavy cranes;
• Transit vehicles subject to the Innovative Clean Transit regulation;
• Vehicles subject to the Mobile Cargo Handling regulation; and
• Manufacturer test fleets

How do I report the Milestones Group in TRUCRS?

If using the ZEV Milestones Option, it is important to differentiate your California fleet’s body types correctly and to plan for compliance. The ZEV Milestones Option groups these vehicle types by those most suited for electrification in the Milestone Groups.

The TRUCRS system will properly assign your vehicle to the correct Milestones Group based on the information you report.

For more details on truck body types, we will be releasing a fact sheet on the TRUCRS body type categories in the near future.

• Select the body type that most closely applies to your vehicle. Select “Other – Work Truck” if not one of the body types listed.
• Select the GVWR, and indicate whether the vehicle has a heavy front axle (rated to exceed 12,500 lbs.)

Which Milestones Group does my vehicle fit in?

“Milestone Group 1” includes all the light-duty package delivery vehicles, box trucks, vans, buses with two axles, and yard tractors in the California fleet.

“Milestone Group 3” means the sleeper cab tractors and specialty vehicles within the California fleet. Specialty vehicles are defined as Class 8 vehicles with heavy front axles (rated to exceed 12,500 lbs.), or Class 8 vehicles that perform work while stationary (see definition in next section).

Every other vehicle type is in “Milestone Group 2”, which includes the work trucks, day cab tractors, pickup trucks, and buses with three axles in the California fleet.

What are the definitions for the Milestones Group category?

The ZEV Milestones Option allows fleet owners to phase ZEVs into their California fleet based on the body type of the vehicle. The regulation provides definitions for each of the listed body types in section 2015(b). They are listed here for reference:

• “Box truck” means a single-unit vehicle with a fully or partially enclosed space with a roof and at least three sides designed for transporting cargo or payload, excluding the driver and passengers. Examples include vehicles commonly referred to as step vans, refrigerated vans, dry vans, chipper trucks, and box reefer trucks.
• “Bus” means any vehicle designed, used, or maintained for carrying more than ten persons, including the driver, and configured with seats for the primary purpose of transporting persons including the driver.
  • Two-axle bus means any bus that has two axles.
  • Three-axle bus means any bus that has three axles.
• “Day cab tractor” means an on-road tractor without a berth designed for resting or sleeping at the back of the cab and that is not a yard tractor.
• “Light-duty package delivery vehicle” means a motor vehicle with a GVWR equal to or less than 8,500 lbs. with equal to or greater than 100 cubic feet of cargo-carrying volume, as defined in title 49, C.F.R. section 523.2 as it existed on June 3, 2022, which is incorporated by reference herein, that is regularly used to deliver packages, parcels, or mail.
• “Pickup truck” means a vehicle originally manufactured as a complete vehicle with an open box-type bed that meets the definition set forth in CVC section 471. A “pickup truck” with a removable bed cover or camper shell installed is considered a “pickup truck” for the purpose of this article.
• “Sleeper cab tractor” means a tractor with a berth designed for resting or sleeping at the back of the cab.
• “Specialty vehicle” means one of the following:
  • (A) A vehicle with a GVWR greater than 33,000 lbs. and with a heavy front axle; or
  • (B) A vehicle with a GVWR greater than 33,000 lbs. that is not designed to carry cargo and is configured to perform work that can only be done while the vehicle is stationary and the auxiliary mechanism to perform that work is an integral part of the vehicle design. Examples include vehicles commonly known as vacuum trucks, digger derricks, drilling rigs, and concrete pump trucks.
  • “Heavy front axle” means any front steering axle whose gross weight imposed upon the highway by the wheels is rated to exceed 12,500 lbs. The axle weight rating is typically found on the manufacturer’s affixed certification label which contains the gross axle weight ratings and the gross vehicle weight rating.
• “Van” means a single unit vehicle configured with seats to transport passengers or with an enclosed space for the primary purpose of transporting cargo and equipment.
• “Work truck” means a vehicle that does not meet any of the definitions of box truck, van, bus, light-duty package delivery vehicle, pickup truck, day cab tractor, sleeper cab tractor, or specialty vehicle.
• “Yard tractor” means a vehicle that has a movable fifth wheel that can be elevated and is used in moving and spotting trailers and containers at a location or facility. Yard tractors are also commonly known as yard goats, hostlers, yard dogs, trailer spotters, or jockeys.

While most vehicles clearly meet a category’s definition, others may be less clear into which category they fall. The “work truck” category is intended as a catchall category for vehicles that do not meet the other defined categories. The following guidance can help fleet owners determine into which category a vehicle falls but is not intended to be a replacement for the regulation language. Where this information differs from the regulation language, the regulation language is controlling:

What vehicles are in Milestones Group 1?

Milestone Group 1 includes box trucks, vans, buses with two axles, on- or off-road yard tractors, and light-duty package delivery vehicles.

What is a van?

Vans are typically certified by the vehicle manufacturer as complete vehicles and are sold as a passenger van (often with side windows) or cargo van (often without side windows).

Cutaway vehicles with a cab that looks like the front end of a van that are sold as incomplete vehicles and are upfit with a body, are not considered vans, and are classified by the final body configuration.

Vans are typically Class 2b-3.

What is a box truck?

Box trucks are typically certified by the vehicle manufacturer as an incomplete vehicle, cab-and-chassis, or cutaway.

The category includes vehicles configured with a body originally designed for delivery of cargo or payload (excluding the driver and passengers), or that are otherwise listed in the regulation’s definition of box truck.

• Category includes any step vans, refrigerated vans, dry vans, chipper trucks, box reefer trucks

Other truck types that are included in the category:

• Beverage trucks with roll-up cargo bay doors
• Armored box trucks

The category generally excludes vehicles with a box body that are not originally designed for delivery of cargo or payload, that have equipment integrated into the body, that are designed for human habitation, or that are originally designed for and used for transporting tools and equipment to a job site. Such vehicles, though they may have a “box” with at least three sides and a roof, are not considered box trucks. Additionally, vehicles with a box body with fully removable sides, such as curtainside trucks, are not considered box trucks.

• Liftgates and similar low voltage systems are not considered integrated equipment. Integration is a matter of degree, but typically includes power or hydraulic lines routed through the vehicle and would not include self-contained equipment like a stand-alone generator or stand-alone air compressor that happens to be bolted on the body of the truck rather than strapped down.

The category also excludes combination bodies that have a box and some other configuration on the same body attached to the frame. For example:

• Vehicles with integrated combination chipper box and crane body.
• Vehicles with combination half stake-bed and half box.

Use case is not considered. A box truck that is used for purposes other than its original design is still a box truck. A work truck used to deliver cargo or goods is still a work truck.

Box trucks are typically Class 3 to 8.

What is a light-duty package delivery vehicle?

Light-duty vehicles must meet the definition of a “light-duty package delivery vehicle” to be included in the regulation. The vehicle would need to have 100 cubic feet or greater of cargo carrying capacity, and be regularly used to deliver mail, parcels, or packages. Package delivery vehicles are in the business of transporting packages and mail.

Light-duty vans used to transport large appliances or used to provide service to a customer (for example, those used by computer repair technicians, plumbers, or by security system installation technicians) would not be included. Appliances are generally large pieces of equipment that would not be considered parcels or packages. If the vehicles are used to transport equipment and install it in customer homes, this is similar to other use cases that would also not be considered package delivery, such as a heating and air conditioning technician bringing a new unit to install in a customer's home.

Vehicles that are used more than half the time to deliver packages, parcels, or mail would be considered “regularly” delivering packages, parcels, or mail.

What is a yard tractor?

Yard tractors are on- or off-road certified vehicles that are used in moving and spotting trailers and containers at a location or facility. On-road yard tractors are often very similar to off-road yard tractors and have license plates, safety lights, and other features that make them safe to drive on-road as necessary.

These are typically certified as complete vehicles by the manufacturer.

What is a two-axle bus?

Two-axle buses are those vehicles that meet the definition of “bus” that have two axles.

Vehicle types included in this category:

• Shuttle bus
• Limo bus
• Cutaway with bus body

These are typically certified as complete or incomplete vehicles by the manufacturer.

What vehicles are in Milestones Group 2?

“Milestone Group 2” includes the work trucks, day cab tractors, pickup trucks, and buses with three axles in the California fleet.

What is a day-cab tractor?

Any Class 7 or 8 tractor used to pull trailers that has a cab not equipped with a sleeper berth would fit in this category. These are typically used in regional haul, drayage, or local haul applications.

These are certified as complete vehicles by the manufacturer.

What is a pickup truck?

Pickup trucks have a standard open-box type pickup bed not exceeding 9 feet in length, a GVWR of less than 11,500 pounds, an unladen weight of less than 8,001 pounds, and which is equipped with an open box-type bed not exceeding 9 feet in length. This does not include pickup cabs equipped with a bed-mounted storage compartment unit commonly called a “utility body,” as these would be work trucks.

These are typically certified as complete vehicles by the manufacturer.

What is a three-axle bus?

Three-axle buses are those vehicles that meet the definition of “bus” that have three axles.

Vehicle types included in this category:

• Motor Coach Buses

These are typically certified as complete vehicles by the manufacturer.

What is a work truck?

Work trucks are typically certified by the vehicle manufacturer as an incomplete vehicle or cab-and-chassis, and are upfit with specialized bodies to perform some vocational or work function.

Work truck designation is dependent on the vehicle’s configuration. The definition of “configuration” in the regulation is as follows:

• “Configuration” means the primary intended function for which a complete vehicle is designed, or as determined by the body permanently attached to the chassis of an incomplete vehicle. Examples of configurations include bucket trucks, box trucks, concrete pump trucks, dump trucks, digger derricks, drill rigs, stake bed trucks, flatbed trucks, and tow trucks. The configuration does not include any auxiliary equipment or secondary uses of equipment added to or carried on the vehicle body. Examples of truck-mounted equipment include welding equipment, lift gates, portable tanks, generators, storage cabinets, and winches

The definition of “configuration” looks at the “primary intended function” of the vehicle and the equipment integrated into the body. As noted in the prior section, equipment integration is a matter of degree and would generally not include low voltage systems or auxiliary equipment added to the body aftermarket. Power take-off powered equipment integrated into the body is a good indicator that the vehicle is a work truck.

Other truck types that are included in the category:

• Scissor lift trucks
• Curtainside trucks
• Mobile laboratories
• Mobile library trucks
• Utility or service body trucks
• Construction trucks
• Tank or dump trucks
• Shredder trucks

Work trucks are typically Class 3 to 8.

What vehicles are in Milestones Group 3?

“Milestone Group 3” includes the sleeper cab tractors and specialty vehicles in the California fleet.

What is a sleeper cab tractor?

Any Class 7 or 8 tractor with a cab equipped with a sleeper berth would fit in this category. These are typically used in longer distance or interstate travel.

These are certified as complete vehicles by the manufacturer.

What is a specialty vehicle?

Specialty vehicles are defined as:

• Any Class 8 vehicle (with a GVWR over 33,000 lbs.) that have a heavy front axle (rated to exceed 12,500 lbs.), or
• Any Class 8 vehicle that is not designed to carry cargo, and is configured to perform work that can only be done while the vehicle is stationary. The work mechanism must be integral to the vehicle design.

Vehicles with specialized bodies that are not Class 8 would generally be in the work truck category.

Other truck types that are included in this category:

• Class 8 vacuum trucks
• Class 8 digger derricks
• Class 8 drilling rigs
• Class 8 concrete pump trucks
• Class 8 bucket trucks
• Class 8 refuse collection trucks with heavy front axle

How does “any ZEVs count for compliance” work for ZEV Milestones?

The regulation specifies that “any ZEV from any Milestone Group can be used to count toward the fleet’s ZEV Fleet Milestone requirement. For example, a fleet with box trucks and day cab tractors can meet the total ZEV Fleet Milestone requirement with ZEV day cab tractors instead of ZEV box trucks.” For a simple example, a fleet with only 100 sleeper cab tractors would need 10 ZEVs in the fleet by January 1, 2030. The fleet owner could remove 10 sleeper cab tractors, and add 10 of any ZEV type, such as ZEV pickups, that are within the scope of the regulation to meet this requirement.

Are the ZEV Milestones requirements based on the nationwide fleet?

No, the ZEV Milestones requirements are based only on the subset of vehicles operated in California by a fleet owner or controlling party during a calendar year. Fleet owners should only report the vehicles that operate in California for this option.

Do ZEVs that never come to California count toward the Milestones requirements?

No. ACF only affects the California fleet, which is defined as the subset of vehicles operated in California by a fleet owner or controlling party during a calendar year. ZEVs would need to operate in the State during the calendar year to count towards a fleet owner’s ZEV Milestones requirement for that year.

How does removing a vehicle from the California fleet affect my ZEV Milestones fleet size and compliance calculation?

Vehicles sold, scrapped, or otherwise no longer owned or that no longer exist would reduce the number immediately for purposes of the ZEV Milestones calculation. However, it was not intended to reduce the fleet size for vehicles still owned by the same fleet that are transferred out of state but are brought back to operate in California in the same or subsequent calendar years. Transferring a vehicle out of state and allocating it to local operation somewhere else, then bringing it back to operate in California after it was transferred out of state, is not considered removing a vehicle from the California fleet by definition because the fleet owner is still able to continue operating that vehicle in the state. Indicating a vehicle is transferred out of state is effectively telling CARB the vehicle will not be operated in California the following year. Therefore, these vehicles would not be removed from the California fleet count until the end of the current calendar year for purposes of the ZEV Milestones Calculation.

How do lease renewals, buy-outs, and swaps affect my ZEV Milestones fleet size and compliance calculation?

Leased vehicles that have their lease renewed or bought-out are not treated as new additions to the fleet, and do not increase or decrease the fleet size.

Lease swap-outs, where a new leased vehicle replaces an old leased vehicle, are treated as new additions to the fleet. If there is an overlap period between receiving the new vehicle and removing the old one, the ZEV Milestones fleet size will temporarily increase during the overlap period, but not for the whole calendar year per the guidance above related to vehicles that are sold, scrapped, or no longer owned.

Are vehicles registered as non-operational included in the ZEV Milestones calculation?

Yes. Vehicles that are still in the California fleet that have not been destroyed, scrapped, sold out of the fleet, or transferred out of state would need to be included, including vehicles registered as non-operational or vehicles that are used for parts. The vehicle would need to be registered as "non-revivable junked or dismantled" to be considered removed from the California fleet.

How does expanding the fleet with ZEVs affect the ZEV Milestones Calculation?

The ZEV Milestones calculate based on all the vehicles within the “vehicle scope” of the regulation in the California fleet, regardless of fuel type. For example, with a fleet of 100 sleeper cab tractors, if the fleet owner expands the California fleet by buying 10 ZEVs without replacing any vehicles, that increases the California fleet size to 110 vehicles, which would necessitate 11 ZEVs instead of just 10 to meet the Milestones requirement. This affects the ZEV Milestones Calculation in the year the vehicles arrive in the California fleet.

Additionally, the type of vehicle added to the fleet will affect the Milestones calculation. For example, if the fleet with 100 sleeper cab tractors decides to meet their requirement by buying 10 ZEV pickup trucks without removing any vehicles, the ZEV pickups would be counted in the Milestone Group 2 fleet count. In 2030, Milestone Group 2 has a 25% requirement, while Milestone Group 3 has a 10% requirement. To accurately calculate the necessary number of ZEVs for 2030 in this scenario, we would count 10 pickups in Group 2, multiplied by 25% to get 2.5, which rounds up to 3 ZEVs needed from the Group 2 obligation, and 100 multiplied by 10% which is 10 for the Group 3 obligation. This gives a total of 13 ZEVs needed by January 1, 2030, which means the fleet would not be meeting their Milestones requirement. The fleet would need to buy a few more ZEVs total to meet this requirement - a total of 13. Again, they can be from any Milestone Group, but it is important to note the nuance that depending on which Group the ZEV is in, simply expanding the fleet will affect the Milestones requirement.

Please use the fleet calculator tool to plan for various scenarios.

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.