Rule Provision Truck Regulation Implementation Group - December 10, 2024

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Background

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

The meeting was recorded and is available on YouTube (https://www.youtube.com/watch?v=jLmiO1qFqY8)

Meeting Summary

The meeting focused on three major topics: 1) The Draft Streamlined ZEV Purchase Exemption List is scheduled to be posted by January 1, 2025; 2) Updates made to the Non-Repairable Vehicle Exemption Fact Sheet; and 3) The available resources for ACF/ Reporting using the Truck Regulations Upload, Compliance, and Reporting System (TRUCRS).

Staff began the meeting with an overview of the ZEV Purchase Exemption, including information on the Standard Process and Basic Eligibility Requirements. Staff then presented the Draft Streamlined ZEV Purchase Exemption List, inviting questions and feedback on the presented information and layout.

A significant portion of the meeting centered on clarifying the verification process for available ZEV configurations and addressing concerns about the feasibility of certain vehicles included on the Draft Streamlined ZEV Purchase Exemption List. Staff also provided updates made to the Non-Repairable Vehicle Exemption Fact Sheet, highlighting its conversion into a checklist format to better assist fleet owners in submitting complete applications.

The meeting continued with a presentation on the resources and tools available to help fleet owners in reporting for ACF/TRUCRS. The meeting was brought to a close after staff provided statistics regarding current and past ACF Exemption requests, providing a year-in-review summary. Meeting summaries are available on CARB’s website.

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

List of Certified Medium- and Heavy-Duty Zero-Emission Vehicles Update

This list is designed to assist fleet owners with identifying ZEVs that have been certified by CARB.

Panelist Comments:

  • No Comments

Draft Streamlined ZEV Purchase Exemption List

This list is designed to assist fleet owners identify vehicle configurations by vehicle class that are unavailable to purchase as ZEVs. Accordingly, fleet owners can purchase these configurations without applying for the ZEV Purchase Exemption. It is important to note that the ZEV Purchase Exemption is not designed to address vehicle range or performance capabilities.

Panelist Comments:

  • Concerns about the performance capabilities and practicality of ZEV body configurations displayed on the Draft Streamlined ZEV Purchase Exemption List.
  • Concerns about the increased vehicle weight of upfits built on an electric chassis.
  • Has staff verified that vehicles on the Draft Streamlined ZEV Purchase Exemption List are being produced and are available for purchase?
  • Concerns about the operational safety of some of the body configurations.
  • If a vehicle is on the Streamlined ZEV Purchase Exemption List, would a fleet be able to purchase that vehicle tomorrow?
  • Concerns about some of the pictures of vehicle body configurations shown during the presentation, such as the crane vehicle, were misleading and may represent a concept vehicle instead of a commercially available vehicle.
  • The industry and TRIG panelists should be able to report back to CARB to help validate the vehicles listed on the Streamlined ZEV Purchase Exemption List.
  • How will a vehicle product be listed if it is found to not be available? Will it change the streamlined list?
  • Will the manufacturers/upfitters that offer the vehicle configurations be included on the Streamlined ZEV Purchase Exemption List?
  • What does the expiration date for a vehicle on the list represent?
  • Would a fleet have to purchase a vehicle on the Streamlined ZEV Purchase Exemption List before the listed expiration date?
  • What are the reporting requirements for purchasing a vehicle on the list?
  • Do public fleets need to provide fleet composition information that shows the exemption is necessary?
  • Does a fleet need to track the vehicles and expiration dates of vehicles removed from the Streamlined ZEV Purchase Exemption List to substantiate a purchase?
  • Concern about the list provides a false sense of security for fleets about the commercial availability of the vehicles on the list.
  • Concern about the non-traditional manufacturers not having the necessary engineering and specifications documentation for upfitters that outline the body configurations that can be built on the chassis while meeting safety and operational standards.
  • Suggested CARB identify the manufacturers and upfitters that produce the verified body configurations on the Streamlined ZEV Purchase Exemption List.
  • If a vehicle on the streamlined list is available in the next higher weight class, does it have to be purchased?
  • Having better communication between the chassis manufacturers and upfitters to determine the types of configurations that are possible could streamline the process and help fleets.
  • What is the process for industry and fleet owners to provide feedback on the configurations that are available?
  • Clarification on the designation of “NA” versus the “No” on the list.
  • Suggested reassessing categories such as Class 5 flatbed trucks and clarify the classification of "combo" vehicles to ensure accurate ZEV availability designations for the Streamlined ZEV Purchase Exemption List.
  • Consider enhancing transparency in the exemption processes by publishing sources (OEMs and body upfitters) used to determine ZEV availability.
  • Explore creating a publicly accessible repository of granted exemptions to provide insight into ZEV availability trends.
  • Address practical limitations in ZEV availability by providing clearer guidance for fleets facing challenges such as long lead times, limited production runs, or upfitting issues.
  • Provide updates on EPA Waiver status.
  •  

Updates to the Non-Repairable Vehicle Exemption Fact Sheet

This fact sheet provides an overview of the Non-Repairable Vehicle Exemption. An update changed the required documentation to a checklist format to better assist fleets.

Panelist Comments:

  • What can an applicant expect regarding the communication and response timeline of a submitted exemption application?

Feedback on Reporting Tools for 2025 ACF Reporting

Staff provided a brief presentation that covered the TRUCRS system, online reporting guide, and YouTube video series. The presentation focused on CARB's desire to receive feedback from stakeholders on the existing reporting tools, which will help inform updates and improvements to the reporting guide for the 2025 reporting cycle.

Panelist Comments:

  • A fleet we work with had some challenges with the large fleet upload file. Were there any issues on the TRUCRS side?
  • What is the purpose of the engine model year in TRUCRS as it relates to ACF?

Exemption/Extension Statistics

As of the meeting date, CARB had received a total of 47 exemption and extension applications. Most applications (33 out of 47) were for the ZEV Purchase Exemption. The remaining 14 applications submitted consisted of the following:

  • Non-Repairable Vehicle Exemption
  • Intermittent Snow Removal Vehicle Exemption
  • Vehicle Delivery Delay Extension
  • Daily Usage Exemption
  • Infrastructure Delay Extension

Out of the 47 total application attempts, 7 had been approved at the time of the presentation. The breakdown of approved applications by type is as follows:

  • 1 Intermittent Snow Removal Vehicle Exemption
  • 2 Non-Repairable Vehicle Exemptions
  • 4 ZEV Purchase Exemptions

The primary reasons for denial of exemption/extension applications include:

  • Exemption/extension not necessary
  • ZEV options available
  • Incomplete applications

Panelist Comments:

  • Does following the ZEV Milestones Option lower a fleet’s ZEV percentage requirement if the fleet has vehicles that are not available in a ZEV configuration?
  • Has staff identified a pattern associated with the incomplete applications submitted?
  • Can applicants dispute the staff determination of an available ZEV?

Next Steps / Next Meeting

The next TRIG meeting is tentatively scheduled for the second or third week of March 2025. This timeframe allows ample opportunity for CARB staff to gather feedback on the Streamlined ZEV Purchase Exemption List and to address the concerns raised by participants.

Action Items

The TRIG meeting concluded with key action items for CARB staff and industry stakeholders, emphasizing collaboration to enhance the implementation of the ACF regulation.

Action Items

  • Post meeting notes
  • Continue to review ZEV availability and reassess existing determinations. Improve the online reporting guide and instructional videos based on user feedback, including clearer explanations and troubleshooting tips
  • Stakeholders to provide feedback about the ZEV Purchase Exemption List, Non-repairable vehicle FAQ, and reporting materials by December 20, 2024
  • Actively participate in TRIG meetings, raise concerns, propose solutions, and contribute to successful regulation implementation.
  • CARB to post Streamlined ZEV Purchase Exemption List by January 1, 2025

Members In Attendance

  • Bang Yong Lo, Daimler Trucks NA
  • Bradley Northup, Public Works Superintendent, City of Carlsbad
  • Bret Stevens, Daimler Trucks NA
  • David Clifford, Ventura Transfer Company
  • Don Jones, City and County of San Francisco
  • Emily Lemei, Northern California Power Agency (NCPA)
  • Joe Korn, Holman
  • Jon Costantino, CCEEB
  • Kristian Corby, California Electric Transportation Coalition
  • Kyle Martin, Innovative Vehicle Solutions
  • Lacy Robertson, Rush Enterprises
  • Lisa McGhee, Tom’s Truck Center
  • Mark Baer, Altec Inc.
  • Michael Lewis, Construction Industry Air Quality Coalition
  • Mike Tunnell, American Trucking Associations
  • Morgan Mitchell, Westside Water Authority
  • Paul Herek, Enoven Truck Body + Equipment
  • Paul Rosa, Penske
  • Rebeca Schenker, Vice President, GNA Clean Transportation & Energy Consultants
  • Robert Teffeteller, Motive Electric Trucks
  • Rick Albertini, Phenix Truck Bodies & Van Equipment
  • Sarah Deslauriers, CA Association of Sanitation Agencies
  • Steve Nelson, Local and regional trucking based in Monterey County
  • Tim Worman, Stellar Industries
  • William Ryder, Brinks
  • Chris Franceschi, CARB
  • Gerald Berumen, CARB
  • Haley McGlasson, CARB
  • Janet Kuzmenko, CARB
  • Jimmy Steele, CARB
  • Matt Kasjaka, CARB
  • Pranish Manandhar, CARB
  • Tiffany Canales, CARB
  • Tony Brasil, CARB