Truck Regulation Implementation Group, Rule Provisions Workgroup - September 4, 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 discussion of the following topics:

The meeting was recorded and is available on You Tube https://www.youtube.com/watch?v=CuXZkutjoDM.

Meeting Summary

The meeting focused on presenting new resources that are available on the ACF website at https://ww2.arb.ca.gov/our-work/programs/advanced-clean-fleets/resources. Staff first presented a checklist for the Daily Usage Exemption and then for the ZEV Purchase Exemption. These checklists are intended to assist fleet owners in submitting complete applications for the respective exemption request in CARB’s ACF regulation. The use of the checklists is not required; however, they are available to help users and cover all the documentation required to be submitted. Staff also went over how to access and navigate the searchable list of certified ZEVs. This list is dynamic and will be updated as new Executive Orders (EOs) are released and posted on CARB’s website. Additionally, staff presented the draft survey that could be sent out by CARB to manufacturers, dealers, and upfitters to help CARB better understand vehicles currently available. The meeting was brought to a close after CARB staff provided statistics regarding current and past ACF Exemption requests.

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

Daily Usage Exemption Checklist

This checklist is a tool designed to assist fleet owners with submitting a complete application for the Daily Usage Exemption.

Panelist Comments:

  • Does the checklist specify the 10 percent ZEV or near-zero emission vehicle (NZEV) requirement?
  • Is there a distinction between zero-emission powertrain (ZEP certified) or non-ZEP certified for the Daily Usage Exemption?
  • Could you clarify for public fleets the ZEV Milestones requirement to demonstrate that no other vehicles can be replaced?
  • Please add that you need to include information about all purchases you have made for public agencies.
  • Please provide an example or a case study of a Daily Usage Exemption application to help fleet owners when applying for the exemption.

Draft Daily Usage Exemption Report Template

This report template (spreadsheet) is a voluntary compliance assistance tool designed to assist fleets and evaluate eligibility for the Daily Usage Exemption.

Panelist Comments:

  • How does a fleet owner use the template to determine if the fleet is eligible for multiple Daily Usage Exemptions?
  • Commenter questioned whether CARB introduced a theoretical range factor. As CARB collects more range data, will an updated range factor be incorporated into the spreadsheet, or will the range factor remain consistent per regulation language?
  • If a fleet is subject to the regulation and plans to expand the fleet as a new business, how do the trucks in the new business comply with the 30-day data collection requirement?

New List of Certified ZEV Manufacturers (visualization tool)

This is a PowerBI visualization tool that lists manufacturers with medium- and heavy-duty ZEVs certified for sale in California. This tool is designed as a resource to assist fleet owners with ZEV purchases that will comply with the ACF regulation.

Panelist Comments:

  • Where is this information sourced from?
  • Who can be contacted for comments and concerns about the list?
  • Can CARB work with manufacturers to provide additional information such as better descriptions about vehicle models to improve the list?
  • Recommend clarifying the distinction between ZEP certified and non-ZEP certified vehicles.
  • Recommend adding a column to identify which ZEVs are complete vehicles vs incomplete vehicles.
  • Recommend adding a column to identify body type.

Some clarity is needed on the stated gross vehicle weight rating to better understand the vehicle class range (e.g., is the class 3 ZEV on low end of range or high end of the weight range?)

  • Please add a description to the webpage about the purpose of the list.

ACF ZEV Purchase Exemption Checklist

This checklist is intended to assist fleet owners in ensuring that they submit complete applications for the ZEV Purchase Exemption.

No comments or questions were given on this topic.

Draft Manufacturer/Dealer/Upfitter Survey

The purpose of this survey is to assist CARB identify manufacturers and upfitters, help identify ZEVs that are currently available, and to expand CARB’s contact list.

Panelist Comments:

  • What is the objective of the survey?
  • What is the status of the ZEV Purchase Exemption List?
  • Recommend identifying whether the vehicles have undergone road tests for both combustion and ZEVs. Before any purchases can be made, fleets must make sure that the vehicle has been tested on the road, or as part of demonstrations.
  • Will there be a process for exchanging information on power energy requirements to determine if an upfit is feasible for operating on-site equipment?
  • Is participation in this survey optional?
  • If a manufacturer completes the survey and receives an email from CARB, are they required to respond?
  • Concern that the survey may not be as helpful as CARB wants because it may not capture the many different custom solutions involved in upfitting vehicles by different upfitters.
  • Is the survey a one-time event or will it be updated regularly?
  • Will the survey consider commercial driver license operators?
  • If someone doesn’t have a relationship with an upfitter or manufacturer, will they still need to purchase the vehicle if it’s the only one available?
  • Is there any consideration for service networks?
  • Will the survey be shared?
  • Could it serve as a resource for fleets to provide manufacturer documentation when applying for exemptions?
  • Recommend disclosing that the information in the survey could become public.
  • Recommend including a section for associations that the upfitter is affiliated with.

Draft ZEV Purchase Exemption Request for Review

This visualization tool may be used as a public solicitation resource of ZEV availability in accordance with the ACF regulation.

Panelist Comments:

  • Will this information be posted on the ACF website?
  • Would a manufacturer respond to this request by stating that they produce a ZEV with a particular configuration?
  • If CARB receives responses from five manufacturers or upfitters, will the applicant receive information about those upfitters and the make and models they produce?

Current Exemption Statistics

A total of 34 applications have been received for ACF exemptions and extensions. 68 percent of these applications have been for the ZEV Purchase Exemption, 15 percent for Non-Repairable Vehicle Exemption, and the remaining six applications received were spread across Intermittent Snow Removal Vehicle Exemption, Vehicle Delivery Delay Extension, Daily Usage Exemption, and the Infrastructure Delay Extension. Of these 34 applications, three applications have been approved as of today. We have one of ZEV Purchase Exemption approval from a high priority fleet following the Model Year Schedule, one approval for the Intermittent Snow Removal Vehicle Exemption from a high priority fleet following the Model Year Schedule, and we have one approval for the Non-Reparable Vehicle Exemption for a drayage day cab. Primary reasons for denials include that in the best case, an exemption simply wasn't needed due to flexibility in the regulation based on the selected compliance option or early purchase credits. Other reasons for denial include missing or ineligible documents resulting in an incomplete application, requesting exemptions for a vehicle that is not subject to ACF, or CARB has identified a zero-emission vehicle option available for sale in CA.

Panelist Comments:

  • For the ZEV Purchase Exemption, what aspects were done correctly by successful applicants?
  • Are there specific mistakes that led to rejections?
  • It would be helpful to include details on successful applications and common errors.
  • What can someone expect to receive after submitting an exemption application?

Next Meeting

Staff asked panelists to check schedules for the week of December 9, 2024, for the next meeting. One of the topics to be discussed will be the streamlined ZEV Purchase Exemption List. Panelists were asked for their suggestions on additional meeting topics.

Panelist Comments:

    • Discussing impacts of AB 1594 and section 100 changes including discussions on draft provisions.
    • Would be helpful to go over how compliance reporting will work for public fleets (e.g., compliance date vs purchase date).
    • Additionally, it would be helpful to go over the specifics of the streamlined ZEV Purchase Exemption and how public fleets following the ZEV Purchase Schedule will prove that they need the exemption.

Action Items

  • Post September 4, 2024, meeting notes.
  • Schedule the next Rule Provisions TRIG meeting and send out a listserv notice.
  • Update and publish the Daily Usage Exemption Checklist along with the Daily Usage Compliance Assistance spreadsheet.
  • Revise and send out the ACF Regulation Vehicle Availability Survey to manufacturers, dealers, and upfitters.
  • Update and publish the ZEV Purchase Exemption Request for Review to the ACF webpage.

Members In Attendance

  • Jon Costantino
  • Kristian Corby
  • Sarah Deslauriers
  • Rick Albertini
  • Bret Stevens
  • Bradley Northup
  • Mike Tunnell
  • Marty Tufte
  • Emily Lemei
  • Lacy Robertson
  • David Clifford
  • Don Jones
  • Michael Lewis
  • Rebecca Schenker
  • Steve Nelson
  • Suzanne Seivright-Sutherland
  • William Ryder

CARB

  • Gerald Berumen
  • Pranish Manandhar
  • Dorothy Fibiger
  • Tony Brasil
  • Chris Franceschi
  • Tiffany Canales
  • Haley Mcglasson
  • Matt Kasjaka