Initial compliance and reporting dates.The California regulation governing in-use diesel powered off-road mobile equipment 25 hp or larger is in effect. When fleets must comply is based on:
Fleet Size:
Large Fleets (5,000 or more total fleet hp)
Medium Fleets (2,501 to 5,000 total fleet hp)
Small Fleets (less than 2,501 hp)
When the fleet was formed. ARB says that an existing fleet is one that was formed in state or operated in state before Jan 1, 2012.
Where the equipment operates. Fleets that operate entirely in areas that meet the federal ozone standard are called Captive Attainment Area Fleets and are subject to the small fleet requirements regardless of size. For a list of these counties Click on Rule Summary, and then on box that contains the text "Captive Attainment Area Fleet"
So when do you have to report and be in compliance?
Existing fleet that does not operate entirely in a Captive Attainment Area:
Large Fleets
First reporting deadline: You should have reported by now. If you have not reported our understanding is you can still report, but you must be in compliance for the previous compliance deadline.
Annual reporting. Due each year by March 1 for the preceding Jan 1 deadline.
First compliance deadline. Was Jan 1, 2014.
Medium Fleets
First reporting deadline: You should have reported by now. Our understanding is you can still report.
Annual reporting: Once the initial reporting is done your next reporting deadline is March 1, 2016 (for the fleet as it exists on Jan 1, 2016)
First compliance deadline: Jan 1, 2017.
Small fleets
First reporting deadline: You should have reported by now. Our understanding is you can still report.
Annual Reporting: Once your initial reporting is done your next reporting deadline is March 1, 2018 (for the fleet as it exists on Jan 1, 2018)
First compliance deadline: Jan 1, 2019.
New fleet that does not operate entirely in a Captive Attainment Area:
Large Fleets
Reporting deadline: Reporting is due within 30 days of the date the entity starts operating in California.
Annual Reporting: Once your initial reporting is done you are required to report annually with reports due March 1 showing your fleet as it exists on the previous Jan 1.
First compliance deadline. Immediate. The fleet must meet the next large fleet emission target at the time of reporting.
Medium Fleets
Reporting deadline: Reporting is due within 30 days of the date the entity starts operating in California.
Annual Reporting: Once your initial reporting is done you are required to report annually with reports due March 1 showing your fleet as it exists on the previous Jan 1.
First compliance deadline. Immediate. The fleet must meet the next large fleet emission target at the time of reporting.
Small fleets
First reporting deadline: You should have reported by now. Our understanding is you can still report.
Annual Reporting: Once your initial reporting is done you are required to report annually with reports due starting March 1, 2018 showing your fleet as it exists on the previous Jan 1.
First compliance deadline; Jan 1, 2019.
Existing fleet that operates entirely in a Captive Attainment Area:
All Fleet Sizes are Treated as Small Fleets
Reporting deadline: First reporting deadline: You should have reported by now. Our understanding is you can still report.
Labeling. In addition to labeling each piece of equipment with the ARB issued equipment ID numbers (EINs), the equipment must also meet the captive equipment labeling requirements (EIN white on green background)
Annual Reporting: Once your initial reporting is done you are required to report annually with reports due March 1 showing your fleet as it exists on the previous Jan 1.
Annual Reporting: Once your initial reporting is done you are required to report annually with reports due March 1, 2018 showing your fleet as it exists on the previous Jan 1.
First compliance deadline. Jan 1, 2019.
New fleet that operates entirely in a Captive Attainment Area:
All Fleet Sizes are Treated as Small Fleets
Reporting deadline: Reporting is due within 30 days of the date the entity starts operating in California.
Labeling. In addition to labeling each piece of equipment with the ARB issued equipment ID numbers (EINs), the equipment must also meet the captive equipment labeling requirements (EIN white on green background)
Annual Reporting: Once your initial reporting is done you are required to report annually with reports due March 1 showing your fleet as it exists on the previous Jan 1.
First compliance deadline. Jan 1, 2019.
First compliance deadline. Immediate. The fleet must meet the next small fleet emission target at the time of reporting.
Reporting equipment bought and sold. You are supposed to report (update your ARB fleet information) equipment bought/sold within 30 days of the transaction.
Medium Feets no longer need to worry about becoming a Large Fleet.Medium sized fleets no longer need to worry about becoming a large fleet. The regulation says that if a medium fleet becomes a large fleet it must meet large fleet requirements on the reporting date two years subsequent to the year it became a large fleet. So for example if during 2015 a medium fleet purchases equipment which kicks it over the large fleet size threshold (5,000 hp) it would have to meet the large fleet Jan 1, 2017 compliance requirements. The compliance requirements on Jan 1, 2017 are the same for medium and large fleets.
Year-By-Year Low Use exemption is a powerful and low risk exemption. Engines that run less than 200 hours per year during a calendar year can be classified as "Year-by-Year Low Use" and the hp deducted from the hp used to determine fleet size and compliance obligations. This can significantly reduce/delay compliance obligations, but you have careful how it is used.
Restrictions on what you can buy and use.
Large and Medium fleets cannot buy Tier 0/1 powered equipment and cannot buy Tier 2 equipment starting Jan 1, 2018.
Small fleets cannot buy Tier 0 equipment, beginning cannot buy Tier 1 equipment beginning Jan 1, 2016;and Tier 2 equipment beginning Jan 1, 2023.
Other Requirements
Restrictions on idling. Except in certain situations equipment cannot idle more than five minutes. Large/medium fleets are required to have a written idling policy.
Selling disclosure – Sellers need to notify buyers that the equipment could be subject to ARB's off-road regulation.
All equipment must have Equipment labeling
Complexity. Be careful this regulation has number of complex twists and turns.