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Changes to Truck and Bus Regulation Based on Regulation Adopted on April 25, 2014

On April 25 the ARB Board adopted changes to the truck and bus regulation. These changes are summarized below. To jump to detail on each topic click on that item.

For information straight from ARB see:
Truck and Bus Regulation Summary of Amendments Approved in April 2014
And as usual there is some uncertainty on some of the changes which ARB staff will have to clarify.

Enforcement

DMV Data: The Board also directed staff to work with DMV to the extent possible to help ensure compliance using DMV registration data. Note that one problem here is that DMV data does not apply to the 620,000 heavier trucks registered out of state that travel some of the time inside CA.

Compliance Generally: FYI ARB says that the regulation applies to

ARB also says 80% of fleets are in compliance.

Low Mileage Exemption

Was: Trucks that run less than 1,000 mi/yr, and 100 engine hours per year (if PTO used for some purpose other to load or unload the vehicle), are exempt from PM retrofit and 2010 engine standards.

Now: 5,000 mi/yr with no hour limit. If a truck runs more than 5,000 mi/yr and operates both inside and outside CA, the limit is 1,000 mi/yr. This exemption ends in 2020.

Uncertainty: It appears that both exemptions can be used. My question is can a truck owner could use the 5,000 mi limit until 2019 and the then switch to the 1,000 mi/yr exemption in 2020? Logic would say yes.

Low Mileage Work Trucks

Was:

Now:

Uncertainty: The definition of "work truck" is confusing and is far more complicated that it needs to be. I assume ARB will have to issue clarification.

Reduction in Maximum No. Trucks Per Year that Must Meet 2010 Engine Standards

Was: No such option.

Now: Puts a cap on the number of trucks that must meet 2010 engine standards: 25% of the fleet of lighter or heavier vehicles, or two lighter or heavier trucks, whichever is larger.

Small Fleet (3 or fewer trucks larger than 14,001 lbs GVWR where one or more is larger than 26,000 lbs GVWR

Was: First truck larger than 26,000 lbs GVWR had to meet PM filter requirements by 2014, the second larger than 26,000 lbs GVWR by 2015, and the third larger than 26,000 lbs GVWR by 2016.

Now: First larger than 26,000 lbs GVWR is the same, the second larger than 26,000 lbs GVWR has until 2017, and the third larger than 26,000 lbs GVWR until 2018.

Bad Credit Option

Was: No such provision

Now: If a truck owner can prove he/she was denied a load for a PM filter or new truck and the owner can commit to upgrade the truck by Jan 1, 2016 then the truck is not on hook for that filter for up to three trucks. To use this option truck owners need to report by the end of the year.

Uncertainty: This proposal was modified at the board hearing. And the exact change needs to be verified.

Credit for Early Compliance

PM Filter Retrofits Before Jan 1, 2014

Was: Trucks equipped with a PM filter by Jan 1, 2014 were required to meet 2010 engine standards between 2020-2022; depending on the truck weight and engine age.

Now: Trucks with equipped with a PM filter by Jan 1, 2014 do not have to meet 2010 engine standards until 2023.

Reduced Fleet Size Credit

Was: To use this credit fleets had to report by Jan 31, 2012 and could get credit towards PM filter requirements if the fleet had fewer heavier trucks in a compliance year than in 2006. The credit expires 2016.

Now: Fleets can report for this credit which now expires Jan 1, 2018.

Uncertainty: I am unclear if fleets had to have reported by Jan 31, 2014 to use this credit. This is another topic where ARB will need to provide clarification.

Alternative Fuel and Advanced Technology Truck Credits

Was: Fleets with a heavier vehicle powered by a fuel other than diesel or gasoline were allowed to treat another vehicle as compliant with PM filter requirements until Jan 1, 2017. Lighter trucks were also eligible if the alternative fueled truck was added before 2012.

Now: Fleets with light and heavy hybrid and electric trucks (advanced technology) can treat another light or heavy truck as compliant until 2020. Fleets powered with a fuel other than diesel or gasoline (and excluding hybrid and electric vehicles) can treat another truck as compliant with PM filter requirements until 2018.

NOx Exempt Areas

Was: Exempts heavier trucks from replacement provided they are retrofit between 2014 to 2016 and run entirely in one or more of the following counties or areas: Alpine, Colusa, Del Norte, Glenn, Humboldt, Lake, Lassen, Mendocino, Modoc, Monterey, Northern Sonoma, Plumas, San Benito, San Luis Obispo, Santa Barbara, Santa Cruz, Shasta, Sierra, Siskiyou, Trinity, Tehama, and Yuba.

Now: