California Air Resource Board Implementing New Compliance Measures

Note: This article was updated 1/15/24 to reflect regulation updates.

The California Air Resources Board (CARB) is the primary state agency responsible for protecting public health from air pollution in California. By January 31, 2024, fleets operating heavy-duty trucks (i.e., vehicles over 14,000 lbs. GVW) in California must comply with the new Clean Truck Check emissions monitoring regulation. More information about specific compliance obligations under the Clean Truck Check regulation is below under the “How is Your Fleet Impacted?” section.

In addition, under CARB’s Advanced Clean Fleet regulation, most fleets will be required to report all vehicles operating in the state of California that are over 8,500 lbs. GVW. This regulation is intended to phase out internal combustion engine (ICE) vehicles and replace them with “zero emission” alternatives. The original reporting deadline was February 1, 2024. However, as announced in late December 2023, CARB suspended enforcement of the Advanced Clean Fleet regulation pending the Environmental Protection Agency’s (EPA) determination on CARB’s request for a “preemption waiver” under the federal Clean Air Act (CAA), which generally prohibits states from enacting their own vehicle emissions standards without such a waiver. CARB is asking, while the waiver request is pending, that fleets nonetheless “voluntarily” report their vehicle information and work towards compliance with the regulation, since the regulation will apply retroactively upon EPA’s approval of CARB’s waiver request.

The Clean Truck Check and Advanced Clean Fleet regulations aim to ensure well-maintained heavy-duty trucks, reduce vehicle emissions and enhance public health.

How Is Your Fleet Impacted?

January 31, 2024:
The Clean Truck Check regulation is a comprehensive heavy-duty vehicle inspection and maintenance regulation aimed at ensuring that vehicles’ emissions control systems are properly functioning. It applies to vehicles over 14,000 lbs. and includes a biannual (i.e., twice a year) emissions inspection requirement that replaces the current PSIP Periodic Smoke Inspection Program, which expires in 2024.

Fleets must create an account on the California Clean Truck Check, Vehicle Inspection System (CTC-VIS) Portal, report their affected vehicles on the CTC-VIS Portal, and pay a $30 per affected vehicle fee by January 31, 2024.

February 1, 2024:
Under CARB’s Advanced Clean Fleet Regulation, February 1, 2024 was the original reporting deadline for fleets to submit their reports for all trucks operating in California weighing over 8,500 lbs in the TRUCRS system. GVW. Fleets can opt to comply with either the Model Year Schedule or the ZEV (Zero Emission Vehicles) Milestones Option.

• The Model Year Schedule mandates that only ZEVs may be added to a California fleet starting in 2024, with the gradual removal of internal combustion engine vehicles beginning in 2025 based on mileage thresholds.
• ZEV Milestones Option allows fleets to phase in ZEVs based on percentage targets for specific vehicle types from 2025 to 2042.

As noted above, CARB has suspended enforcement pending EPA’s determination on CARB’s request for a preemption waiver, but fleets are nonetheless encouraged to comply with the reporting requirement during pendency of EPA’s determination as the regulation will apply retroactively upon approval of the request.

Additional Awareness

Other states are beginning information-gathering processes for what Holman believes will lead to regulations in those states similarly aimed at reducing vehicle emissions. In early 2023, the state of New York requested a one-time fleet report as part of New York’s Advanced Clean Truck (ACT) Regulation. In December 2023, the state of Washington issued a one-time fleet reporting requirement for fleets to report information on their vehicles that operated in Washington during the 2022 calendar year, as part of Washington’s Zero-emission vehicles law.

Holman’s Commitment

Holman is committed to helping you find the best solutions for your fleet and sustainability needs. We will continue to monitor regulations and provide supporting information and updates to help you meet your compliance obligations with respect to your vehicles.

What’s Next?

For fleets in California, meeting the January 31st deadline for reporting your vehicles in the CTC-VIS Portal is critical. If you have questions about your fleet, please contact us at [email protected].