The California Air Resources Board (CARB) Truck and Bus Regulation has end of year reporting requirements for all truck owners needing a compliance certificate or operating trucks under any credit or extension to the regulation.
As the 1/31/2016 reporting deadline approaches, members should take a minute to ensure they are on solid ground in the New Year. This article provides an end of year checklist for fleets that desire to operate “CARB-legal” in 2016:
The end of year summary for the Truck and Bus Regulation is:
- Fleets that “phased-in” compliance for their heavy trucks must meet a 100% filter requirement on 1/1/2016 unless reported credits extend that date.
Low use vehicles must be reported accurately and operated within the 1,000 or 5,000 annual mileage limit, except for an emergency event (defined by CARB as: “The mileage accrued in support of an emergency event does not count towards the usage limits of the low-use exemption. Emergency events include wild fires, floods, and other natural disasters where the vehicle was dispatched by a local, state, or federal agency.”) See: www.arb.ca.gov/msprog/onrdiesel/documents/faqLowuse.pdf
- Low mileage work trucks (labeled CT or WT and defined in the regulation) have reporting requirements and still may provide extended timelines for 2006 and older engines. Refer to the latest fact sheet dated 11/9/2015 on the CT/WT conditions that is posted on the CARB Truck Stop (e.g. if you previously reported a CT/WT as a one-truck owner then your ability to now add a filter will be restricted and if you are a fleet of 2 or more vehicles with CT/WT’s then you must meet the required percentage of 60% the fleet with PM filters) see www.arb.ca.gov/msprog/onrdiesel/documents/faqconstructiontrucks.pdf
- CT/WT Options for 1994-95 Engines: Members that operate these engines should recognize they have been living on borrowed time for the past five years and owe a debt of gratitude to WSTA for getting CARB to extend the drop dead date for these engines. The excerpt from the linked fact sheet states, “Eligible trucks that are required to be replaced by the Engine Model Year schedule must continue to stay under the annual 20,000 mile limit. For example, a heavier 1994 model year engine or a lighter 1995 model year engine vehicle may continue to operate as a Low Mileage Work Truck if a PM filter is installed and the truck operates within the mileage limit.” Members that have not installed a filter by end of this month are down to the wire and can call us for advice on their options. Members that get the filters installed should report those trucks, will be limited to 20,000 miles per year until 2020 and can call us for reporting assistance if needed.
- State and federal auditing will affect the industry as USEPA is teaming up with CARB to conduct fleet audits and enforcement. A Virginia interstate carrier recently paid over $390,000 for missing filter deadlines and failing to verify the CARB compliance of trucks they hired. Brokers should especially be focused on complying with the CARB “How to Verify” document.
How you reported in the past influences what options are available to you today so insist on clear communication from CARB or an outside expert that provides you written guidance and professional liability insurance coverage.
Opacity Testing: All diesel truck owners of two or more trucks greater than 6,000 lbs GVWR must have the opacity test or state Smog Check inspection performed to cover the December 31 compliance deadline. Make sure you have an opacity test result for each truck and CleanFleets performs this testing should it not be completed yet during 2015.
CleanFleets has already assisted dozens of WSTA members with these requirements.
You may email Service@CleanFleets.net with any questions related to this article or call 916-520-6040 Ext 102.