Your On-Road Checklist
We reiterate here that this is a DIESEL Regulation. All Non-Diesel vehicles are currently exempt from regulation requirements.
The regulation exempts non-diesel trucks and trucks less than 14,000 lb. GVWR. Light Duty Diesel Trucks are classified as those between 14,001 and 26,000 lb. GVWR, and Heavier Diesel trucks are classified as those over 26,001 lb. GVWR.
LIGHT DUTY TRUCKS
No reporting required, but starting January 1, 2020 and each year thereafter, DMV is cross-checking with CARB for vehicle compliance. Unfortunately, DMV uses the vehicle model year while CARB uses the engine model year. These are NOT always the same, and now the assumption is that the engine is 1 year older than the vehicle model year. Of course, confusion abounds at registration renewal time. In light of this the chart below is available to assist in determining compliance and requirements for light duty and heavy duty vehicles.
Although we have published the vehicle compliance chart in various UCON magazine articles, we continue to include it here as a courtesy to truck owners. Use it as a compliance planning reference and contact UCON if you have questions or need assistance.
We have repeatedly criticized the CARB approach concerning pre-2010 Light-Duty Vehicle (14001-26000 lb. GVWR) compliance. Unless a mileage or other exemption is claimed, these vehicles are not required to be reported. They follow the engine model year schedule and phase out between now and 2023, depending upon engine model year.
Now that DMV verification begins in Jan. 2020, all the unreported Light-Duty vehicles will be subject to verification upon registration renewal attempts. They will not appear in the CARB database, and therefore, will be denied registration until the fleet owner can prove compliance. Add these vehicles to your CARB truck account now to avoid such issues.
If using the Engine Model Year Schedule, note the compliance chart above. If your filtered vehicle has an engine 1999 or older, retirement date is Jan. 1, 2020. The filters with older technology must phase out per the compliance chart. For example, a vehicle with a 2009 filtered engine is good only until Jan. 1, 2023, despite the filtering. The older technology did not reduce NOx emissions to the degree currently required. 2010 or newer engines are currently compliant, and nothing need be done to those.
ELECTRIFICATION IS ON THE HORIZON
CARB is attempting to electrify the California Truck Fleet within the next 10-20 years. Incentives are available for some electric vehicles now, and the plan appears to be developing at a rapid pace. However, the creation of, and incentives for, charging stations and associated infrastructure is woefully lagging. Until that aspect of the overall CARB plan is resolved, we don't see full-scale electrification as a viable option for most construction fleets. Expect to see electrification first in distribution center fleets such as Amazon, UPS, and perhaps CALTrans and other Public transportation facilities. Construction has many separate practical issues which will take time (and of course money) to resolve.
REPORT LOW USE MILEAGE
The annual low use exemption has been reduced from 5000 to 1000 annual miles as of Jan. 1, 2019. (Think water trucks, small dumps, and any other trucks used primarily on site at your projects, as well as normal trucking operations). No filtering of any of these vehicles is required, but mileage reporting IS required annually, by January 31. Odometer Photos will be required.
Annual smoke testing violations remain the most enforced (and penalized) portions of the Truck & Bus regulation. Therefore, do not neglect your annual smoke testing and recordkeeping requirements. A list of vendors can be found on the CARB TRUCRS web site. A recordkeeping spreadsheet is also available online.