California withdrew the request for an EPA waiver of its Advanced Clean Fleets rule before the change of Administration (https://www.prepassalliance.org/california-withdraws-from-zero-emission-trucks/). As part of that ACF withdrawal, the California Air Resources Board (CARB) no longer seeks to require “high priority fleets” and operators of drayage trucks to transition to zero-emissions vehicles (ZEVs) in the short term, as well as requiring all trucks to achieve zero emissions over time (https://ww2.arb.ca.gov/our-work/programs/advanced-clean-fleets).
Now the U.S. Environmental Protection Agency is reviewing several emissions rules (https://www.prepassalliance.org/epa-announces-massive-environmental-regulation-review/), including EPA’s own Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles – Phase 3 (GHG3), labeled by many as an “EV (electric vehicle) mandate,” and California’s Advanced Clean Trucks (ACT) rule, which impacts truck dealers nationwide.
So, it has become much simpler for truckers to be environmentally legal in California? Simpler, yes. But easy? No. Even if the EPA revokes the ACT rule and revises GHG3, California has state-level emissions regulations, emissions testing and registration programs which require compliance by all trucks operating in the state.
To begin with, California has outlawed old truck engines. If a vehicle is not compliant, the California Department of Motor Vehicles (DMV) can no longer register that vehicle. Heavier vehicles (greater than 26,000 lbs GVWR) with an Engine Model Year (EMY) of 2009 or older need to be replaced or repowered to a 2010 or newer EMY (https://ww2.arb.ca.gov/truck-bus-regulation-truckstop).
Applying to all motor carriers and trucks is CARB’s Clean Truck Check (CTC) program. It has three components:
- First, CARB has stationed roadside emissions monitors to detect high-emitting trucks. Polluters are then tested by state technicians, who may require emission control repairs.
- Second, beginning February this year, all trucks operating in California, regardless of their state of registration, must file with a CARB database, called the ”Truck Regulation Upload, Compliance and Reporting System (TRUCRS)” (https://ssl.arb.ca.gov/trucrs_reporting/login.php), and pay an annual $30 compliance fee. That registration must be renewed and the fee paid each year so long as the truck continues to operate in California.
- Third, truckers are now required to conduct emissions testing twice a year and submit the results to CARB. Motor carriers can utilize a state-certified emissions tester or can have their own employees complete certification. If the truck is licensed outside of California, the testing must be conducted within 90 days of the month associated with the last number of the truck’s VIN, and every six months thereafter, as set out in this table:
| VIN# | 0 | 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 |
| Month | Oct | Nov | Dec | Jan | Feb | Mar | Apr | May | Jun | Jul |
By the way, CARB’s Clean Truck Check program also requires shippers, receivers and brokers of freight to prove that the motor carriers with whom they do business in California have registered with the CTC program.
The CARB Clean Truck Check program seeks to enforce existing state emissions standards without requiring unproven truck technology or futuristic fuels. It is in effect now and does not require a waiver from the EPA. To be “environmentally legal” in California, motor carriers must register, pay the compliance fee, and conduct periodic emissions testing.