According to the California Air Resources Board (“CARB”), there are roughly 1.8 million Class 2b-8 vehicles operating on California roads. Today, approximately 2,000 of those are zero-emission vehicle (“ZEVs”), or roughly 0.1% of the 1.8 million medium and heavy duty (“MHD”) fleet. CARB’s new Advanced Clean Fleet (ACF) regulation (“Final Order”) – adopted by the Board on the 28th of April – is focused on rapidly growing that 0.1 percent to 30 percent ZEVs, and it hopes to achieve that, in part, by including light-duty (Class 1-2a) package delivery vehicles as well. Between medium, heavy and light-duty vehicles, CARB estimates that ACF applies to just over a half million vehicles.

Which Fleets & Vehicles Have To Comply With ACF

The ACF regulation requires “High Priority…” and “State and Local Agency…” fleets to begin converting on-road[1] vehicles with a GVWR of more than 8,500 lbs. to zero-emission as soon as 2024. The requirement applies to portions of vehicle purchases, as the fleet owner decides to buy new vehicles.

CARB defines High Priority as light-duty[2] package delivery vehicles, fleets that generate $50 million or more in total gross annual revenues and, fleets with 50 or more vehicles[3].

For state and local agencies, CARB states that ACF, “…applies to any state or local government agency with jurisdiction in California that owns, leases, or operates one or more vehicles…that have a gross vehicle weight rating (GVWR) greater than 8,500 lbs…”. This doesn’t mean that light-duty vehicles aren’t relevant to your compliance efforts.

When it comes to exemptions that you may need to request from CARB, for MHD vehicles that cannot demonstrably be accommodated by available ZEVs (e.g., the “Daily Use Exemption”), CARB requires that at least ten percent of your fleet is ZEV before making such requests. This is where light-duty ZEVs come in. If ten light-duty pickups in a hundred-vehicle fleet are ZEV, then you would meet the precondition for submitting a Daily Use Exemption request on a medium or heavy-duty vehicle.

Furthermore, if one opts for the alternative Milestone Option, then the regulations require that a certain percentage of your vehicles are ZEV by certain years, and within certain CARB-defined vehicle-type categories, regardless of their rated weight.

Common Questions

Designated Low-Population Counties: There are a few other ‘applicability’ questions that come up. One of which is, “If I’m in a CARB-designated low-population county, what are my obligations?” The short answer is, the same as everybody else, except for 2024 purchase requirements. You still need to meet all reporting and recordkeeping requirements, and you still need to submit a “report” by April of 2024. Detailed requirements for the report are clearly specified in Attachment A-1 of the Final Order. This is the report that sets the baseline from which CARB will monitor agency compliance.

Vehicle Retirement Requirements: Fleet operators often want to know when CARB might require the retirement (and ZEV-replacement) of an existing vehicle. The answer is, at the end of the vehicle’s “useful life.” In CARB’s words[4], “The ACF regulation…guarantees a [vehicle’s] full useful life.” The ACF allows fleets to continue operating existing conventionally fueled trucks until they’re 18 years old or, until the odometer reaches 800,000 miles. If your truck reaches 800,000 miles before it’s 13 years old, you can continue to operate it through its 12th year.

Defining a “State or Local Agency”: And finally, there’s one of the toughest questions to answer. “Does my organization meet the definition of a state or local agency?”.  Of course, we all want an easy, clear answer to this question. Unfortunately, there isn’t one. As such, you’ll need to consult with your legal expert for guidance. In the meantime, here are several excerpts from federal and state law that address similar definitions.

According to 5 U.S. Code § 1501 – Definitions (2), “State or local agency” means, “…municipality, or other political subdivision of a State, or an agency or department thereof…”

According to California Code, Public Contract Code – PCC § 2051(g)

(1) “State agency” means any department, division, board, bureau, commission, or agency of the executive branch of government.

(2) “Local agency” means a county or city, whether general law or chartered, city and county, school district, or other district.

(3) “District” means an agency of the state, formed pursuant to general law or special act, for the local performance of governmental or proprietary functions within limited boundaries.

TerraVerde Can Help

TerraVerde Energy is working with a variety of organizations across California to provide critical consulting services as agencies and districts that are subject to the Advanced Clean Fleet regulation establish plans to ensure a smooth, well-managed and intelligent transition to a zero-emission transportation fleet.  Contact Phil Villagomez at TerraVerde today to schedule a free overview of the approved regulation and an overview of the services that TerraVerde is offering to those seeking assistance in complying with the Advanced Clean Fleet regulation.



[1] and off-road yard tractors

[2] Weighing 8,500 lbs. or less

[3] Final Regulation Order, Attachment A-1: High Priority and Federal Fleet Requirements



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