CARB Issued An “Enforcement Notice” Regarding ACF

As 2023 came to a close, the California Air Resources Board (CARB) issued an important notice regarding the Advanced Clean Fleets (ACF) regulation. In their December 28, 2023 “Enforcement Notice”, CARB indicated that they will “not take enforcement action as to the drayage or high priority fleet reporting requirements or registration prohibitions until U.S. EPA grants a preemption waiver applicable to those regulatory provisions or determines a waiver is not necessary.” Of utmost importance to public agency fleets, CARB specifically noted that for State and local government fleets: “CARB is not required to request a waiver for the Regulation pursuant to section 209 of the federal Clean Air Act to enforce as to State and local fleets. CARB will fully enforce all requirements including reporting and the ZEV purchasing requirements or the option to comply with the ZEV Milestone Option beginning January 1, 2024.”

California public agencies are still subject to both the reporting and zero-emission vehicle (ZEV) transition requirements included in the Advanced Clean Fleets regulation.

Public Fleets Must Submit Initial Compliance Reports By April 1, 2024

Per the regulation, California public agencies are required to file their initial compliance report no later than April 1, 2024. This report includes requirements for providing detailed information on the agency’s vehicle fleet, including details on each vehicle (year, make, model, GVWR, purchase dates, odometer readings, etc.), planned removals or additions, and the agency’s selection of compliance option (Default vs. Milestone Option).

TerraVerde Energy Can Help You Develop Your Compliance Strategy

TerraVerde Energy stands ready to provide your team with a clear, actionable assessment of your options, costs, challenges, and opportunities, enabling your team to take an intelligent, risk-mitigated approach to complying with the ACF regulation. We can support your team in meeting the April 1, 2024 deadline in submitting your compliance report to CARB, while also identifying key elements to your compliance strategy, including:

  • Comparison of compliance options
  • Evaluation of exemption opportunities
  • Forecast of ZEV purchase requirements
  • Analysis of charging / infrastructure requirements
  • Identification of incentive programs and funding sources
  • Total cost of ownership analysis

Contact David Burdick (david@terraverde.energy) today to discuss your ACF compliance planning needs.