The California Air Resources Board (CARB) has introduced the new Advanced Clean Fleet (ACF) Regulation, with a mission to expedite the transition to zero-emission vehicles (ZEVs) across the state. This regulation affects vehicles with a gross weight rating (GWR) greater than 8,500 pounds which includes some commonly used pickup trucks such as Chevrolet Silverado/GMC Sierra 2500, Ford F-250 Ram 2500 and other models of similar or greater weight.  There are some vehicles that are exempt from this regulation such as historical vehicles, dedicated snow removal vehicles, two-engine vehicles, and heavy cranes. This article tries to give a simple and brief overview of the regulation with exemptions and extensions.

Who is Affected: The ACF Regulation applies to growers with either $50 million or more in gross annual revenue or owning, operating, or controlling 50 or more vehicles over 8,500 lbs. Hence, many growing operations in the region will fall under the regulation which classifies such growers as “High Priority Fleet”. Growers who fall under this category will need to start complying with the regulation in the upcoming year. Additionally, entities that are engaged in drayage (freight hauling) operations at seaports and railyards, as well as fleets owned by State, Local, and Federal government agencies are also affected by this regulation.

Compliance Requirements for the Growers:

a)       The first part of the regulation is submitting a compliance report which includes information about the ownership and of each vehicle in the fleet. The first compliance report needs to be submitted through the Truck Regulation Upload, Compliance, and Reporting System (TRUCRS) by February 1, 2024, and subsequently it should be uploaded each year until 2045. The report should contain information about

• Fleet ownership details
• Details about each vehicle in the fleet such as VIN, make, model, weight, etc.
• Selection of ZEV transition option (discussed below).

b)      The second part of compliance is choosing a pathway to transition to zero-emission fleets. There are two possible pathways:

1.  Model Year Schedule Option:

• Starting January 2024, any new vehicles with a gross weight over 8,500 lbs. (eg.  Ford F-250, Ram 2500) must be a ZEV.
• However, if the new gasoline/diesel-powered were ordered for purchase before October 1, 2023, can be added to the fleet.
• Further, existing gasoline/diesel vehicles must be removed from the fleet when mileage exceeds 800,000 miles or when it exceeds a lifespan of 18 years.
  2. ZEV Milestones Option:

This option allows fleet owners to gradually introduce ZEVs into their fleets between 2025 and 2042, depending on the type of vehicle and its usage. Under this option, the entire fleet is categorized into three vehicle groups:

• Group 1: Includes box trucks such as refrigerated vans and trucks, vans, buses with two axles, yard tractors, light-duty package delivery vehicles (means a vehicle with a gross weight equal to or less than 8,500 lbs. with equal to or greater than 100 cubic feet of cargo-carrying volume).
• Group 2: Includes work trucks, day cab tractors (on-road tractor without a berth designed for resting or sleeping), pickup trucks, buses with three axles.
• Group 3: Sleeper cab tractors (a tractor with a berth designed for resting or sleeping at the back of the cab) and specialty vehicles.

Each group of vehicles must transition to ZEV by the dates and milestones indicated in the table below.

Here's the table that shows ZEV Fleet Milestones that a grower must achieve by group and year.

Here is an example calculation for a fleet for the calendar year 2030: Let's say a fleet has 100 Group 1 vehicles, 50 Group 2 vehicles, and 30 Group 3 vehicles. By 2030, the fleet must have 25% ZEVs for Group 1, 25% for Group 2, and 10% for Group 3 (from the above table). Number of ZEVs required would be as follows:

Group 1: 100 vehicles x 25% = 25 ZEVs

Group 2: 50 vehicles x 25% = 12.5 ZEVs

Group 3: 30 vehicles x 10% = 3 ZEVs

So, the total ZEV Fleet Milestone for that year is 40.5 ZEVs, which rounds up to 41 ZEVs needed.

A crucial point to keep in mind is that the ZEVs do not need to be in a particular group (1,2,3).  It is the total number ZEVs purchased that CARB is going to consider for compliance.  As long as the ZEVs added have a gross vehicle weight rating of greater than 8,500 lbs., it can count towards compliance regardless of the three groups. Thus, a fleet owner can use any combination of ZEVs from the three groups to comply. For more information, please visit Advanced Clean Fleets Regulation Zev Milestone Option

b)      Exemptions and Extensions: Presently the number of models of ZEVs that are suitable for on-farm use is limited and the supply of these types of vehicles has not ramped up yet. Also, it would take time and significant investment before there is a substantial charging infrastructure in place to support a fleet of ZEV. Fortunately, there are exemptions and extensions for specific circumstances. For example, if you have an old vehicle that is rarely used (less than 1,000 miles a year), you might not have to get rid of it. And if you can't find an electric replacement for your aging vehicle, you can ask for permission to buy a similar non-ZEV. If setting up charging stations is going to delay the transition to ZEV, you can also ask for more time. The same goes for delays in purchasing new electric vehicles due to circumstances beyond your control, such as a shortfall in supply. If you can't find an electric replacement, you might be able to buy regular gasoline or diesel engine vehicle.

To apply for exemptions or extensions, growers must email the supporting documents as evidence for the exemption or extension to TRUCRS@arb.ca.gov.

Here's an example situation where one could apply for an extension due to a delay in the electric vehicle delivery. If you ordered a ZEV at least one year before the compliance date, but the delivery of the vehicle was delayed, you can keep using your old vehicle until the new ZEV arrives by qualifying for an extension. The fleet owner must email following information to TRUCRS@arb.ca.gov during the annual reporting period:

• VIN of the combustion engine vehicle for which the extension is being requested.
• A written, signed, and dated legally binding purchase document that provides information about the owner's commitment to purchase the ZEV, date of the purchase, and that the purchase is for immediate delivery to the owner.

c)       Enforcement and Penalties

• Penalties may be imposed on individuals or entities failing to comply with the Advanced clean fleet requirements, including submitting false information.
• Penalties also apply for missing reporting deadlines, beginning January 1, 2025.
• CARB agents have the right to verify compliance records through inspections.

Concluding Remarks

The ACF Regulation marks a substantial shift towards zero-emission vehicles in California. For growers, staying in the loop, submitting compliance reports on time, and figuring out the best path for your fleet is key. Following these rules isn't just about compliance; it's a step towards a greener, more sustainable future for the Salinas Valley and beyond. Growers with hauling operations or High Priority Fleets need to be aware of the compliance requirements and available options.

Navigating this new regulation can be a bit of a puzzle. At first glance, it seems strict and challenging, especially for growers being asked to electrify commonly used pickup trucks starting next year. However, there's a silver lining – plenty of exemptions and extensions exist for growers to meet the electric vehicle replacement requirements over a longer period than is indicated in the timetable. Still, it's no walk in the park; it'll demand a chunk of your time and effort, thanks to the paperwork, monitoring, and reporting that comes with it.

The primary goal of this article is to connect with growers, sparking a conversation about this regulation. We want to field your questions, uncover the main obstacles you might face in compliance, and, just like UCCE did with the Ag Order on Water Restrictions, convey these challenges and feedback to the regulatory authorities Our goal is to ensure your voice is recognized in this ever-changing landscape, reassuring you that, as always, UCCE is here to provide any help or assistance you may need.