Monday, July 7, 2014

CARB Truck & Bus Advisory Released - PM Filters Remain a Key Strategy for Fleet Owners

Guest Contributor: Sean Edgar, Director,

On June 27, California Air Resources Board (CARB) staff issued guidance on the April 2014 amendments to the Truck and Bus Regulation.  Below is a summary of the major provisions.

The most important step for fleet owners to take is to catch up if they are behind on filter installations and to update their CARB TRUCRS account as soon as possible to reflect their compliance actions.

What We Know:
The following summarizes the Advisory that is posted on the CARB website.
  • Past “Good Faith Effort” (GFE) Truck Owners: Owners that registered with CARB in late 2013 or early 2014 that ordered a PM filter retrofit must complete the action and must update their CARB registration by July 1, 2014 or face penalties (see Failure to Comply, below).
  • Future Economic Hardship Extension: There will be a narrow window for small fleets to apply for some additional delay, however it will take several more months to determine the application process.  In April, the Board directed changes to be made so that the delay could only be applied for by owners that are truly financially unable to comply and have auditable proof that no financing options are available. The details are being revised and will be made available for public comment period before they can be finalized. If you have a filter ordered and is pending installation we highly recommend that you keep that installation date as it is speculation at this point who can or will be eligible for this provision. It appears at this stage that a high level of documentation and statements under penalty of perjury will be required to be filed with CARB.
  • Low Mileage Trucks: “Work trucks” may retroactively claim this status by reporting no later than July 31, 2014. These thresholds are up to 20,000 miles total miles on the truck per calendar year. The minimum PM filter requirement is 40% of the entire fleet by the end of 2014 so every filter that is now waiting to be installed or ordered by September 1, 2014 “counts” toward the 40% minimum.
  • “Green Zone/N0x Exempt" Areas: The good news for trucks staying exclusively in these areas is that they have enjoyed extra time while CARB modifies the regulation. What is now clear is that 25% of the fleet must have PM filters by 12/31/2014. Every filter that is now waiting to be installed or ordered by September 1, 2014 “counts” toward the 25% minimum.
  • Failure to Comply: Vehicle owners that are non-compliant or fail to complete the good faith efforts to comply with the regulation by July 1, 2014, may be subject to penalties and possible Department of Motor Vehicle (DMV) registration holds. Vehicles operating without current DMV registration are subject to enforcement actions by law enforcement which may include vehicle impoundment.
What CleanFleets is doing is:
  • Providing insured and guaranteed CARB registration services for CDTI customers,
  • Performing new registration for customers who can now opt into the categories described.
CleanFleets has already registered over 5,000 trucks with CARB and can be reached at 916-520-6040 Ext 102 or at to obtain additional information.

About Sean Edgar,

Sean Edgar has 23 years of field experience in transportation, construction and air quality projects for clients in both the public and private sectors. For the past 15 years, his consulting practice has consisted of regulatory compliance regarding transportation and air quality issues. 

Sean has established a presence at the California Air Resources Board (CARB) and is a member of CARB’s Truck Regulations Advisory Committee - authorized to train business owners about CARB rules. Over the past two years, Sean has educated more than 4,000 fleet owners in six western states and is a recognized expert regarding CARB’s on-road fleet rule implementation and technology options.

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