Thursday, July 18, 2013

Order Early, Order Often

CARB Clarifies the 4-Month Early Order Provision for On-Road Truck and Bus Rule Compliance

Once and a while, most taxpayers will agree that the government “gets it right”…sometimes. With such a small consensus on actions of late that would qualify for that designation, it is refreshing to see the great state of California reminding people about a little known and often misunderstood provision within the On-Road Truck and Bus Rule that they “got right” so to speak.
In the era of cheaper, faster and NOW! We find ourselves becoming more and more intolerant of delayed gratification. While technology has made things move at the speed of light, it has also complicated matters for some industries (or generations) that are used to a snail’s pace. When it comes to new diesel engine or retrofit technology CARB did in fact recognize the need to give considerations for these highly technological pieces of custom equipment when they are being ordered directly from the factory. Many fleets have experienced delays from original equipment manufacturers when ordering vehicles with unique specifications, or when ordering retrofits at the same time as everyone else. Needless to say, there is only so much capacity to go around.
Because of these issues, CARB included into the regulation the so-called “4 month early Order Provision” or aptly named, Compliance Extensions for Emissions Control Device Manufacturer Delays 2025(p)(8)(A-E). Although it says “Emission Control Device Manufacturers”, it also applies to new truck or vehicle purchases. So if a fleet places an order by August 31 of the year preceding compliance, and has a bona fide order for the equipment, then if the equipment does not deliver until into the compliance year, they will not be cited. This DOES NOT delay the rule, but merely provides a small amount of flexibility for fleets who were thinking ahead and ordering equipment for compliance well before the deadlines.
If a fleet waits until September 2nd to order the equipment, the extension will not apply. And it will definitely not apply to any equipment that is ordered in December for January compliance. Typical build time for custom spec trucks is 90 to 120 days at a minimum, so the 4 month provision will allow ample time to get the truck in the fleet or at least demonstrate a commitment to achieving compliance.  CARB does not want to punish fleets who are making the effort to comply, but, they want to see a legitimate effort being made. Check out the advisory from CARB below and happy trucking!

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