Monday, January 18, 2016

2016 CARB Compliance Continues
CARB Rules Ratcheting Down

All California fleets with active heavy duty vehicles over 26,000 pounds GVWR must operate retrofitted or OEM emissions controlled equipment or must have registered with CARB for an exemption.  Any truck 26,000 GVWR or below equipped with a 1996 or earlier engine is also out of compliance.

This is old hat to many fleets operating in California, the on-road rules have been in effect since 2012 and still have another 7 years before all control measures are fully implemented.   There is concern within the industry that CARB is not done and many fear that strict GHG focused standards will rear their ugly head in particular sectors. While we will see what the future will hold, today, not only must heavy duty trucks meet the 100% control standards, but 53’ or greater box type trailers will need to have aero dynamic control measures installed.  In order to avoid the standards they will need to register with CARB for an exemption if they qualify.  The GHG tractor trailer regulation is the second major phase for CARB rules governing emissions from HDD vehicles. 

Many have put the trailer requirements off specifically because CARB was not enforcing the rule. Despite the fact that the standards required full compliance by 2013 for any trailer older than 2011, not a single published enforcement settlement contains violations for the rule.  2011 or newer trailers needed to be SmartWay certified as of 2010. So that is potentially 6 years of retroactive fines that may potentially be levied against fleets. Tractors also need a SmartWay certification if they are model year 2011-2013. 2010 and older tractors and trailers need to have had tires installed by 2013. Sound familiar? If not, you are not alone, very few have heard about these dates because CARB has not been enforcing the rule.

This year, the agency has made it clear that the GHG tractor trailer rule will be apriority. They will begin enforcing it now that all phase in timelines are complete for large fleets with registered small fleets needing 75% compliance if they had signed up for the phase in option.

Much to the chagrin of anyone who is just finding out about the regulation, CARB will also have the ability to issue fines retroactively.  And more than likely, many may find themselves out of compliance and not even know it. 100% of the 53’ trailer fleet is supposed to be aerodynamically equipped   or registered for an exemption of some type.  
What always comes up is the question of what specific trailers are covered. The rule only pertains to box type 53’ or longer dry or refer vans. Flatbeds, containers, 48’, anything is not a 53’ box type trailer is not covered. Refer trailers have a slightly different schedule for 2003-2009 model year trailers. Nevertheless, if it is a dry van 53’ box type trailer it is covered.  

Several exemptions exist and a fleet will need strict analysis of their tractor and trailer fleet to see if it will be applicable to vehicles.
When an exemption is chosen for an eligible tractor, it exempts the trailers it is hauling at any time from the aerodynamic standards. Both the short haul and the local haul tractor exemption provide this. The difference between the two is that on the tractor side, a short haul tractor is exempt from all requirements including tires. A local haul tractor is exempt only from aerodynamic requirements, not the tire requirements.  On the trailer side, only a local haul exemption exists, if a trailer is not being pulled by an exempted tractor, it should be registered as a local haul to be exempt from the aerodynamic requirements.

If you or someone you love is hauling a 53’ trailer, let them know it is time to install skirts or register for an exemption. They are out there, and when they find you, they will fine you.
Stay Tuned!!!