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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