This does not mean that truckers should sit and wait!
The amendments that the CARB board approved in December 2010 are winding their way through the construction industry concessions (specifically dump trucks) and the legal process required of all regulations under the state Administrative Procedures Act. As this legal process continues, we need to be aware that the existing law requires affected truck owners to collect truck and engine data and prepare to report if they are planning to use any extensions or credits under the Rule.
This month I am focusing on what information to collect and how to report it when it is due (January 31, 2012 for most fleets).
You should be able to access the following required information in your business records and by performing a physical inspection of your vehicle:
Vehicle Details:
Vehicle type (e.g. typically the body type and it behooves owners to use the same nomenclature as that in the “lower-use construction truck” definition adopted by CARB; see below)
- Vehicle identification number
- Vehicle manufacturer
- Vehicle model
- Gross vehicle weight rating
- Vehicle model year
- License plate number
- The state where the vehicle is or was registered and type of registration plate
- Whether the vehicle will be designated as a low-use vehicle, and if so:
- Whether the low-use status is based on mileage or hours of operation,
- Whether the vehicle has PTO for performing work in stationary mode,
- Whether the vehicle is used as an emergency support vehicle, which is defined as, Emergency Support Vehicle: means a vehicle, other than an authorized emergency vehicle that has been dispatched by a local, state, or federal agency that is used to transport services or supplies in connection with an emergency operation.
- Fuel type
- Whether the fleet contains more than three vehicles subject to the regulation with a GVWR greater than 14,000 lbs
Engine Details:
- Engine manufacturer
- Engine model
- Engine family (except if reporting information about vehicles in the 2006 baseline fleet that are no longer in the fleet)
- Engine serial number
- Engine model year
- Whether the engine meets an on-road or off-road emissions standard
- Whether the engine is used to propel the vehicle or to operate auxiliary equipment
Small Fleet Reporting:
- For small fleets planning to use any time extensions under the rule, the fleet owner must provide the information about all vehicles in the fleet including the vehicle and engine information above. This reporting is mandatory for small fleets expecting to delay the PM requirements and the 2010 engine or equivalent emissions requirement until January 1, 2020.
- Small fleets with vehicles with 1996-1999 model year engines that do not meet the requirement to have a diesel particulate filter installed (i.e. “PM BACT”) by January 1, 2012. They must comply with the reporting requirements by January 31, 2012 to utilize the option to delay emissions upgrades until 2013 or 2015 if the truck meets the “lower-use construction truck” definition.
- Small fleets with vehicles with 2000-2004 model year engines that do not meet PM BACT by January 1, 2013 must comply with the reporting requirements by January 31, 2013 to utilize the option to extend compliance dates.
- Small fleets with engines older than 1995 or 2005-2006 that are using any delay provision must comply with the reporting and recordkeeping requirements by January 1, 2014.
Large Fleets (4 or more) Reporting
An owner of four or more diesel trucks greater than 14,000 lbs GVWR does not qualify as a small fleet. For these large fleets, if they plan to use the “phase-in” allowed under the Rule or any credits or time extensions under the rule, the fleet owner must report by January 31, 2012.
Fleets That Have Downsized Must Report if They Want Credit
Fleets requesting credits allowed for having fewer trucks now than on October 1, 2006 must report the following:
- The information for all vehicles in the 2006 baseline fleet. Information about vehicles registered on October 1, 2006 that are no longer in the fleet may exclude the engine and any previously installed filters information.
- Information about trucks certified as non-operational with the California Department of Motor Vehicles (DMV) equivalent agency in another state.
- The emissions standard to which the engine was certified if lower than required for the engine model year.
- The percentage reduction in fleet size from the baseline to the compliance year can be applied to the “phase-in” as further defined in the Rule language at http://www.arb.ca.gov/msprog/onrdiesel/onrdiesel.htm
Lower-use Construction Trucks
Below is the language adopted by the CARB Board on December 17, 2010.
“Low-Mileage Construction Truck” means:
- a truck that travels less than 15,000 miles per year, and
- is a cement mixer truck,
- a concrete pump truck,
- water tank truck,
- a single engine mobile crane with a capacity greater than 30 tons, or
- a dump truck designed to transport construction materials such as dirt, asphalt, rock or construction debris including a transfer truck, or a tractor trailer combination used exclusively to pull bottom dump, end dump or side dump trailers
“Phase-out” for Low-Mileage Construction Trucks
The owner of a small or larger fleet that meets all requirements still has to report to CARB, but is only required to “phase-out” one-third of its construction trucks by 2014 (prior to December 2010, ALL small fleets had to put a filter on their truck(s) by December 31, 201). Now, two-thirds of a “lower-use construction truck” fleet can remain without a filter until the beginning of 2015, and the final third retrofitted or retired by 2016, provided they comply with the reporting and mileage requirements. These trucks do not count toward the baseline calculations for the purpose of non-construction trucks in a fleet.
Labeling Requirements for Low-Mileage Construction Trucks
By January 31, 2012, fleet owners must permanently affix or paint an identification label on each low-mileage construction truck that utilizes the delay provision as follows:
- The letters CT shall be white block lettering on a black background. Both letters shall be at least three inches high on a five by eight inch background.
- The label shall be located on the left and right door of the vehicle and be in clear view at all times.
Conclusion
While the legal process moves forward, I am recommending that dump truckers prepare for the requirements by taking the steps outlined in this article.
Early attention to these items will pay dividends as you evaluate your trucks. CleanFleets.net is available immediately to begin the planning and reporting process as we have for more than 150 fleets over the past ten years.
Please contact me at (916) 718-7050 with any questions related to this article.
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