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What to make of California’s Advanced Clean Fleet Rule

    The California Air Resources Board (CARB) adopted another far-reaching regulation that dictates what kind of trucks and fuels can be used in California in the future. Last week’s move comes on the heels of the Advanced Clean Trucks Rule which was adopted in 2021 and mandates an increasing percentage of sales of zero emission trucks in California.   

    Taken together, these rules could be likened to a game of Jenga®. In this case, instead of a stack of wooden blocks, it is a teetering tower of rules and deadlines on the backs of manufacturers and fleets. It leans heavily on government funding and incentives, with uncertainty and assumptions of cost, projections of timing, and feasibility protruding at every level. Which block will be the one to topple the tower, or will it withstand the force of time?

    The rules are related and, according to CARB, based on the need not only to meet California’s clean air needs but also the state’s commitments to reducing greenhouse gas emissions (GHG) and tackling climate change. According to CARB the benefits far outweigh the costs, and the need is immediate.

    What does all this mean for the future of diesel and other internal combustion engines in California? Some flexibilities are provided to continue to operate or acquire a new internal combustion engine truck in hardship cases or if zero emission vehicles or infrastructure are not available at the compliance deadline. CARB indicated they will review the state of technology in 2025. The rule banning diesel and gasoline truck sales does not apply to emergency vehicles like ambulances and fire trucks.

    Starting in 2036, all new sales of medium-duty and heavy-duty trucks must be zero emissions in California; scaling up from phased-in timelines that start in 2024 and vary by the type of truck. Companies that operate 50 or more trucks or have $50 million in annual revenue will be forced to gradually convert their fleets into electric or hydrogen models. They will need to reach 100% zero-emissions by 2042, with timelines also based on the type of truck.

    The earliest requirements would be for trucks that serve the ports (drayage trucks) of Los Angeles, Long Beach, and Oakland. All of them must be converted to electric models by 2035, and new sales beginning in 2024 must be zero emissions.  

    The state requirements to switch existing truck fleets to zero emissions by 2042 would apply to “high-priority fleets,” which are owned or operated by companies with 50 or more trucks or $50 million or more in annual revenue, and to federal trucks. CARB also indicates it will begin looking at similar mandates for zero emissions vehicles (ZEV) for smaller fleets of less than 50 vehicles in the future. This is significant since, according to the American Trucking Associations, 90% of the trucking industry are fleets containing 20 or fewer vehicles.

    To say the rule was controversial would be an understatement. 

    Hundreds of testifiers and commenters have made their case to CARB’s board since last fall when the proposal was first released. Like many things in America these days, polarization ruled the day, with comments following a familiar pattern. Environmental advocates and residents around port communities or freight corridors praised the rule and wanted it to be more aggressive in timelines and phase-in. In the end, the Board responded by moving up one deadline by four years.

    Trucking user groups, local governments, and those on the receiving end of the regulation generally expressed grave concerns, and dismay that the Board had failed to consider the good-faith suggestions made during the rulemaking process. Trucking industry representatives summed it up this way:

    “The amount of chaos and dysfunction that is going to be created by this rule will be like nothing we’ve ever seen before,” said Chris Shimoda, Senior Vice President of the California Trucking Association, an industry trade group.  

    Chris Spear, President and CEO of the American Trucking Associations said this:

    “Today, an unelected Board in California voted to force trucking companies to buy zero-emission trucks. Fleets are just beginning to understand what it takes to successfully operate these trucks, but what they have learned so far is they are significantly more expensive, charging and refueling infrastructure is nonexistent, and ZEVs are not necessarily a one-for-one replacement—meaning more trucks will be needed on California roads to move the same amount of freight.

    California is setting unrealistic targets and unachievable timelines that will undoubtedly lead to higher prices for the goods and services delivered to the state and fewer options for consumers. As it becomes clear that California’s rhetoric is not being matched by technology, we hope the Board will reverse course and allow trucking companies the freedom to choose the clean technologies that work best for their operations.”

    The challenges for this shift in industrial policy to move from a fossil fuel-based transportation system to fully electrified at a state level are unprecedented. Penske Truck Leasing, a leader in the industry said this about the timelines:

    “Fleet scale (electric charging) infrastructure projects of 5+ Mega watts (MW) take 3-5 years in a best-case scenario, meaning the initial 1/1/2025 deadlines are already an impossible target for most fleets, even with a one-year implementation delay.”

    The highly respected California Council on Energy and Economic Balance (CCEEB) said:

    “It’s impacts will reach far beyond the medium and heavy-duty trucking fleets it directly regulates, requiring nothing less than a fundamental transformation of the state’s electrical, energy, and goods movement systems. Indeed, to even have a realistic chance at achieving its stated goals, the Rule would require a year-over-year expansion of statewide electrical generation, transmission, and distribution capability in the next two decades well above what the State previously has been able to achieve in even its highest single year.”

    Local governments weighed in as well which lead the League of California Cities, State Association of Counties, and California Special Districts Association to say:

    “The vehicles don’t exist, the infrastructure does not exist, grid reliability is sketchy, there’s nothing to protect public agencies from price gouging.”

    Comments filed by a leading environmental analysis firm Ramboll for the Western States Petroleum Association, found that:

    “…expanded implementation of zero-emission and low-NOX vehicles, coupled with increased introduction of renewable liquid and gaseous fuels, can deliver earlier and more cost-effective benefits than a ZEV only approach. As advanced low-emitting trucks are commercially available to deliver benefits to communities sooner, with greater certainty, multi-technology pathways can help achieve emission reductions without reliance on infrastructure and technology upgrades that will take years to resolve.”

    Among other things, some commenters noted that the success of the CARB ZEV mandate assumes:

    1. A successful tripling of the power supply in California to fully renewable resources, and
    2. The power grid will be both ready and capable of supporting a mass switch to electric power for transportation, even as blackouts and brownouts are annual occurrences today. 

    California is but one state, with a few others following. At the federal level, EPA’s initial signals in its just proposed Phase 3 Greenhouse Gas Rules are toward a technology neutral approach at the federal level with no discussions about bans or unachievable emissions standards. Instead, EPA proposed standards:

    “ not mandate the use of a specific technology, and EPA anticipates that a compliant fleet under its newly proposed standards would include a diverse range of technologies (e.g., transmission technologies, aerodynamic improvements, engine technologies, battery electric powertrains, hydrogen fuel cell powertrains, etc.). The technologies that have played a fundamental role in meeting the Phase 2 GHG standards will continue to play an important role going forward as they remain key to reducing the GHG emissions of HD vehicles powered by internal combustion engines.”

    We’re still learning about how this all fits together or doesn’t. The need and opportunity to achieve cleaner air and reduce GHG is a basic shared goal among everyone; even those with the most extreme points of view for or against either of these rules. 

    CARB’s clean fleet and clean truck mandates do ensure at least one thing - the next generation of diesel trucks and continued use of low-carbon renewable biodiesel fuels in California will be extremely important. This new generation of diesel trucks for California will be 75% cleaner starting next year (2024) and 90% cleaner than today in 2027. 

    Ensuring continued progress toward cleaner air and reducing GHG emissions rests largely on the turnover of the legacy fleet to newer generations of available and affordable diesel technology. Also, expanding use of low carbon renewable biodiesel fuels ensures continued progress in lowering GHG emissions as the zero emissions future is yet to fully materialize. Truck and engine manufacturers have stated their commitment and have some ZEV products on the street but also realize the need to serve their customers’ needs today. They recognize a lot more has to happen with infrastructure and technology in general to realize a deep penetration of ZEV technology in the trucking industry.

    Reducing carbon and other emissions in the near term in California and beyond will likely depend more on the next generation of super clean diesel trucks using blends of renewable biodiesel fuels. This will be vital to keep the economy moving with the inevitable slippage of deadlines, twists, and turns on the journey to a zero emissions future. Or in case the tower tumbles completely.