California trucking regulation flies under radar as first deadline looms

California is getting ready to implement another environmentally focused truck regulation, but the biggest problem with it at this point may be that plenty of affected truckers don’t appear to know about it. 

The rule is called the Clean Truck Check (CTC), and according to a fact sheet from the California Air Resources Board (CARB), it is the rechristening of what had been known as the Heavy-Duty Inspection and Maintenance regulation. One significant difference, however, is that it applies to all trucks that ever operate in California, not just those based in the state. 

CTC was first approved in 2021. 

The most pressing deadline in the program is that trucks must be signed up with a state registry for CTC by Dec. 31.

Corinna Peterson of the transportation segment of compliance consultancy J. J. Keller & Associates said when her team talks to clients about California issues, “people are more concerned about the zero-emission vehicle program that’s rolling out,” a reference to the Advanced Clean Fleets (ACF) rule that is taking several significant steps forward in 2024.

“But they don’t realize that is down that road, that it’s not imminent,” Peterson said, referring to the fact that few actions have to be taken in 2024 for compliance with the ACF rule. “They don’t realize that these January 1 CTC deadlines are coming up in a few weeks and that it applies to them as well. And this is something they need to worry about right now.”

Michael Tunnell, a senior director of energy and environmental affairs at the American Trucking Associations who has a particular focus on California, echoed that view on preparedness.

“I am hearing of people just learning about this program,” he said. CARB has taken several steps to alert the industry about CTC, he said: “They’ve done a lot of outreach on this.” (CARB recently announced another informational webinar on the regulation).

But he conceded that “the industry is so broad and diverse. It’s just hard to get the word out.”

Under the CTC, registration must be completed by Dec. 31, along with payment of a $30 fee.

Vehicles that fall under the rule’s mandates are those with a gross vehicle weight rating of more than 14,000 pounds.

CARB, in its fact sheet about the program, said the CTC was “analogous” to the state’s Smog Check program for light-duty vehicles.

“These testing requirements help ensure that heavy-duty vehicles operating in California remain equipped with properly functioning emissions controls, and when malfunctioning, that these systems get repaired in a timely manner,” CARB said.

Tunnell said the test will reveal one key metric: whether a truck’s malfunction indicator light is on, signaling issues with the vehicle’s emissions.

Some of the program already is in place, beyond the registration mandate. CARB said that at the start of 2023 it implemented “roadside emissions monitoring equipment” that could detect vehicles with particularly high emissions. If a vehicle is identified through that system, it gets a Notice to Submit to Testing, which comes with a 30-day window to get fully inspected and come into compliance.

Tunnell said the CTC is “not as onerous” as other CARB regulations that have become the industry focus through much of 2023, likely ramping up in 2024. “It depends on what you compare it to, like going out and buying an electric truck,” he said.

Tunnell said all trucks from the 2013 model year onward will have the necessary onboard diagnostics. Trucks without it prior to that model year will probably need to continue the so-called “smoke testing” under the earlier regulation.

But “if you’re running long haul, you’re probably not running an old beat-up truck,” Tunnell said. Only a “fairly small percentage” operating in California might find themselves running into continued smoke testing to meet the mandates rather than the download from the onboard diagnostics.

For most trucks, the process needed for compliance will amount to a simple twice-a-year download of data from onboard diagnostics. “Over-the-road fleets will be able to just have their telematics provider pull the data from the truck and transmit it to CARB,” Tunnell said. “So it really doesn’t matter where that truck is. [Data] can just be sent to CARB when it’s due, and that’s great.”

Peterson said that while all vehicles that travel in California would need to be registered with the state’s system and begin reporting next July, a larger fleet might choose not to register older models that don’t have the onboard diagnostics that make reporting easy. They could register vehicles that are technologically advanced and “use only those vehicles when they have operations in California,” she said.

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