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CTA/Lawson Lawsuit: 2014 Truck & Bus Regulation Amendments Affected


   


Due to the court’s ruling in the CTA/Lawson Lawsuit, flexibility options that could be claimed before the Lawson Rock & Oil, Inc. v. CARB decision became final in 2018 will not be available in 2019 or may have different eligibility criteria. Fact sheets and regulatory documents are being updated, and will be available in December 2018 at: www.arb.ca.gov/dieseltruck.  The compliance requirements for options that remain available in 2019 and future compliance years are as follows with the following limitations, modifications or requirements.


Low-Use Exemption

  • The mileage limit is 1,000 miles per year in California.
  • Vehicles that are designed to power other equipment that can only be used while stationary must be operated less than 100 hours per year and those hours must be reported every compliance year.

Low Mileage Construction Truck Option

  • The Low Mileage Construction Truck Option was previously known as the Low Mileage Work Truck Option, which had expanded eligibility criteria that is no longer available.
  • A PM filter must have been installed by 2018 for the vehicle to continue to operate under Low Mileage Construction Truck Option.
  • If the fleet owner has been issued a valid Contractor’s License, then all vehicle body types are eligible.
  • Low-mileage construction trucks must operate less than 15,000 miles per year; however, dump trucks can operate up to 20,000 per year.
  • Lighter vehicles (14,001 to 26,000 GVWR) can no longer claim this flexibility option.

Agricultural Vehicle Extension for Replacement Vehicles, not Initial Opt In

  • Agricultural vehicles that reported for this flexibility option cannot operate more than 10,000 miles per year until January 1, 2023.

NOx Exempt Area Extension

  • The counties that were added to the list of NOx Exempt Areas under the 2014 amendments have been removed.
  • A PM filter must be installed to continue to claim the NOx Exempt Area Extension.
  • To meet the 2019 compliance requirement, vehicles without a PM Filter must meet the upgrade requirement based on the Engine Model Year schedule or claim a different flexibility option for which they are eligible.

Retrofit by 2014 and No Replacement Until 2023 Extension

  • Lighter vehicles with pre-2000 model year engines and heavier vehicles with pre-1996 model year engines that were eligible for this option must meet the 2010 or newer model year engine compliance requirement by January 1, 2020.
  • After the 2020 compliance year, vehicles with the remaining engine model years must meet the replacement requirement in the Engine Model Year schedule.
  • Notices are being sent to affected fleets to inform them of the change to their compliance deadline.

Options No Longer Available

  • Heavy Cranes: These vehicles must meet the same upgrade requirements as all other vehicles subject to the Truck and Bus regulation.
  • Smoothing out Compliance Requirements: There is no longer a limit to the number of vehicles that must meet the replacement requirement in the Engine Model Year schedule.
  • Cattle Livestock Trucks: These vehicles are no longer considered eligible to use the Specialty Agricultural Extension.
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