Key Takeaways

• The proposed amendments incorporate input received in public feedback from March 2024 workshop and comment period and announce some new amendments pertaining to Daily Usage Exemptions and the Definition of a Traditional Utility-Specialized Vehicle.
• The Daily Usage Exemption for Public Agency Utilities (PAUs) has been relaxed to offer more flexibility.
• The Traditional Utility Specialized Vehicles category has been proposed to expand to Class 3 or higher.
• Stakeholders’ feedback also indicate inclination towards relaxation of the end of life limit for BEVs.

California Air Resources Board (CARB) convened a workshop on October 3rd, 2024, to discuss proposed amendments to the Advanced Clean Fleets (ACF) regulation. These amendments were primarily driven by the requirements outlined in Assembly Bill (AB) 1594, though the scope of changes extended somewhat beyond the bill’s specific mandates.

In March 2024, CARB acquired information on several areas: clarification on the definition of utility-specialized vehicles, methods for determining their end-of-use life, and the calculation of daily usage energy needs.

Based on this, the following proposals are introduced at the second workshop on 3rd October 2024:

• The Daily Use Exemption, which permits ICE vehicle purchases when BEV battery capacity cannot meet operational requirements, now requires the fleet to maintain at least 10% Zero-Emission Vehicles (ZEVs)/Near-Zero-Emission Vehicles (NZEVs).
• The Daily Use Exemption is invalid if comparable NZEVs, Fuel-Cell Electric Vehicles (FCEVs), or Battery Electric Vehicles (BEVs) meeting minimum battery requirements are available (150kWh for Class 2b-3, 325kWh for Class 4-6, 450kWh for Class 7-8, 1000kWh for tractors/three-axle buses).
• For PAU operations, Daily Usage Exemption calculations no longer exclude the three highest usage days from consideration.
• ZEV Purchase and Daily Usage Exemption Eligibility Requirements have three proposed categories: For high priority and federal fleets ICE vehicles, either the model year is 16 years old or the vehicle has exceeded 700,000 miles (whichever comes first); for State and Local Government Fleets, the model year must be 13 years old. There is also a ZEV Milestones Option, where fleet owners must demonstrate that reaching their next ZEV Fleet Milestone is impossible without exemptions, requiring them to obtain exemptions for all remaining ICE vehicles in their California fleet.
• The proposed amendment to the criteria for Traditional Utility Specialized Vehicles under AB 1594 now includes vehicles that must be Class 3 or higher, operated by Public Agency Utilities (PAUs) more than 50% of the time, not primarily designed for cargo or passengers, and equipped with a manufacturer-stated towing capacity and either PTO or 4/6-wheel drive. In contrast, these vehicles were previously limited to those equipped with PTO systems and fell within weight classes 4 to 8 based on their intended work.

Overall, the proposed amendments received further input from different stakeholders in three broader areas discussed below.

Clean Fleet Flexibility: Daily Usage Exemption calculations

Multiple utility organizations—the California Municipal Utilities Association (CMUA), Joint POUs (California Municipal Utilities Association, Northern California Power Agency, and Southern California Public Power Authority), the Association of California Water Agencies (ACWA), and Metropolitan Water District of Southern California (Metropolitan)—aligned on two key points:

• Allow comprehensive fleet usage data rather than limiting it to Battery Electric Vehicle (BEV) data, especially when BEV alternatives don’t exist.
• Include peak usage days in calculations to accurately reflect emergency response capabilities and extreme operational scenarios.

The California Electric Transportation Coalition (CalETC) also suggested including all usage data (peak days) in assessments.

The California Council for Environmental and Economic Balance (CCEEB) advocated for uniform Daily Use Exemption methodology across all fleet types, arguing that different treatment for utility vehicles creates unnecessary market disruption.

Push for Flexible End-of-Life Criteria for Utility Vehicles

CCEEB, Metropolitan, and CalETC advocated a flexible approach to determining the end-of-life for utility fleet vehicles, moving beyond the fixed model year or the 13-year threshold established by ACF regulation.

Metropolitan and CMUA, in their respective feedback, provided several inputs for the PAU vehicle retirement procedure, which determines a vehicle’s end of useful life. The suggested criteria included factors such as usage (stationary hours or mileage), vehicle condition and reliability, maintenance, availability and affordability, safety, and criticality for mission tasks, or through a retirement policy established and approved by the utility’s Governing Board.

CASA and ACWA recommended that wastewater treatment plants track vehicle metrics like model, miles, and operational hours. They further advocate for end-of-life decisions based on vehicle condition and maintenance costs while emphasizing flexibility during emergencies.

Redefining Specialized Vehicles

Multiple organizations raised concerns about the limitations of the initial proposed “Traditional Utility Specialized Vehicle” definition.

CalETC proposes expanding utility-specialized vehicle definitions to cover Class 3-8 equipment with off-highway or vocational capabilities, such as bucket trucks and digger derricks.

CMUA challenges the requirement for off-highway driving capability, arguing that it’s unnecessary for many specialized utility vehicles. ACWA proposes a broader definition that would include any vehicle exceeding 10,000 pounds GVWR with specific capabilities such as PTO systems or towing capacity, regardless of off-highway capabilities.

Collectively, these organizations urged CARB to revise the definition to reflect better the diverse operational requirements and functionality of California’s utility fleets.

Next steps

• For the ACF regulation, CARB will host a public online webinar on 1st November 2024 to discuss Exemptions and Extensions under the ACF regulation. CARB invites stakeholders to submit their questions by 22nd October 2024, which will be addressed during the webinar.
• For AB 1594, public comments are due and expected to be submitted to the CARB for consideration in early 2025.