It's Time to Instill Urgency with CARB's Advanced Clean Fleets Rule

At a recent industry event, I spoke with a fleet manager who runs a national sales and service fleet with a sizable footprint — over 100 units — in California. I asked how he was approaching compliance with the Advanced Clean Fleets (ACF) rule set forth by the California Air Resources Board (CARB).

ACF applies to any vehicle doing business in California that is Class 2b (a standard cargo van) or larger.

"The electric cargo vans don't work for my duty cycles," he said. "They don't have the range."

Yeah, I responded, that's an issue with commercial EVs today. But how are you approaching compliance? "I heard the rule won't stand up in court," he said, "and what are they going to do, come after me?"

This attitude is particularly pervasive with large private sector fleets, or high-priority fleets as CARB calls them. However, avoiding the regulation altogether is not a viable option.

The rule has many facets depending on fleet size and type, with two compliance pathways. To keep it simple, we'll stick to this fleet manager's situation, which is fairly common.

For California's government and public sector fleets, the timeline set forth by ACF to acquire zero-emission vehicles (ZEVs) kicked in this year. They're knee-deep in compliance considerations — from figuring out their charging infrastructure needs to sourcing the EVs.

ACF Compliance Starts Jan. 1 for Private Fleets

Compliance for our fleet manager and other high-priority private fleets starts on Jan. 1, 2025. Choosing the ZEV Milestones path, 10% of a fleet of box trucks, cargo vans, package delivery vehicles, and yard trucks must be ZEV on that date.

Our fleet manager must have 10 electric cargo vans in operation by Jan. 1. As of this writing, that's in 184 days. Initial compliance reporting began on Feb. 1. And yes, CARB could come after you for non-compliance — to the tune of $10,000 per vehicle per day.

The fleet manager may have a case for an exemption or extension. Still, the application requires documentation showing that ZEVs cannot replace ICE vehicles of that type to satisfy the intended duty cycle. Applications for infrastructure extensions must be completed at least one year before the next applicable compliance date.

ZEVs are expensive, but California offers serious grant money under the state's Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP).

Fleets can access a $45,000 voucher for a CARB-approved Class 3 electric truck and $60,000 for a Class 4 truck at the point of sale. Stacked with the federal $7,500 credit, the capitalized costs of these EVs can be reduced by as much as 75% and could be far lower than acquiring equivalent ICE vehicles.

Like compliance, there are deadlines for accessing HVIP grants — they sunset for high-priority fleets on Dec. 31, 2024.

ACF: What You Need to Do Right Now

If this is turning into a Holy Cow moment for you, there are things you should do right now:

• Access the resources and know-how of associations such as NAFA and AFLA.
• Gain advice from public-sector fleets in California, most of which have already established some form of infrastructure and have EVs on the road.
• Contact your fleet management company or one of the numerous organizations that help fleets electrify.
• Contact your California utility or utilities to understand your power and infrastructure needs.
• Start the application process for an HVIP grant.
• Contact CARB immediately and explain your situation and better understand your compliance.
• Attend the Fleet Forward Tour stop at the Port of Los Angeles on June 12. We’ll be incentives and compliance, and plenty of resources will be there to help you.

To the fleet manager's comment, challenges to ACF are making their way through the courts. One school of thought is that the compliance timeline may be elongated, and more exemptions may be granted, but ACF would not be eliminated entirely.

The most important takeaway is demonstrating that you have a plan and you're making progress on that plan. CARB is more likely to give leeway to organizations making good-faith efforts.

The wrong decision is to wait until January 2025.