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CARB Advanced Clean Fleets Regulation

On Aug. 30, 2022, CARB issued a notice announcing that it will conduct a public hearing on Oct. 27, 2022 where it will consider adopting the proposed Advanced Clean Fleets (ACF) regulation.

The proposed regulation includes four components:

• requirements for State and local government fleets,
• requirements for drayage truck fleets,
• requirements for high priority and federal fleets, and
• a 100% ZEV sales requirement for medium- and heavy-duty truck manufacturers.

The deadline for submitting comments on the proposal is October 17, 2022.

All documents for this rulemaking can be found here. 

CARB ACC 2 Regulation

On April 12, 2022, CARB issued a notice announcing that the Board will conduct a public hearing on June 9, 2022 to consider the proposed Advanced Clean Cars II (ACC II) rulemaking.  The ACC 2 rule proposes that manufacturers be required to deliver for sale increasing percentages of ZEVs and PHEVs as a portion of their overall product deliveries between model years 2026 and 2034 and reach 100-percent ZEVs in 2035 (and after). The Notice, ISOR, and all subsequent regulatory documents are available on CARB's ACC 2 rulemaking webpage.  Comments are due May 31.

Regulatory and Legislative Tracking Reports for Vehicle Manufacturers and Suppliers

Since 1999, Kardos & Associates LLC has supplied the auto industry with the most comprehensive regulatory and legislative tracking reports available. We currently offer clients the following:

Motor Vehicle Safety & Emissions Regulatory Update (the REG UPDATE)

The REG UPDATE has been tracking US and Canadian regulatory activity impacting the auto industry for over twenty years. Regulations developed by the NHTSA, FMCSA, EPA, FCC, CARB, Transport Canada, and Environment Canada are the focus. For each rulemaking, the Reg Update provides a description of the rulemaking, comment deadlines, effective dates, a docket reference, and links to documents available online. Deadlines and critical path items are color-coded so that you can quickly identify what’s new and important. In addition to being an excellent tool for tracking regulatory activity, the Reg Update is a great archive of past actions. The report contains information on virtually every rulemaking affecting automakers from the past two decades. Approximately 400 pages in length.

U.S. Safety & Fuel Economy Regulatory & Legislative Update
The U.S. Safety & Fuel Economy Regulatory & Legislative Update provides a snapshot of the past month’s legislative and regulatory activities relating to safety, emissions and fuel economy. The report provides brief summaries of notices issued by DOT, EPA, CARB and others. With regard to federal legislation, the report covers newly introduced bills, information on committee hearings, etc. Activities at the state level pertaining to emerging technologies (e.g., automated vehicles, advance driver assistance systems, EVs and EV infrastructure, etc.) are also covered.

Federal Legislation Tracking Report
Our legislative tracking report focuses on matters relating to environment and energy, safety and fuel economy/climate change. The report covers two years-worth of bills (the length of each Congressional session) and includes summaries and status updates for each tracked bill. Links to bill text and related information are provided.

All of our reports are distributed monthly via email as a PDF. Subscribers also get access to an online archive of past reports.

For pricing, contact Dale Kardos at (202) 3064997 or [email protected]. For more information about Kardos & Associates LLC, see www.kardosllc.com.

For a PDF of this information, click here.

California ZEV Credit Balances

CARB has posted ZEV credit balance data as of Aug. 31, 2020.  The data includes 2019 vehicle production for sale in California of large volume and intermediate volume manufacturers.  2019 ZEV requirements are based on 7.0% of a manufacturer’s total average production volume of all passenger cars and light-duty trucks up to 8500 lbs for sale in CA for the 2015-2017 model years.  The report additionally shows transfer of credits between manufacturers for the period Sep. 1, 2019 to Aug. 31, 2020. There was only one transfer (6000 BEV credits from Tesla to Mazda). For a copy of the report, click here.

CARB Proposed Advanced Clean Trucks (ACT) Regulation and Draft Environmental Analysis (EA)

On Oct. 22, 2019, CARB released it proposed Advanced Clean Trucks (ACT) Regulation and Draft Environmental Analysis (EA) for public comment.   The proposal, if finalized, would require manufacturers of incomplete or complete vehicles > 8500 lbs GVWR with 500 or more annual sales in CA to begin to electrify their fleets starting in 2024. Fleet compliance percentages vary by year and vehicle class.  By 2030, one out of every two Class 4-8 vehicles will need to be electrified.

The rule will be considered by the Board at a hearing which will take place in Sacramento, CA on Dec. 12, 2019 starting at 9 am (PST).

Written comments on the proposal must be submitted no later than Dec. 9, 2019.

All documents concerning the rulemaking are available online at https://ww2.arb.ca.gov/rulemaking/2019/advancedcleantrucks.

Automakers Announce New Voluntary Framework with California on Greenhouse Gas Regulations

On July 25, 2019 Ford, Honda, Volkswagen Group of America and BMW of North America announced terms agreed to by the CARB to preserve a single 50-state framework for the regulation of GHG emissions from vehicles. These terms will provide regulatory stability, preserve vehicle affordability for customers, reduce compliance costs and result in increased environmental benefits.

The agreement with CARB is available to all automakers.

The terms are as follows:

• Revised Greenhouse Gas Standards:  GHG standards, beginning in the 2022 model year (MY) and extending through the 2026 MY, with increasing stringency at a nationwide average annual rate of 3.7% (year-over-year). Of the 3.7% annual stringency, 1% can be achieved using the advanced technology multiplier credits, below.
• Appropriate Flexibilities to Promote Zero Emission Technology:  Continue current advanced technology multipliers that now expire after MY 2021, extending them through MY 2024 at the current 2.0x for Battery Electric and Fuel Cell Electric Vehicles (BEV/FCEV), and 1.6x for Plug-in Hybrid Electric Vehicles (PHEV), tapering off at the current MY 2020 and MY 2021 levels in MY 2025 and MY 2026, respectively. 
• Simplify Accounting:  Remove the requirement to account for upstream emissions of fuels, as these can be addressed by other programs.
• Increase Innovation:  Raise the current cap on off-cycle menu credits, which account for actions taken outside the formal test cycle framework, from 10 grams per mile to 15 grams per mile starting in MY 2020.
• Streamlining and Process Improvements: Improve the off-cycle credit program to facilitate timely review and decision-making regarding the approval of new off-cycle technologies. 
• Recognize California’s Authority: Participating companies are choosing to pursue a voluntary agreement in which California accepts these terms as compliance with its program, given its authority, rather than challenge California’s GHG and ZEV programs.

CARB and Canada agreement to advance cleaner vehicles and fuels

On June 26, 2019, CARB issued a press release announcing that Canada’s Minister of Environment and Climate Change, Catherine McKenna, and the Chair of the California Air Resources Board, Mary Nichols signed a new cooperation agreement to advance cleaner vehicles and fuels.

The Memorandum of Understanding commits both governments to work together on developing their respective regulations to cut greenhouse gas emissions from light-duty vehicles, such as those currently in effect in Canada, California and the 13 U.S. states that have adopted California’s standards.  Canada is currently reviewing its light-duty vehicle standards to help make sure people can drive fuel-efficient cars that cut pollution and reduce fuel costs.

The partnership will also see Canada and California work together to accelerate the adoption of zero-emission vehicles like electric cars.

The two jurisdictions will also share technical information and best practices in regulating cleaner fuels, as California does today though its Low-Carbon Fuel Standard.

The cooperation will take a variety of forms, including establishing a working group that meets annually, sharing policy information and program design, providing capacity building and technical support, exchanges of personnel, cooperative research and development, and joint organization of symposia and trainings. The two regulatory agencies will also work together on emissions testing and enforcement of vehicle regulations.

For a copy of the press release, click here.

EPA, DOT Propose Greenhouse Gas and Fuel Efficiency Standards for Heavy-Duty Trucks

The U.S. Environmental Protection Agency (EPA) and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) are jointly proposing standards for medium- and heavy-duty vehicles that would improve fuel efficiency and cut carbon pollution.

The proposed standards are expected to have the following impact:

• Lower CO2 emissions by approximately 1 billion metric tons
• Cut fuel costs by about $170 billion
• Reduce oil consumption by up to 1.8 billion barrels over the lifetime of the vehicles sold under the program 

The EPA concludes the reductions would nearly equal the greenhouse gas (GHG) emissions associated with energy use by all U.S. residences in one year and the total oil savings under the program would be greater than a year’s worth of U.S. imports from the Organization of the Petroleum Exporting Countries (OPEC).

The proposed vehicle and engine performance standards would cover model years 2021-2027, and apply to semi-trucks, large pickup trucks and vans, and all types and sizes of buses and work trucks. They would achieve up to 24 percent lower CO2 emissions and fuel consumption than an equivalent tractor in 2018, based on the fully phased-in standards for the tractor alone in a tractor-trailer vehicle. Additionally, the proposed standards are:

• Not mandating the use of specific technologies. Rather they establish standards achievable through a range of technology options, and allow manufacturers to choose those technologies that work best for their products and for their customers. (These technologies include improved transmissions, engine combustion optimization, aerodynamic improvements and low rolling resistance tires). 
• Phased in over the long-term, beginning in model year 2021 and culminating in standards for model year 2027 – giving manufacturers the time and flexibility to plan.
• Flexible, by allowing banking and trading emissions credits for most manufacturers, and providing businesses the opportunity to choose the most cost-effective path to meet the standards.

The proposed standards are fully harmonized between NHTSA and EPA. The agencies have also worked closely with the State of California’s Air Resources Board in developing the proposed standards. A public comment period will be open for 60 days after the proposal is published in the Federal Register. In addition, NHTSA and EPA will host two public hearings. 

ARB Symposium on California’s Development of its Phase 2 Greenhouse Gas Emission Standards for On-Road Heavy-Duty Vehicles

On March 27, 2015, CARB announced that it will hold a symposium on its Phase 2 GHG Emission Standards for On-Road Heavy-Duty Vehicles.  The symposium will be held in Diamond Bar, CA on April 22 from 9 am to 5:30 pm.  Participation via webcast will be available.  For more information about Phase 2 GHG emission standards for on-road heavy-duty vehicles, see http://www.arb.ca.gov/msprog/onroad/caphase2ghg/caphase2ghg.htm.

Questions regarding the symposium should be directed to Krista Fregoso at (916) 445-5035 or [email protected].

ZEV Program Amendments

On Monday (July 14, 2014), the California Air Resources Board (CARB) will hold workshop at 10 am PST in Sacramento to discuss changes that are being considered for the ZEV program. 

According to the Staff presentation that was released Friday, the workshop will focus on amendments that would make the percent of sales requirement for Intermediate Volume Manufacturers (IVMs) more consistent with the percent of sales requirement applicable to Large Volume Manufacturers (LVMs).  IVMs include manufacturers like JLR, Mazda, Mitsubishi, Subaru and Volvo.  If adopted, the percent of sales requirement for IVMs would, according to projections by CARB, change from 44% in 2025 to 18.4% in 2025 (assuming IVMs use TZEVs to comply). This is depicted in the figure below. 

  

At the workshop, CARB also intends to discuss changes that would reduce the compliance burden for IVMs that want the flexibility to pool compliance in ZEV states and to earn a reduced TZEV requirement. Currently, to have this flexibility, IVMs must deliver ZEVs to S.177 states prior to 2018, however, under the modifications being considered by CARB, IVMs would get an extra two years to comply with this requirement.

CARB will discuss the fast refueling and clarifying language related to that provision.

The schedule for finalizing the modifications that will be discussed at the workshop calls for the proposed amendments to be issued for public comment in early September and a Board Hearing in late October. 

Persons unable to attend in person may take part via webcast. The broadcast can be accessed on the day of the workshop at: http://www.calepa.ca.gov/broadcast/?BD0=1.  

Source: Mobilis Trading