By Paul Sousa, Director of Regulatory & Environmental Affairs

The California Air Resources Board (CARB) has been working to reduce criteria air pollutants and greenhouse gas emissions (GHG) from heavy-duty trucks with a series of rules aimed at replacing older trucks with newer, cleaner ones, making sure emission control equipment is functioning as intended, and eventually moving to Zero Emission trucks.  I am going to touch on two of those rules here. The first rule in this series was the Truck and Bus Rule, which required the phasing out of trucks with 2009 and older engines by January 2023. That phase-out is complete, but older trucks are still allowed to operate if they stay under 1,000 annual miles and are reported under the Low Use Exemption.  I recently had a WUD member who received a Notice of Audit letter from CARB regarding their truck in the Low Use Exemption. CARB wanted a photo of the odometer that included the letter in the photo to prove that the mileage was compliant with the Exemption.  We submitted the photo as requested by the deadline.  

A couple of days later, the dairy received a Notice of Violation with a proposed $10,000 fine dated on the day of the deadline in the Notice of Audit letter.  I contacted ARB, who said the two documents crossed in the mail and not to worry that the dairy was compliant.  I bring this up because if you get a Notice of Audit from CARB, do not wait to respond.  I am here to help you, so do not hesitate to reach out.

I also wanted to let you know about a new rule, the Clean Truck Check (CTC), which is a smog check requirement for heavy-duty trucks to ensure that truck emission control systems are operating as intended.  Starting next year, trucks will have to undergo a smog check, like how cars are tested now.  For newer trucks, this will just involve plugging into the truck’s On-Board Diagnostic (OBD) port.  The test does not have to be completed at a smog check station but can be completed anywhere by a certified technician using an approved device.  Agricultural vehicles must be tested once per year, but other trucks will eventually be tested four times per year.  

ARB is setting up a database that truck owners must use to register their trucks for CTC.  A factsheet on CARB’s website states: “CARB anticipates that the database will be open for fleet representatives to create accounts on October 1, 2023. Required information must be entered for vehicles in their fleet that are subject to Clean Truck Check and the $30 per vehicle compliance fee(s) paid for all vehicles in the fleet by December 31, 2023.”  I will have more information on that as it becomes available.  This rule is new, and exactly how it will all work out is still being figured out.  You can visit the Clean Truck Check website: for the latest information.  If you have any questions on this, please reach out to me at [email protected] or at the WUD office.  

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