19 www.ortrucking.org Issue 4 | 2023 increasing percentage of their annual sales from 2024 to 2035. ACT uses a cap-and-trade system, capping the number of fossil fuel vehicles sold by stipulating annual sales percentage requirements. Manufacturers can comply by generating compliance credits through Zero-Emission Vehicle (ZEV) or Near-Zero-Emissions Vehicle (NZEV) sales. Thus far, only battery electric vehicles qualify as ZEVs. While the intent of the rule is to transition all trucks and buses sold in California to ZEVs by 2035, the transition will require significant public and private investments to establish the required infrastructure for electric vehicles as well as to purchase these trucks. Finally, because the rule requires that OEMs sell a specific percentage of ZEVs and there is not a significant market for electric, there is concern that the mandate will result in a lack of non-ZEV vehicles. For example, if the mandate is 10 percent ZEV vehicles and there is zero market for ZEVs, OEMs would not be allowed to sell any non-ZEV vehicles because 10 percent of zero is zero. California’s Advanced Clean Fleet (ACF) Rule Intended to serve as another tool to decrease emissions and transition to ZEVs, the ACF requires that High priority (entities that own, operate, or direct at least one vehicle in California and have either $50 million or more in gross annual revenues, or that own, operate, or have common ownership of 50 or more vehicles) and federal fleets must purchase only ZEVs beginning in 2024 or elect to meet ZEV targets as a percentage of the total fleet starting with vehicle types most suitable for electrification. In addition, manufacturers may only sell zero-emission medium and heavyduty vehicles beginning in 2036, and, beginning Jan. 1, 2024, trucks must be registered in the CARB Online System to conduct drayage activities in California. Beginning January 1, 2024, only zeroemission drayage trucks may register in the CARB Online System. All drayage trucks entering seaports and intermodal railyards would be required to be zeroemission by 2035. ATA has joined the California Trucking Association’s lawsuit, explaining that the targets and timelines set by California are unrealistic and unachievable given existing technology and infrastructure for ZEVs. The Bottom Line While decreasing emissions is a commendable effort, these requirements are neither realistic nor achievable, as the ATA has made abundantly clear. The trucking industry has made significant progress in the past decade toward decreasing emissions and improving technology behind ZEV trucks, but the industry simply hasn’t made enough progress to meet these new standards on the stringent timelines required by the EPA and the state of California. ZEV trucks cost anywhere from 1.5–5x more than conventional trucks, let alone the serious range issues, less fuel/distance capacity, and the serious lack of charging and refueling infrastructure. Industry members have also pointed out that ZEVs are not a one-for-one replacement, meaning more trucks will be needed on the roads to move the same amount of freight. Simply put, the trucking industry is being forced into this new technology before the industry is able to safely, adequately, and appropriately meet these new standards. OTA is working closely with our counterparts at ATA, in California and in other states to combat these unrealistic timelines. If you are interested in learning more about these proposals and how they will impact your operations, or getting involved with OTA’s government affairs committee, please email us at info@ ortrucking.org.
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