This fall has been busy with regulatory activity at the California Air Resources Board (CARB). WG staff has been actively participating in two regulatory proposals that will impact farmers in both the short- and long-term.

The first proposal is the Advanced Clean Truck Regulation which is designed to mandate that manufacturers make and sell more zero-emission trucks and buses. It would be comprised of two parts:

1. A one-time reporting requirement from large business entities that operate in California regarding the number and types of shipments they make. As proposed, large entities would be businesses that earn more than $50 million in annual revenue and operate a facility in California, or own a fleet of 100 or more Class 2b or higher vehicles and operate a facility in California, or dispatch 100 or more Class 2b and greater vehicles in California.
2. The utilization of data from the one-time reporting rule to develop and implement a zero-emissions manufacturing and sales requirement for truck manufacturers.

WG is part of a coalition of business interests that have raised significant concerns with both portions of the proposal, stating that the reporting requirement is onerous given the number and lack of clarity about the questions being asked. The proposed zero-emission truck sales requirement is also troubling since the regulation would establish a sales and marketing mandate on zero-emission truck sales at a time when the technology is still being tested and evaluated. There is also a real-world concern about what happens when there is a public safety power shutoff and employers are not able to recharge their truck batteries.

CARB shares many of our concerns about the technology not being advanced enough for a mandate and is currently re-working many aspects of the one-time reporting requirement in response to our comments. However, environmental groups are pushing CARB to enact a stricter mandate on a faster time schedule.

CARB is also working on the development of the next Transportation Refrigeration Unit (TRU) regulation. WG is participating in those workshops and meetings in order to raise our concerns about the real-world impacts of the proposal.

The proposal includes four general requirements:

1. Starting in 2022, TRUs and TRU generator sets would have to register with CARB.
2. Starting in 2023, applicable facilities, including grocery stores and warehouse distribution centers, would have to register with CARB. These facilities would also need to supply CARB with their geo-fence information.
3. Starting in 2024, these applicable facilities would need to complete the installation of their electrical charging infrastructure.
4. Starting in 2025, truck TRU fleets would be required to turn over 15% of their fleet each year to zero-emission TRU technology. All truck TRU’s would have to be zero-emission by 2031. This is a very aggressive and unrealistic time schedule.

WG will continue to participate in these regulatory discussions to ensure that the concerns of the agricultural industry are heard.

For more information, contact Matthew Allen at (916) 446-1435.