Preparing for the Coming ZEV Revolution

If you’re a business with on-road or off-road vehicles operating in California, you’ve likely spent the past 10+ years strategically retrofitting and replacing vehicles in order to meet the stringent requirements of the CARB regulations governing off-road large spark-ignition (LSI), off-road diesel (ORD), and on-road truck fleets. These regulations have generally accelerated the turnover rate in fleets to force wider integration of newer, cleaner engines. As these rules have reached/are nearing the end of their useful life (the final emission targets/deadlines were 1/1/2013 for the LSI rule and 1/1/2023 for the ORD and on-road truck rule), a new mandate is in play that will force those fleets into even cleaner territory.

Between the Governor’s September 2020 executive order with zero-emission transportation goals and the five-year update to the CARB Mobile Source Strategy document, the agency is moving aggressively on multiple fronts to accelerate the adoption of zero-emission vehicles (ZEV) and equipment, incentivize construction of the necessary infrastructure for ZEV, and create a market for ZEV technology. Among the wide-ranging regulations currently in various stages of development are:

  • Zero-Emission Forklifts: Targets forklifts with lift capacity up to 12,000 lbs. Aims to phase out smaller forklifts (up to 65 hp) beginning 2025 and larger forklifts beginning 2030, replacing them with ZEVs at 8-10 years old.

  • Off-Road Diesel Amendments: (In development) Anticipated to introduce phase-out schedules for Tier 0 through Tier 4i equipment. Likely to include a schedule for use of renewable diesel fuel.

  • Advanced Clean Fleets: Targets medium- and heavy-duty trucks (GVWR > 8500 lbs) for replacement with ZEVs everywhere feasible by 2045. Drayage trucks are targeted for 100% ZEV by 2035.

  • Transport Refrigeration Units (TRUs): Phases in zero-emission truck TRUs beginning 12/31/2023.

  • In-Use Locomotives: Anticipated to apply to locomotives with at least 1006 hp. Proposal involves a novel approach requiring the locomotive owner to put a certain amount of money in a spending account each year (beginning in 2023) to be used toward the purchase of cleanest available or zero emission locomotive replacements. The amount required for deposit in the account would be determined by the emission factors and usage of the current locomotive fleet (i.e., the dirtier the current fleet, the more money will need to be set aside).

  • Cargo Handling Equipment: Phase-out of pre-Tier 4 engines by 2031, with initial equipment and infrastructure targets beginning in 2026 that will work toward transition to full electric operation.

  • Commercial Harbor Craft: Requires 100% renewable diesel for all harbor craft beginning in 2023, with phase-in of cleanest engines and DPF retrofits beginning in 2023.

What are the key things to pay attention to now with these regulations?

Pay particular attention to the exemptions that CARB is proposing and whether they will potentially apply to your fleet. Do you have any existing conditions that would make ZEV replacements particularly expensive or difficult (or impossible) that aren’t already addressed in the proposed exemptions?

Looking at the ZE forklift regulation, as an example: CARB intends to include an exemption for all-terrain forklifts but needs feedback on what characteristics distinguish and identify an all-terrain forklift. Similarly, CARB staff are considering exemptions for low use forklifts, rental vehicles, remote operations where charging stations are not feasible, and/or extreme duty cycles that can’t accommodate charging time but need more information in order to craft the specifics of these exemptions and justify them. If your fleet includes operations like these, it’s best to be engaged in and contributing to the rule development process while the opportunity is available!

If you would like to learn more about our services in this area, contact Lara Gertler at or at (805) 764-6014.