CARB in a recent email to our legal counsel’s office purports to clarify CCTA’s role in the labeling requirements for the low-mileage construction truck extension. Over the last month, we requested a follow-up with CARB concerning some confusion about CCTA’s role.

We have clarified that “CCTA does not appear to have a direct role in the label process,” and CCTA may voluntarily assist its members if desired (i.e. print decals, etc.). The email clarifies that CCTA has no mandatory role in this process. As such, each individual company must determine how best to comply with the CT labeling requirements required under subdivision (p), paragraph (2) of the rule, set out below:

(H) Labeling Requirements for Low-Mileage Construction Trucks – Available 2/11/12

1. By January 31, 2012, (pushed-out we assume to March 30) fleet owners must affix or paint an identification label on up to ten low-mileage construction trucks and within thirty days after notification that any additional trucks have been approved as follows:

a.    The letters CT shall be white block lettering on a black background. Both letters shall be at least 3 inches high on a 5 x 8 inch background.
b.    The label shall be located on the left and right door of the vehicle and be in clear view at all times.

Div. 3, Chpt. 1., Sect. 2025, (d) Definitions,

(41) “Low-use Vehicle” means a vehicle that will be operated fewer than 1,000 miles in California in any compliance year. If that vehicle has an engine that powers other equipment that can only be used while stationary, the engine or power take off (PTO) must also operate less than 100 hours in any compliance year. The hour limitation does not apply for vehicles where the engine is used to power an auxiliary mechanism that strictly loads and unloads cargo from the vehicle (examples include, but are not limited to, dump trucks, cement powder trucks, or trucks with attached lift devices). (pg. 10)

 (p) Exemptions, Delays, and Extensions (pg. 30)

(4) Exemption for Low-Use Vehicles (pg. 33)

(A) Low-use vehicles as defined in section 2025(d)(41) are exempt from the requirements of section 2025(e) but the owner must meet reporting and record keeping requirements in accordance with sections 2025(r)(12) and 2025(s) Recording Keeping (pg. 50).

1. To be considered a low-use vehicle, the fleet owner must submit engine operation data from a properly functioning odometer or hubodometer and non-resettable hour-meter (for PTO operation).

2. A vehicle is also considered to be a low-use vehicle if it is not driven for the entire compliance year and either a planned non-operation certificate or a certificate of non-operation has been filed with the DMV or, an equivalent certificate has been filed with another state prior to the beginning of the compliance year. The vehicle must not be operated for any other purpose during the compliance year except to demonstrate functionality of the vehicle to potential buyers, to move the vehicle short distances for maintenance, or to a storage facility while awaiting sale.

3. Low-use vehicles need not be included when determining compliance with the small fleet compliance option of section 2025(h) or the phase-in option of section 2025(i).

2025 (r)(12) Low-Use Vehicle Reporting

For vehicles that are designated as low-use, the fleet owner must report the following information to the Executive Officer annually for as long as the fleet owns or operates the vehicle:

(A) Owner, vehicle, and engine information identified in sections 2025(r)(5) through 2025(r)(9);

(B) Mileage readings from a properly functioning odometer or hubodometer taken on January 1 and December 31 of the compliance year. A hubodometer may be used in lieu of the odometer;

(C) If the vehicle uses engine power as specified in 2025(d)(41), hour-meter readings from a properly functioning non-resettable hour-meter taken on January 1 and December 31 of the compliance year;

(D) The dates and readings of the odometer and non-resettable hour-meter readings. In the event that the odometer is replaced, the original odometer reading and the new odometer reading and the date of replacement must be reported within 30 days the original odometer failed. In the event that the odometer or hubodometer is removed, the reading and date it is removed and the reading of the replacement and the date it is placed in service. If hubodometers are used, the fleet owner must report the serial numbers;

(E) Upon request of an agent or employee of the ARB, the owner of a vehicle operating both inside and outside of California must provide records from a electronic tracking system as defined in section 2025(d)(21) that can acquire date, time, engine-on, and location data. The owner may use other documentation of vehicle operation and location, such as IRP records;

(F) Whether the vehicle is used as an emergency support vehicle as defined in section 2025(d)(23); and, if so, the fleet owner must report the information in section 2025(r)(15); and

(G) Whether a planned non-operation certificate has been filed with the DMV or, an equivalent certificate has been filed with another state prior to the beginning of the compliance year, and whether the vehicle will not be operated in the compliance year.

$10/set for Members

$20/set for Non-Members

Order at 909-982-9898