How Can I Comply with the CARB Advanced Clean Fleets (ACF)?

What is Advanced Clean Fleets (ACF)?

The recently passed Advanced Clean Fleets (ACF) regulation is part of the California Air Resources Board’s (CARB) effort to accelerate the adoption of zero-emission trucks by the state’s medium- and heavy-duty vehicle fleets. This transition to zero-emission vehicles (ZEVs), specifically trucks in Classes 2b through 8, will cut emissions of greenhouse gasses and harmful air pollutants over the next decade, improving the health of Californians and advancing the state’s climate goals¹.

At the same time, the regulation presents unique challenges for commercial fleets, particularly those with little (or no) experience procuring and operating zero-emission vehicles. By working with partners who understand the associated hurdles and how to overcome them, fleet managers can set their companies up for success: improving the environmental and economic performance of their fleets, all while complying with ACF.

As a first step, fleet operators must recognize the requirements laid out in these newly minted regulations.

Which fleets are impacted by ACF?

Under the ACF regulation, high priority commercial fleets and federal fleets are subject to the same zero-emission vehicle adoption requirements. By CARB’s definition, high priority fleets are fleets belonging to entities with 50+ trucks in CA, or over that have $50 million or more in gross annual revenue. Of note, the regulations have separate requirements for drayage fleets and state & local agencies.

What are the compliance requirements for high priority fleets?

High priority fleets have two options for compliance under ACF regulation:

• OPTION 1: Model Year Schedule – Compliance under this option begins in January 2024, after which point every new vehicle added to the fleet must be a zero-emission vehicle. Furthermore, fleets must remove vehicles from the fleet as they reach the end of their useful lives (as determined by SB 1)².

This option draws a harder line in that it restricts fleets from adding internal combustion engine (ICE) vehicles, but it allows fleets to determine the pace by which they integrate zero-emission vehicles into their operations.

• OPTION 2: Milestone Schedule – Fleets must meet zero-emission vehicle targets as a percentage of their total fleet, according to the ZEV Milestone Schedule (see table below).

Figure: ACF’s Milestone Schedule for respective vehicle groups.

Vehicle types are split into three different groups based on CARB’s determination of market maturity for the respective zero-emission vehicle types.

This option affords fleets more time to comply, as even Vehicles in Group 1, which has the most accelerated compliance schedule, are not impacted until 2025. However, the “Milestone Schedule” option enforces stringent fleet composition requirements, in contrast to the “Model Year” option, which provides more flexibility on the pace of adoption. Another key difference between these options is that the “Milestone Schedule” track allows fleets to continue purchasing ICE vehicles, as long as they meet the fleet zero-emission vehicle composition mandates.

Steps to comply with ACF:

With an understanding of the ACF regulations and compliance options, fleet managers can begin to take steps towards zero-emission vehicle adoption. Making this switch does not have to compromise the economic or operational performance of your fleet, as long as you take the proper steps:

First, take stock by asking yourself these key questions:

1. Am I taking a programmatic approach to fleet electrification? Your initial EV deployment will likely be the first in a staged transition to a zero-emission fleet, but from the start, fleet managers will be well served to develop a long-term plan. Such planning will minimize the overall cost and operational challenge of transitioning to a zero-emission fleet and set your fleet up for success.
2. Which vehicles and charging products are right for my fleet/facility? The technology landscape for zero-emission vehicles, EV charging equipment, and supporting software products is constantly transforming. Keeping tabs on these changes and evaluating different options against the needs of the fleet is overwhelming and impractical for most fleet managers. However, missteps expose the fleet to unnecessary costs and headaches, leaving fleet managers in a tough position.
3. Once your fleet is operational, how will you keep it running? For most dealers, fleet management companies, and EV charging contractors, responsibility stops after product delivery. Lack of coordination and misaligned incentives across vendors can expose fleets to additional risks when integrating new vehicles into their fleets. Fleet managers should take particular care to ensure that all components of their zero-emission fleet (vehicles, charging infrastructure, telematics, custom features, etc.) operate seamlessly together well beyond just day one. Moreover, having a partner with deep knowledge across vehicle and charging technologies provides an additional layer of security and ensures that problems are quickly addressed when they arise.

Next, find a partner like Revolv to assist in the transition to zero-emission:

If you operate a fleet in California and are seeking guidance on zero-emission vehicle adoption, a full-service provider like Revolv can help to minimize disruption while maximizing progress. Whether you are in the early stages of planning for ACF compliance or getting a head start to meet your company’s ESG goals, Revolv can deliver a single-partner solution for deploying, charging, and integrating electric vehicles seamlessly into your operations. Fleet electrification does not have to be daunting; by partnering with Revolv you can offload the most difficult tasks and position your fleet for a successful transition to zero-emission vehicles in the months and years to come.