CARB question and replacing my engine
Thanks for the information. When I received the notice from DMV I read everything I could find on ARB, CARB, AQMD, and TRUCRS web sites called ARB twice. Everything I read and was told by ARB that the Low usage exemption was 2000 miles obviously that is incorrect. I will check the CARB EDVR. I also need to talk to the original owner about how he had the truck registered. The truck does not have a CVRA decal so I suspect he had it registered as a non commercial truck. Just heard that the Governor signed a bill requiring trucks over 14,001 lbs will now have to pass smog checks.
Chuck
This is patently false, due to the way the sentence is worded. The GVWR being 17,500 lbs is not the thing which makes bluovl's truck exempt.
While a 17,500 GVWR vehicle is not subject to biennial smog inspection program... it is instead subject to an ANNUAL Periodic Smoke Inspection Program (PSIP), as well as the random Heavy Duty Vehicle Inspection Program (HDVIP). So it isn't the GVWR that garners the exemption. Just so no one misunderstands.
Nor does the receipt of 2020 tags demonstrate that bluovl cleared the hurdle of the new DMV registration enforcement regulations that take effect on January 1, 2020. It isn't January 1, 2020 yet, so there are no current DMV restrictions in place for registering 2000 through 2003 trucks. If an owner's renewal due date is in December, 2019, and they pay their fees on time, they will get 2020 tags good through December 2020, regardless of their vehicle use or lack of exemption status. The DMV's authority to deny registration for purposes of enforcing the Truck and Bus Regulation does not begin until January 1, so the possession of 2020 tags now does not in anyway mean that the hurdle has been cleared for receiving 2021 tags.
To get 2021 tags, either the engine needs to be replaced with a 2010 or newer engine, or an exemption status must be reported through one of two reporting databases that the CARB maintains... either TRUCRS or EDVR, whichever is applicable. Still, the truck is not legal to operate, regardless of valid registration status, if it is not reported to CARB under one of the two available exemption options.
bluoval's 17,500 GVWR F-550 is actually subject to PSIP testing every year (smoke testing), unless his F-550 is the only diesel truck in his "fleet" that is over 14,000 GVWR, and is for personal use exclusively. THOSE are the two factors which make his truck exempt... not the GVWR alone. It is rather the constellation of factors that determine exemption status... as bluoval further explains below:
https://www.ccair.org/sb-210-becomes...d-by-governor/
Thanks!
Remember, your truck was not required to be reported to TRUCRS unless it was retrofitted with BACT prior to 2014 and that retrofit was being used as part of a "credit" to prolong a percentage of total fleet compliance for subsequent years. But all of those compliance and credit options expired. And even if retrofitted with BACT back then, the engine would still need to be replaced with a 2010 or newer engine before 2023.
Whether your 2003 engine 16K GVWR F-450 is personal use in a fleet of 1, or dedicated commercial use in a fleet of 100,000, your truck was never required to be reported to TRUCRS until this coming January. At that time, it will need to either be committed to the Low Use Exemption operating not more than 1,000 miles per year in California, or have been retrofitted with a 2010 or newer engine, with the attendant emissions control systems for that engine (SCR, DPF, DOC, DEF), unless your truck was granted an exemption based on your application through the EDVR system.
About 120 days prior to your next year's registration coming due, you will receive a Certified Letter via the US Postal Service sent to the address of registration records from the CARB advising you that your vehicle registration will be denied.
While a 17,500 GVWR vehicle is not subject to biennial smog inspection program... it is instead subject to an ANNUAL Periodic Smoke Inspection Program (PSIP), as well as the random Heavy Duty Vehicle Inspection Program (HDVIP). So it isn't the GVWR that garners the exemption. Just so no one misunderstands."
Ok, I'm not sure about the context of "patently false", but I disagree. Look at the B.A.R. chart below, and read note #7. I am not a "fleet" operator. Clearly the delineator for diesel is GVWR:
I agree, this truck was inspected once before after the bed was installed. I agree I will need to send pictures and a statement on the trucks use to avoid being denied renewal for 2021. I take it that you are on the Board or occupy some official capacity with the State. Correct?
Looking at the B.A.R. chart that you posted (nice addition to the thread btw) entitled titled "Smog Check Requirements By Vehicle Type", with the blue boxed red check mark "Smog Check" icon in the upper right... we can clearly see that this chart describes the biennial (every two years) and COO (Change Of Ownership) Smog Check program.
However, your previous quote, that I found patently false, stated:
I am convinced that you have a good handle on what regulations your truck is subject to... my point of clarification was at the wording of your sentence, which could confuse and mislead others. The Smog Check program is only a small part of all the smog regulations in California. And this thread wouldn't exist if 17,500 GVWR vehicles were not subject to smog regulations, including and especially the new Truck and Bus Regulation.
Now let's talk about footnote 7 and whether or not you are a fleet.
In an earlier post, you quoted the Final Regulation Order, so turn to the top of page 8 in the pdf of that Order. I'll spell it out, just like you did earlier, so others can find it also on their own.
Title 13, California Code of Regulations,
Division 3: Air Resources Board
Chapter 1: Motor Vehicle Pollution Control Devices
Article 4.5
Section 2025: Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen and Other Criteria Pollutants from In-Use Heavy-Duty Diesel-Fueled Vehicles.
(d) Definitions: For purposes of this regulation, the following definitions apply:
(28) “Fleet” means one or more vehicles, owned by a person, business, or government agency traveling in California and subject to this regulation.
{Bold emphasis added.}
The Regulation reiterates one truck as substantive enough to be a fleet by further defining the parameters of the "Small Fleet Compliance Option", on Page 17, under Sub Paragraph (h)
(h) Small Fleet Compliance Option: In lieu of initially complying with the schedule set forth in Table 2 of section 2025(g), a fleet with a fleet size of one to three vehicles with a GVWR greater than 14,000 lbs...
{Bold emphasis added.}
So, for purposes of the new Truck and Bus Regulation, your one truck is a fleet, owned by a person. It does not matter that you are not a business, or in business. It does not matter if you only have one truck. You have a fleet. As do I.
However, the regulations that created the PSIP program preceded the new Truck and Bus Regulation by many years, and the definition of "fleet" for purposes of compliance with the PSIP program is slightly different.
The PSIP program requirements, as of May 2019, are as follows:
All California-based fleets of two or more heavy-duty diesel vehicles over 6,000 pounds gross vehicle weight rating (GVWR) with engines over four years old are required to perform annual smoke opacity tests (1998 and newer diesel vehicles between 6,000 – 14,000 pounds GVWR subject to biennial smog check are not subject to PSIP)
So you are correct in that your truck is not currently subject to smog inspection, either through the Smog Check program, or through the PSIP program, with only one truck that is over 14,000 GVWR. But that truck remains subject to the smog regulations in the Truck and Bus Final Regulation Order, and the smog regulations in Senate Bill 1, which vested authority with the DMV to deny registrations for those vehicles that are not compliant with the Truck and Bus regulations.
Our "disagreement" lay only in the wording of the sentence in your earlier quote, which some folks might believe and run with, only to find out later that ignorance or misunderstanding of the law is no excuse for non compliance... learning the hard way.
Incorrect. I am not on the Board, nor do I occupy any type official capacity with the State. I'm just an FTE member, who, just like you, has a personal use F-550 pickup with the same 17,500 GVWR.
I do however, regularly take training classes with CARB truck and bus regulatory, training, and enforcement staff, in my part time capacity as a regulatory compliance manager for a commercial fleet of mostly much larger trucks and equipment.
Because 2020 is a major transition year, under two constructs, the first being the kick in of a lot more Super Duties, which began in model year 1999, and roared in earnest by 2000, when the F-650/750 came on board with the then new body style... and the second construct being the inaugural year of DMV registration denial based on non compliant status... threads such as this can be useful to help existing members and attract new members to FTE who seek a little "layman's" help in navigating the upcoming implementation of these newly enforceable regulations, despite them being codified into law 10 years ago.
It isn't clear to me that bash sessions bagging on California or speculation as to the reasons these regulations were passed would be as useful in the endeavor to help folks facing very real problems, in the very near term. When moving out isn't an option, and willful defiance isn't in the game plan, the most constructive use of this forum, and this thread in particular, is to help each other achieve compliance.
Please consider this more purposeful goal when you post.
You are absolutely correct and for that I apologize for continuing the hijack. California has more serious issues than what is being discussed here. I just feel bad that my fellow Americans out there have to deal with this for their older vehicles. That's all. I'm out....
Thanks
Ford Trucks for Ford Truck Enthusiasts
Please don't force us to close the thread or remove it. Keep it on topic guys. Thanks.
Stewart


















