CARB: Enforcement of Clean Truck Check (CTC)

Scope

Clean Truck Check applies to nearly all diesel and alternative fuel heavy-duty vehicles with a gross vehicle weight rating (GVWR) over 14,000 pounds that operate on California public roads. This includes both in-state and out-of-state vehicles.

Regulatory citations

• 13 CCR Chapter 3.7 - Heavy-Duty Vehicle Inspection and Maintenance (HD I/M) Program

Key definitions

• CARB: The California Air Resources Board.
• Citation: A notice issued by the CARB alleging a violation of the requirements of the HD I/M Regulation, which requires submission of documentation and payment of a penalty.
• HD I/M compliance certificate: A certificate issued to a vehicle owner by CARB, obtained after demonstrating compliance with the HD I/M Regulation, confirming the vehicle can legally operate in California.
• Notice to Submit to Testing (NST): A notice requiring demonstration of compliance, as specified in section 2198.2(a).
• Outstanding enforcement action: Any unresolved civil, administrative, or criminal violation for which a notice was issued to a vehicle or a fleet owner for non-compliance with any in-use heavy duty vehicle requirements established by CARB.
• Roadside emissions monitoring device: A CARB-authorized system for remotely measuring exhaust emissions, downloading onboard diagnostics (OBD) data, or collecting other information for identifying vehicles passing through the system.
• Unresolved citation: A citation issued for violating the requirements of CTC for which acceptable demonstration of compliance has not been provided or, if required, payment of all required penalties has not been received.

Summary of requirements

Enforcement of the Clean Truck Check – Heavy-Duty Inspection and Maintenance (HD I/M) regulation began in January 2023. The program is intended to:

• Ensure that polluting, poorly maintained heavy-duty vehicles operating in California are quickly identified and repaired, and
• Promote a level playing field for businesses that operate compliant vehicles.

How violations are discovered

Vehicles must be reported in the Clean Truck Check – Vehicle Inspection System (CTC-VIS), pay annual compliance fees, and undergo emissions testing.

Vehicle owners, operators, freight contractors, seaports, and railyards may become engaged in enforcement actions as a result of inspections, tests, or audits of vehicles, engines, and records.

Potential enforcement actions

Compliance with the regulation prior to enforcement can help avoid enforcement actions, which may include:

• Vehicle registration holds;
• Citations, penalties, or fines; and
• Possible public posting of settlements.

CA DMV registration holds are automatically placed on vehicles that are not compliant with CTC requirements.

Vehicles found to be in violation of this regulation are subject to removal from service by the Department of the California Highway Patrol if requested by a CARB inspector, and if one or more unresolved citations issued under the program (section 2198.2(b)(1)) exist at the time of inspection.

Steps to compliance

The CTC program requires all non-gasoline powered vehicles that operate in California with a GVWR of 14,001 pounds or more to be registered in CARB’s CTC-VIS database. Part of registering includes paying a per vehicle annual compliance fee.

This program also requires vehicle owners or operators to upload onboard diagnostic (OBD) data to CARB proving that the vehicle is operating within its designed emissions parameters starting in January of 2025.

Roadside testing

The owner of a vehicle passing through a roadside emissions monitoring device may receive a Notice to Submit to Testing. The owner will have 30 calendar days to submit a demonstration of compliance. Failure to provide the demonstration of compliance by the due date may result in a violation.

Freight contractors, brokers, and applicable freight facilities

The regulation requires freight contractors, brokers, and certain freight facilities to:

• Verify fleet compliance prior to doing business with companies or allowing them onto their property,
• Obtain copies of compliance documentation, and
• Maintain records of contracts with those they do business within California.