California Announces the Opening of the Vehicle Fleet Reporting System for Entities with Operations in the State

Environmental Alert

(by Julie Domike and Gina Falaschi)

On January 15, 2020, the California Air Resources Board (CARB) announced the opening of the reporting system for the Large Entity One-Time Reporting Requirement for vehicle fleet owners. This reporting requirement was passed by CARB as part of its June 2020 adoption of the Clean Trucks Rule. As the California Office of Administrative Law (OAL) has not yet approved the regulation, businesses may voluntarily provide information at this time if they wish to begin the reporting process ahead of the April 1, 2021 deadline.

The Large Entity One-Time Reporting Requirement seeks to gather information about how medium- and heavy-duty vehicles are being operated by individual fleets and entities in order for CARB to: (1) determine where zero-emission vehicles may now be suitable; (2) identify the barriers to adoption of zero-emission vehicles; and (3) define necessary vehicle characteristics to meet different fleet needs.

Many businesses, organizations, and government entities must comply with this requirement on or before April 1. An entity must report if it operates a facility in California and: (1) had more than $50 million in revenues in 2019 from all related subsidiaries, subdivisions, or branches, and has at least one vehicle; (2) owns 50 or more vehicles; (3) dispatches 50 or more vehicles into or throughout California; or (4) is a government agency (federal, state, local, and municipalities) that has at least one vehicle. This reporting requirement applies to owners of on-road vehicles with a manufacturer gross vehicle weight rating (GVWR) greater than 8,500 pounds; light-duty vehicles, such as cars and small pick-ups, are not covered by this requirement.

The report must contain general information about the entity and its operations, as well as information about the vehicles it owns and operates. This includes basic information about the vehicles (including off-road yard trucks), home-base locations for vehicles, and how the vehicles are operated. Vehicle operation information includes vehicle body types, daily miles traveled, where vehicles are refueled, and other usage characteristics.

If you have any questions or need assistance determining whether your business must complete this filing, please contact Julie R. Domike at 202-853-3453 or or Gina N. Falaschi at 202-853-3483 or

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