Washington Report: New Heavy-Duty Truck Emission Standards and Concrete Pumps

by Patty Power, ACPA Washington Advocate

ACPA has been navigating the very complicated world of clean air emission standards set by the Federal Environmental Protection Agency (EPA) and state environmental departments, most notably the California Air Resources Board (CARB). Significant emission standard reductions are now in place and more are expected over the next three years. Existing and expected reduced emission standards at the state and federal level will impact every concrete pumper in the near future.

Typically, EPA and CARB work together to synchronize their standard-setting to provide industry with clear, well-defined and coordinated standards. CARB directly oversees the California market, which is large enough to drive vehicle manufacturers’ decision-making. However, other states’ environmental regulators regularly adopt CARB standards and regulatory approaches. Thereby, the scope of the impact of CARB’s decisions is much broader than the California market, many times becoming the model for the national EPA standards. EPA and CARB emission standards and implementation plans differ in new NOx and the greenhouse gas emission (GHG) standards, making this already technically challenging set of rules even more confusing.

This Washington Report will explore the “who, what, when, where and how” of the EPA and CARB emission standards changes to heavy duty trucks. In a nutshell:

• Who — must comply? Original engine manufacturers (OEMs) must comply with EPA emission standards – engine OEMs for NOx and truck OEMs for EPA GHG Heavy Duty Truck Phase 3 rule (GHG); Engine OEMs must comply with CARB Heavy Duty Omnibus (Low NOx) rule; and fleet operators must comply with the CARB Advanced Clean Fleet (ACF) rule (GHG).
• What — must be complied with? Reduction of NOx and GHG emissions to new EPA and CARB standards.
• When — to comply? CARB NOx starting in 2024; EPA NOx starting in 2027; CARB ACF starting in 2024 through 2045; EPA GHG starting in 2027 through 2032.
• Where — do the new emission standards apply? EPA standards apply nationwide; CARB standards apply in California plus other the other states that adopt the CARB standards. See States that have adopted CARB vehicle standards for current lists.[i]
• How — can new standards be met? Change heavy duty truck engine configurations for new NOx standards and change composition of fleets (expand low emission vehicle (LEV) use) for GHG standards.

Bottom line is that both NOx and GHG reduced emission requirements will impact all concrete pump companies by 2027. The CARB ACF standards will apply directly to concrete pumps in California and in states that have adopted the CARB standards starting in 2024. The CARB Low NOx standards will apply to engine OEMs in California and in states that have adopted these CARB standards starting in 2024. Starting in 2027, the EPA Greenhouse Gas Heavy Duty Vehicle standards will apply to truck OEMs and the EPA Heavy Duty Engine and vehicle standards (Low NOx) will apply to engine OEMs. Whether these new standards apply directly to concrete pump fleets or to the manufacturers of concrete pump engines or concrete pump trucks, all of these rules will have an impact on all concrete pump companies planning to buy or sell equipment in the future.

We heard at the 2024 World of Concrete seminar that EPA is looking to the truck OEMs to meet emission averages. The challenge is for concrete pump truck OEMs to keep producing diesel-powered concrete pumps while meeting their overall ZEV production requirements. EPA’s proposed standards will impact concrete pump companies indirectly by possibly creating pressure on the truck OEMs to produce fewer concrete pumps. EPA has not yet issued the final rule and we understand that they are working with the truck OEMs to address these concerns.

The CARB ACF rule includes the zero emission vehicle (ZEV) Purchase Exemption List that will be posted on the CARB website by January 1, 2025 for specific vehicles currently not configured to support zero-emission technology. Concrete pump fleets can apply to CARB for a ZEV purchase exemption[ii]. ACPA will work with all members who need to navigate this process.

ACPA will continue to work with our truck manufacturers and industry partners to ensure that the federal and state regulators understand and address the needs of concrete pumps.