Navigate new emission limits in trucking


Some trucking companies could soon face an uphill road to regulatory compliance. The California Advanced Clean Trucks (ACT) regulation now requires that half of heavy-duty truck sales in the state be fully electric by 2035, and that manufacturers start making zero-emission trucks in 2024.


Federal rules had already mandated that manufacturers start making zero-emissions trucks by 2027, with a target of 300,000 zero-emission trucks by 2035. California’s ACT regulation set a tighter timeline, which required approval by federal regulators. They approved it this spring, so the timeline is in place for any companies that plan to operate in California — and other states might follow suit.


The quick pace of the changeover could challenge transportation companies that have already been facing other financial and regulatory hurdles. By extension, those challenges could spill out to threaten many supply chains that only recently bounced back from pandemic-era disruptions.




Navigate the issues

Russell Norris

“You have to look at how you charge the vehicle, and the downtime of charging the vehicle. Do the electric grids and charging stations in place allow you to complete similar deliveries as to your historical network?”

Russell Norris

Grant Thornton Transportation Industry National Managing Partner 


The regulation emphasizes zero emissions, rather than just lowering emissions, so it pushes the industry toward electric vehicles. To make the shift to zero-emissions trucks, Grant Thornton National Managing Partner for Transportation Russell Norris, highlighted challenges that transportation companies must address:


  1. Technology: Companies need to determine how to adapt to electric truck technology, which has its own limitations. “For example, they may not have the battery-powered longevity to complete a haul similar to what a current tractor-trailer would be able to accomplish,” Norris said. “You have to look at how you charge the vehicle, and the downtime of charging the vehicle. Do the electric grids and charging stations in place allow you to complete similar deliveries as your historical network?”
  2. Cost: The transition to electric will come with a cost for companies, and the industry is currently experiencing a cyclical downturn. “It's not that there's a lack of motivation to improve emission standards, but the economics of the industry are cyclical, and we just so happen to be in a downturn,” Norris said. “The industry has significant recessionary pressures, and is navigating through a very challenging 2023, so having to suddenly spend on this type of equipment is exceptionally difficult.”
  3. Time: The regulation requires capital expenditures, often with long lead times, approaching a year. Given the expense associated with both the trucks and the necessary infrastructure, companies will struggle to fund and implement these changes within a short timeline. Smaller carriers could be disproportionately affected.

These issues can be further complicated by another California regulation passed in 2020, the Assembly Bill 5 (AB5) law, or “gig worker” law, that limited how trucking companies can work with independent drivers. “It basically said that independent drivers need to be treated as employees,” Norris said. He explained that some California transport companies have not owned trucks because they relied on independent drivers. However, they are now required to hire those drivers as employees. “Many of these employee drivers don’t have equipment, so the companies are having to invest in equipment now, just to change the employment model,” Norris said.




Consider the options


To try to meet the new regulatory timelines, companies need to be strategic and quick. Larger companies are already making investments, and companies of all sizes should consider how they can start to adjust.

Russell Norris

“It's a lot of costly equipment, and some of the costs are unknown at this point.”

Russell Norris

Grant Thornton Transportation Industry National Managing Partner 

  1. Reallocate cash: To address cost and time issues, companies need to forecast and budget for the changes and enforcement on the horizon. “It's a lot of costly equipment, and some of the costs are unknown at this point,” Norris said. However, companies need to do what they can to “plan from a cash flow perspective aiming for compliance, or determine whether the networks you're currently doing business in will make sense longer-term.” To stay updated and budget accordingly, look for ways to inform or be informed by the regulations in process. “It’s clearly best if you can get involved in the regulatory discussions, to understand where this is going to go from a timeline perspective — to appropriately plan for the needs that you're going to face to have your fleet compliant.”
  2.  Replan routes: To address the technology and cost issues, some companies are already re-planning routes around the restrictions of zero-emissions trucks. “Some of the larger carriers are starting to invest in some of this equipment and test it on their normal transportation patterns right now, trying to figure out, ‘If our typical length of haul is X miles, here's what we can do. Here's how we're going to have to adjust to meet these criteria into the future,’” Norris said. “Especially for those that have a terminal network, or are contracting with customers in different areas within these networks, it's a question of how far that length of haul should be. It’s really helpful to have the ability to go through the testing and develop a longer-term vision of how this is going to look.”
  3.  Redraw territories: To address the cost and time issues, companies might need to reconsider where to (or not to) operate. “In some cases, we've seen carriers say, ‘We're going to shift around our direct network, and start using other carriers to achieve those goals,’” Norris said. “In some cases, carriers are selling California property,” Norris said, adding that other carriers are forming partnerships or networks to maintain nationwide coverage. “I think it's about forming the networks — deciding really what's realistic for you and your company, based on your size and goals, and building out that framework.” On the other side, some companies could see new opportunities as competitors abandon jurisdictions they currently serve.

Prepare for the next phase


The shift to zero-emissions trucks is already having a large impact on the industry, and that impact will change over time. “This could pull carriers away from the states requiring these changes, creating supply chain disruptions,” Norris said. “You’ll simply have fewer carriers in those areas.”


As carriers, territories, supply chains and even customers shift, transportation companies need to stay informed and think strategically about where to invest for both regulatory compliance and long-term business success.






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