title
Zero Emission Vehicle Exemption Request - Deputy Director Riske-Gomez
end
Requested Action(s)
recommendation
Adopt Resolution No. 01-2026 Authorizing the Submittal of a Zero-Emission Bus Purchase Exemption Request Pursuant to the Innovative Clean Transit Regulation, authorizing the Executive Director, or designee, to advance a request to the California Air Resources Board (CARB) for an exemption from Zero-Emission Bus (ZEB) purchase requirements under Title 13, California Code of Regulations §2023.4(c).
body
Financial Impact:
None at this time.
Adoption of the resolution does not commit the Agency to vehicle procurement or infrastructure investment. Approval preserves TRAX’s ability to replace vehicles using conventional propulsion where zero-emission alternatives are not currently feasible, thereby avoiding unplanned capital and operational costs.
Background Information:
The California Air Resources Board (CARB) adopted the Innovative Clean Transit (ICT) Regulation to transition all public transit fleets to zero-emission buses by 2040. Beginning in upcoming procurement cycles, the regulation requires transit agencies to purchase zero-emission buses unless an exemption applies.
The ICT Regulation explicitly allows Small Transit Agencies to request exemptions from zero-emission bus purchase requirements when specific conditions exist, including infrastructure delays, operational infeasibility, vehicle unavailability, and financial hardship (13 CCR §2023.4(c)).
The Tehama County Transit Agency Board (TCTAB) operates the Tehama Rural Area eXpress (TRAX) system, a rural transit network characterized by long service distances, high daily mileage, extreme weather conditions, limited utility infrastructure, and constrained funding typical of FTA Section 5311 operators.
After reviewing fleet replacement schedules, operational demands, available vehicle technologies, and facility conditions, staff has determined that TRAX currently qualifies for multiple exemption categories under the ICT Regulation.
Consistent with CARB guidance and recent precedent established by other California transit agencies, including the City of Clovis, staff has prepared an exemption request supported by a Board resolution and formal submittal letter.
The exemption request is based on the following findings:
1. Infrastructure Delay (13 CCR §2023.4(c)(1))
TRAX does not have existing zero-emission charging infrastructure, nor sufficient electrical capacity at its operations facility. No utility load assessment, infrastructure design, or funded construction project is currently in place. Significant planning, coordination with PG&E, and capital investment would be required before zero-emission buses could be safely deployed.
2. Daily Mileage and Operational Requirements (13 CCR §2023.4(c)(2))
TRAX buses routinely operate extended daily service blocks typical of rural systems, frequently exceeding 120-180 miles per day. Current zero-emission cutaway bus technologies have not demonstrated the ability to reliably meet these mileage requirements under real-world rural operating conditions, particularly when accounting for HVAC loads, terrain, and lack of en-route charging.
3. Route Feasibility and Vehicle Availability (13 CCR §2023.4(c)(4))
At present, there are no Altoona-tested zero-emission cutaway or medium-duty vehicles in the Class 5-6 range capable of meeting TRAX’s passenger capacity, range, and duty-cycle needs without reducing service reliability or coverage.
4. Financial Hardship (13 CCR §2023.4(c)(5))
TRAX is funded primarily through FTA Section 5311 Rural Formula Funds and limited local match. The cost of zero-emission buses, charging infrastructure, facility upgrades, and utility improvements would impose a significant financial burden and could jeopardize the Agency’s ability to maintain essential transit service.
These conditions closely mirror those cited in the City of Clovis ICT exemption approval, which CARB has accepted as a valid basis for relief under §2023.4(c).