LSI Update: New Advisories

Emissions regulations are some of the most pressing issues facing fleet managers. As new notifications are issued, managers must stay informed of the changes. The California Air Resources Board has recently issued additional advisories to the large-spark ignition engine regulation.

Equipment Exclusions
In April the Board announced it would allow fleet operators to exclude equipment that is greater than 3 liters from the fleet average emission level (FAEL) calculation until April 15, 2010. According to Mark Williams, air pollution specialist at CARB, the reason behind the advisory was that there were not as many compliance options available for that type of engine. The only retrofit kit available for greater than 3-liter propane-fueled engines, was verified at 3.0 g/bhp-hr.

“We thought that was going to make it difficult for operators with a large number of 6-cylinder engines in their fleet to achieve the fleet average emission level standards,” he says. “So we allowed fleet operators to exclude those greater than 3-liter engines for a year.”

After April 15, 2010, Williams says, retrofit kit manufacturers are expected to offer cleaner options. In fact, not long after the advisory was issued, a retrofit kit for the engines was verified at 2.0 g/bhp-hr. Also, as of Jan. 1, 2010, all new LSI engines will be required to meet a new 0.6 g/bhp-hr standard.

Additionally, CARB announced it would allow fleet operators to use the standard associated with either a verified retrofit kit or a certified new piece of LSI equipment in place of the default emission rate for the uncontrolled piece of equipment being retrofitted or replaced in the FAEL calculation, as long as the purchase order for the retrofit kit or new piece of equipment is placed by the April 15 deadline — but the retrofit or new piece of equipment must be incorporated into the fleet by Dec. 31.

“There were some folks in the ground support equipment arena that were impacted by that advisory, because they had (greater than 3 liter) ground support equipment that was propane-fueled,” Williams says. “So there are folks that we’d been dealing with that had been asking us for additional time to comply. This exclusion provides them that additional time.”

There is an additional exclusion period included in the advisory for fleets that, as of Jan. 1, 2009, were fully comprised of late model year emission-controlled equipment. Leased and owned fleets could be excluded from the fleet average calculation until April 15, 2010.

“Right now there are no retrofit kits available for already emission-controlled equipment,” Williams says. “We expect that will happen by next year.”

But, he says, the Board will revisit the exclusion prior to the deadline next year to evaluate the possible need for an additional extension.

Upcoming Advisory
According to Williams, the Board will be issuing an additional advisory that will include the following items:

  • Steps for demonstrating a piece of equipment is retired: The steps will include removing the propane tank, draining the oil pan, removing the steering wheel; installing an hour meter on the device if it is not already equipped; and keeping a record of usage on a quarterly basis. Additionally, there should be lockout/tagout procedures to ensure only a limited number of people have access to the key.

“The reason that we need demonstration procedures is that we used to have what could be considered pretty onerous requirements for retirement. And that was that the piece of equipment would have to either have the engine block drilled or the engine removed from the piece of equipment and that pretty much destroys any economic value of the equipment,” Williams says, adding that the new procedures will allow more flexibility. “What that allows is that if an operator has a piece of equipment that they’re contemplating scrapping or retiring out of state and they’re just in transition and it’s just onsite — they don’t have to worry about including it in their fleet size determination. They can just be able to annotate that (it’s retired) in their records and exclude it.”

  • Clarification for the use of electric equipment: According to Williams, there has been confusion regarding the stipulation that an operator must demonstrate that electric-powered equipment of less than 19 kilowatts performs the work equivalent of LSI engine-powered equipment. “Typically, electric equipment and electric forklifts have separate motors — they have drive motors and they have lift motors for the mast. Because they are splitting the work, neither of those motors are greater than 19 kilowatts,” he says. “For the most part, any class 1 or 2 electric equipment is eligible to be included in the fleet average calculation.”

  • Continued exclusion of gasoline-fueled GSE from the LSI fleet average calculation: In December 2008, CARB released LSI Program Advisory 08-02. It allowed GSE operators to exclude gasoline-fueled pieces of GSE from FAEL calculations performed for the purposes of determining compliance with the Jan. 1, 2009, FAEL standard because appropriate retrofit kits had not been verified by Jan. 1, 2007. The upcoming advisory allows GSE operators to continue to exclude their gasoline-fueled pieces of GSE from FAEL calculations until Jan. 1, 2013, because appropriate retrofit kits had not been verified by Jan. 1, 2009.

Stay Informed
To read the latest updates to the advisory and view an LSI tutorial, visit: http://www.arb.ca.gov/msprog/offroad/orspark/orspark.htm

To join the e-mail list to receive updates to the advisory in your inbox, visit http://www.arb.ca.gov/listserv/listserv_ind.php?listname=orspark

Frequently Asked Questions: http://www.arb.ca.gov/msprog/offroad/orspark/documents/faq7_08.pdf

For questions, contact Mark Williams at mwilliam@arb.ca.gov or 916-327-5610.

Extended Verification for Propane Retrofit Kits
Nett Technologies Inc. has two retrofit kits available for less-than and greater-than 3-liter engines that were originally verified for model year 1990 engines and newer. CARB has granted the kits extended verification for 1980 and newer LSI overhead valve engines.

“There are certain technical aspects that need to be met, but it basically allows retrofit kits up to 10 years older than what we were allowing before,” Williams says.

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