California's Off-road Diesel Regulation Moves Forward

As of March 1, medium and large fleets must have a written idling policy. (A fleet owner may apply for a waiver to allow additional idling.) ARB doesn’t mandate what needs to be included in an idling policy, but a guidance document is available at www.arb.ca.gov/msprog/ordiesel/guidance/writtenidlingguide.pdf.

“Besides making sure that the operators understand the idling requirements, owners will want to protect themselves in case operators don’t comply intentionally,” White says. “There should be a corrective action procedure in a written idling policy that says, ‘If you’re caught by the company not complying, here’s the consequence.’ ”

INITIAL AND ANNUAL REPORTING
The next deadline approaching is April 1. By that date, large fleets (with a combined horsepower of more than 5,000) must have completed initial reporting. ORD has different reporting deadlines for different fleet sizes. Medium fleets (2,501 to 5,000 hp) must complete reporting by June 1, and small fleets (2,500 or less) must complete reporting by Aug. 1. There are exemptions for inclusion in total fleet horsepower, such as low-use vehicles (operated less than 100 hours per year).

ARB’s Diesel Off-Road On-Line Reporting System (DOORS) (https://secure.arb.ca.gov/ssldoors/doors_reporting/reporting.php) is the primary reporting tool for initial and annual reporting.

The information that initially needs to be reported is substantial. Making sure that information is complete will ensure that fleets owners receive credit for every effort that they make to meet or exceed the performance requirements. Fleet owner, vehicle and engine information need to be entered. If there’s a retrofit, or if a diesel vehicle was replaced by a non-diesel vehicle, or if there’s a stationary or portable system like a conveyor belt that replaced one or more diesel vehicles, that information needs to be included. Any early credit actions (e.g., surplus repower to a higher tiered engine, early retrofits, or a vehicle retired early) also need to be reported.

After the fleet inventory is provided to ARB, each vehicle will receive an ARB-assigned engine identification number (EIN) and the numbers must be on the vehicles 30 days from when they are received.

“If any owners have not yet started to gather data from their engine tags for the reporting requirement,” SkyWest Airlines supervisor of environmental compliance Toby Steele emphasizes, “they should get started now.”

The process can be difficult depending on the age and condition of the engine.

“Some brands will have all the needed information on the engine tag. Others won’t, so you will have to request help from the engine manufacturer to complete your database,” he says.

PERFORMANCE REQUIREMENTS TO REDUCE EMISSION
Following the idling and initial reporting deadlines, feet operators must meet the performance requirements to reduce emissions.

Beginning in 2010, large fleets must meet the fleet average emission rate target for PM — or apply the highest level verified diesel emission control system to 20 percent of its total horsepower. In addition, large fleets must meet the fleet average emission target for NOx or turn over a percentage of its horsepower: 8 percent until 2015, and then 10 percent thereafter.

Medium fleet requirements start in 2013, but are otherwise the same as large fleet requirements. Small fleet requirements start in 2015, however, operators only have to meet the PM requirements.

In all fleet-size categories there are exemptions. For example, vehicles less than 10 years old are exempt from the turnover requirements, and engines in vehicles less than five years old are exempt from the exhaust retrofit requirements.

Fleet average emission targets can be met with different options:

• installing exhaust retrofits that capture pollutants before they are emitted to the air,
• repowering vehicles with newer, cleaner engines,
• rebuilding engines to a more stringent emissions configuration or
• retiring older vehicles and accelerating turnover of fleets to newer, cleaner engines.

Based on input she’s received so far, White says GSE fleet managers predominantly will turn to electric equipment to meet ORD requirements.