A Matter of Compliance

As the first deadline nears, operators in California are under pressure to bring their LSI fleets into compliance.


The recent monetary struggles plaguing aviation have left much of the industry captivated with cost containment. Yet looming environmental regulations have required GSE fleet operators to balance cost with ever more stringent emissions requirements. The impending large-spark ignition engine fleet regulation has put the pressure on operators in California to arrange their fleets to be in compliance by the end of the year.

Regulation Basics
“Most of the big airlines have already taken care of it. Some of the others have not,” says Dick Baxter, senior VP, planning and business development at Tug Technologies Corp., which offers LSI-compliant options for GSE fleets. “We’re talking to several ground handling companies right now that have come to understand the problem and are working toward fixing it.”

It is a compliance issue affecting fleets that contain 25-horsepower or greater engines fueled by gasoline, propane and CNG in the state of California. By Jan. 1, 2009, fleet operators are required to bring their forklift and nonforklift — including GSE — fleet averages to the emission requirements set forth by the California Air Resources Board (CARB). [see table 1 below]

Table 1
Fleet average emission Level Standards in grams per kilowatt-hour
(brake-horsepower-hour) of hydrocarbons plus oxides of nitrogen
 
Initial Compliance Date
Fleet Type
1/1/2009
1/1/2011
1/1/2013
Large Forklift Fleet
3.2 (2.4)
2.3 (1.7)
1.5 (1.1)
Medium Forklift Fleet
3.5 (2.6)
2.7 (2.0)
1.9 (1.4)
Nonforklift Fleet
4.0 (3.0)
3.6 (2.7)
3.4 (2.5)

Operators with four or more units of forklift and/or four or more units of nonforklift equipment driven by the applicable engines are subject to the regulation. Forklifts used for ground support operations must be calculated separately from GSE, meeting the forklift equipment requirement. The common pieces of GSE that might be affected and should be counted as nonforklift equipment include air starts, cargo tractors, aircraft and baggage tractors, and GPUs.

For fleet average calculations, CARB has devised a system based upon default emission rates for uncontrolled engines, retrofit verification and new engine certification standards. [See table 2 below]

Table 2
LSI Fleet Average calculation
Engine Model Year Emission Standard (g/bhp-hr)
2000 and older
12.0
2001 through 2003 noncompliant
12.0
2001 through 2003 compliant
3.0
2004 through 2006
3.0
2007 and later
2.0
2010 and later
0.6

To determine the emission standard of a certified engine, operators should consult the label, says Mark Williams, air pollution specialist at CARB.

“There will be incidences where (labels) will have been damaged or are missing,” he says. “In that case, if they have information on the engine family, they can get the standard from our online database. If they don’t have the engine family information and they have the serial number, they can get that information through the company they purchased the equipment from.

“And we are going to work to see if we can establish an online correlation for various manufacturers so that if you know the serial number, you can determine what the engine standard was,” Williams says.

Though there is no reporting requirement, operators are required to maintain records pertaining to their LSI fleets. Failure to comply with the LSI fleet regulation could carry a maximum penalty of $500 per day per unit.

Exceptions to fleet calculations
The regulation has included exclusions for certain classifications of equipment, including leased or rental equipment. To be eligible, the equipment must be rented or leased for less than a year and constitute less than 20 percent of the fleet. Also, according to Williams, the equipment must meet a 3.0 gram per brake horsepower hour standard by next January and a 2.0 gram standard by 2011.

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