A Matter of 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.

The regulation has also allowed for the exclusion of limited-hours-of-use equipment from fleet calculations until 2011 if the unit is used 250 hours or less per year. According to Williams, the unit must be equipped with an hours-use meter and the hours must be recorded.

Williams says an important facet of the regulation for fleet operators is concerning on-road equivalent GSE, which have specifically assigned emissions standards included in the regulation that should be used to calculate the average.

Compliance Options
There are a number of options that fleet operators can consider to get their fleets into compliance, including replacing, repowering or retrofitting equipment. With the regulation set to become stricter in the future — including GSE that must meet a fleet average of 2.5 grams per brake horsepower hour by 2013 — the option that makes economic sense in the long term is going to determine the right path for fleet operators.

Tug Technologies is one company that offers regulation-compliant equipment, including electric tractors and belt loaders. The company also offers a Ford 2.3 liter engine for tractors and belt loaders that is available as a repower kit, featuring a standard of .82 grams per brake horsepower hour.

Another option for fleet operators of uncontrolled and noncompliant engines is retrofit kits. Engine Control Systems, which produces the TermiNOx retrofit kits verified for LSI forklift equipment, has the only verified kit under the LSI regulation for 3-liter and larger propane engines of GSE. The technology is verified at a standard level of 3.0 grams per brake horsepower hour, allowing operators to trim their emissions to meet the 2009 requirement. According to Kevin Brown, regulatory affairs manager at Engine Control Systems, the basic cost runs approximately $3000 to $3500 per unit. “So even getting the 3 is going to buy you at least three years time — enough to plan your retirement of the fleet or what you might do,” he says.

Nett Technologies Inc. also has verified retrofit technology for forklifts. According to Wayne Borean, OEM sales coordinator at Nett Technologies, the company is still in the throes of the verification process for its propane GSE retrofit kit for 3-liter and larger propane engines. He says the company should complete the process by November and has aimed for verification at 1.0 grams per brake horsepower-hour. Borean says the kit itself would cost approximately $3300 for each unit.

Though fleet operators have the option of converting gasoline engines to propane in order to be retrofitted, Williams says there are currently no verified gasoline-engine retrofits available. And thus, he says, fleet operators can apply for a compliance extension for those engines that would be valid until Jan. 1, 2011.

The right fit
Toby Steele, compliance manager at SkyWest Airlines, which operates out of several California locations, says the airline’s GSE fleet was not subject to the regulation, but its fleet of roughly a dozen forklifts was affected. “What happened to us is all of our engines were pretty old, so the highest rating you could get was 12 and all of my engines were 12s,” he says.

After researching possible options, Steele says the airline decided to go electric, replacing its fleet with refurbished electric units at a price between $15,000 to $18,000 each. “It was a little bit more than new engines would have been or the retrofit, but we’re good now for good,” he says.

Though electric is a viable option for coming into LSI compliance, as they can be counted in the fleet average, Williams says fleet operators should be aware of the off-road diesel rules. “There’s some interaction between this rulemaking and the in-use off-road diesel rulemaking. And that interaction is that both rules allow operators to use electric equipment to comply with the regulation … you can use any given piece of electric equipment or GSE to comply with either the LSI regulation or the off-road diesel fleet regulation but not both,” he says.

Down to the Wire
With the initial compliance date rapidly approaching, there is a question of how many fleets are ready or taking the appropriate measures.

Tim Pohle, managing director of US environmental affairs and assistant general counsel at Air Transport Association, which played part in the LSI rulemaking, says its members have been made well aware of the regulation. “I know all the carriers in our group have been familiar with this and planning for it for a long time,” he says.

Yet, there is lingering doubt that all fleets will be ready come January. “One of the concerns we have is that this thing is coming up so fast that we think when everybody figures this out in November, people are going to be going crazy and nobody will be able to help them because it will be too late,” Baxter says.

For more information on the LSI regulation, visit the following:
LSI regulation homepage
www.arb.ca.gov/msprog/offroad/orspark/orspark.htm

List of verified retrofit kits available
http://www.arb.ca.gov/msprog/offroad/orspark/verdev.htm

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

California Air Resources Board engine emission standards Database
http://www.arb.ca.gov/msprog/offroad/cert/cert.php

List of included GSE
www.arb.ca.gov/msprog/offroad/gse/appendix-2-final.pdf

Or contact…
Mark Williams at 916-327-5610 or mwilliam@airb.ca.gov

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