CARB Mobile Sources: Off-Road Diesel Equipment Yorke Engineering, LLC www.yorkeengr.com Office Locations: Los Angeles, Orange County, Riverside, Ventura, San Diego, Fresno, Berkeley Tel: (949) 248-8490 Fax: (949) 248-8499
Yorke Engineering, LLC Yorke Engineering was founded 20 years ago in 1996. Yorke Engineering has worked for over 600 customers at well over 1,000 facilities. Completed over 5,000 Air, Water, and Waste Environmental Projects. 2
Yorke Engineering Offices Bay Area San Joaquin Valley Ventura County Los Angeles County Riverside County Orange County San Diego
Yorke Presenters Harmony Gates: MS in Chemical Engineering, CalTech Ms. Gates has been working with CARB Mobile Sources regulations since 2009 when compliance requirements began. Jeremy Howes IT Manager 4
5 Using GoToWebinar Webinar window We have everyone muted. Please use questions window: We will e-mail you if your question is not answered in the webinar. Polling question: Helps us provide appropriate content. 5
California Air Resources Board (CARB) Off-Road Diesel In-Use Regulation Definition & Applicability Requirements Reporting Equipment Labeling Performance Standards (Fleet Average / BACT) Example Fleet Calculations Adding Equipment Restriction Low Use & Rental Provisions Idling Restriction 6
Off-Road Applicability Diesel and alternative diesel fueled vehicles that are: Off-road & Self-propelled (no portable equipment!) 25 horsepower or greater Operate within California 7
What is an Off-Road Diesel Vehicle? Included: Equipment with an off-road engine Workover rigs 2-engine cranes 2-engine vehicles (with an integrated auxiliary engine >50hp) see www.arb.ca.gov/msprog/ordiesel/faq/twoengine-vehicles.pdf Some Yard Trucks/Goats/Jockeys off-road types that do not operate at a Port/Intermodal Rail Yard or for Agricultural Operations. See www.arb.ca.gov/msprog/ordiesel/faq/faqyardtrucks.pdf 8
What is Not an Off-Road Diesel Vehicle? Excluded: Equipment used 100% for Agricultural Operations Equipment at Ports or Intermodal Rail Yards that are subject to the Cargo Handling Equipment Regulation. Vehicles with engines manufactured for on-road, regardless of use. For example, a DMV non-op Water Truck operated only at facility is not off-road (and instead is subject to an on-road regulation). 9
Common Facility Equipment 10
Determining Fleet Size Add up all diesel off-road horsepower Include all vehicles under common ownership or control Exclude: Low use vehicles (operate < 200 hrs/year) Dedicated Emergency vehicles Dedicated snow removal vehicles Vehicles used > 50% of the time for agricultural operations 11
Poll #1 How many do you own? How many off-road diesel vehicles do you own? 1-5 5-10 10-20 21+ Don t know 12
Poll #2 How large is your fleet? What is the sum of horsepower of all your off-road vehicles? More than 5,000 hp 2,501 5,000 hp 2,500 hp or Less 13
Fleet Size Categories Large: >5,000 hp; or Any size Government fleet Medium: 2,501 to 5,000 hp Small: < 2,500 hp; Any size fleet in Captive Attainment area; or Any size fleet that is a local municipality in low population county 14
Compliance & Reporting Dates Fleet Size Category Annual Reporting** Dates (Mar 31) Performance Dates (Jan 1) Large: >5,000 hp or government fleet 2012-2023 2014*-2023 Medium: 2,501 to 5,000 hp 2016-2023 2017-2023 Small: < 2,500 hp or fleet in Captive Attainment area or local municipality in low population county 2018-2028 2019-2028 **Baseline Fleet reporting was due in 2009 *Enforcement on performance requirements began July 1, 2014. Information based on the approved Dec 2011 amendments to the Off-Road regulation and Mail-Out MSC1401. 15
Diesel Off-Road Online Reporting System (DOORS) Register all off-road diesel equipment Equipment: Type/Make/Model/Year/Serial # Engine: Make/Model/HP/Year/Serial #/Engine Family https://ssl.arb.ca.gov/ssldoors/doors_reporting/doors_login.html 16
Annual Reporting Responsible Official Affirmation of Reporting (ROAR) form Due by March 1 of each reporting year and annually thereafter for each year compliance must be demonstrated (ex, low use) Sign and email to DOORS@arb.ca.gov 17
Diesel Off-Road Labeling Equipment Identification Number (EIN) Both Sides 3in tall x 1.5in wide minimum size Most Facilities White on Red background Captive Attainment Areas White on Green 18
Performance Requirements For each compliance year (based on fleet size), a fleet will need to comply in one of 2 ways, each of which are specific to the fleet s composition: Fleet Average < Fleet Average Target Rate; or BACT* credits > BACT requirements. *Best Available Control Technology 19
Fleet Average Compliance Option Fleet Average < Fleet Average Target Rate Fleet Avg = SSSSSS HHHH EEEE FF VVVVVVVVVV eeeeeeeeeeee SSSSSS (HHHH eeeeeeeeeeee ) Fleet Avg Target = SSSSSS HHHH TTTTTTTTTTTT eeeeeeeeeeee SSSSSS (HHHH eeeeeeeeeeee ) HP is the maximum horsepower per engine Emission Factor (EF) based on engine year and size (HP) F VDECS is the emission reduction factor for a Verified Diesel Emission Control Standard (VDECS) (i.e. a filter) 20
Fleet Emission Rates Used for Fleet Average Targets Fleet Targets (g/bhp-hr) for each Max HP group 21
BACT Compliance Option Fleet Size Due Date (Jan 1) BACT Percentage 2014 4.8 % Large 2015-2017 8 % 2018-2023* 10 % Medium 2017 8 % 2018-2023* 10 % Small 2019-2028* 10 % Some early emission reductions generated BACT credits BACT credits can carryover into future years Must turnover Tier 0 and Tier 1 engines first. *After final compliance date, continue to clean up fleet at 10% per year until Fleet Average < Fleet Average Target 23
Options for Improving Fleet Average and/or Generating BACT credits Retrofit (VDECS/filter) Turnover options Retire (sell, scrap, move out of CA) Reduce to Low Use (<200 hr/yr)* Repower an engine to cleaner emission standard *Not all Low Use equipment generate BACT credits 24
Example Fleet 25
Example Compliance Options Must EITHER Improve Fleet Avg or meet BACT Can improve Fleet Average by reducing emissions on enough engines until meet Fleet Average Target; OR Can meet BACT by turning over 279 hp (3485 x 8% = 279 hp) 26
Example Improve Fleet Average For Ex: Year-by- Year Low Use Equip and Replace equip with cleaner Tiers 27
Example Meet BACT For Ex: Repower 300 hp 28
Yorke vs CARB Fleet Tools Compliance Tool Feature Fleet Average Calculations BACT vs Fleet Avg Yearly Planning Inventory Tracking Low Use Tracking YORKE Tool CARB Tool 29
Other Requirements: Sales Disclosure Requirement When selling Off-Road Diesel equipment, you must include Sales Disclosure statement and keep records 3 years: When operated in California, any off-road diesel vehicle may be subject to the California Air Resources Board In-Use Off-road Diesel Vehicle Regulation. It therefore could be subject to retrofit or accelerated turnover requirements to reduce emissions of air pollutants. For more information, please visit the California Air Resources Board website at http://www.arb.ca.gov/msprog/ordiesel/ordiesel.htm. 30
Other Requirements: Adding Equipment Chart shows the minimum tier engine that may be added by a fleet beginning Jan 1 of given calendar year. Adding Vehicle Requirements by Fleet Size & Calendar Year (Minimum Engine Tier Allowed to be Added to a Fleet) 31
Other Requirements: Adding Equipment (Cont.) Meet the minimum tier requirement for adding equipment Add to DOORS within 30 days of purchase EIN will be assigned within DOORS Label both sides within 30 days of EIN assignment 32
Other Requirements: Low Use Equipment Operate < 200 hours/year Equipment must have non-resettable hour meter. If reported as low use, exempt from turnover (upgrade) requirements Excluded from both fleet size determination and Fleet Calculations. Report hour meter information in DOORS each year it is classified as low use. 33
Other Requirements: Low Use Equipment Options Year-by-Year Operated <200 hours in previous calendar year (or <600 hr in 3 years) Can be operated more than 200 hours in future years 34 Permanent Low Use Limits future operations to <200 hours in future years Receive BACT credits* Must meet Adding Tier Restriction to be operated more than 200 hours/year *If designated after beginning annual reporting
Other Requirements: Diesel Off-Road Rentals In owner s fleet by default In operator s fleet only if either Rental began before 6/15/2008 and was for one year or more, or Specifically indicated in rental contract. 35
Other Requirements: Idling Restriction for Diesel Off-Road Equipment No engines may idle for more than 5 consecutive minutes. Idling does not apply during some operations (e.g. queuing, testing, servicing, repairing, etc.) Idling of a rental is the responsibility of the operator. A written idling policy is required for medium & large fleets as of 3/1/2009. Title 13, CCR Section 2449(d)(2) 36
Questions? CARB Webinar Questions Harmony Gates (909) 861-2729 HGates@YorkeEngr.com Other General Environmental Questions Brian A. Yorke Operations & Marketing (949) 248-8490 x228 BYorke@YorkeEngr.com 37
Yorke Engineering Upcoming Classes on Yorke Website Air Quality, Permitting & Compliance SCAQMD March 15-16, 2017 Anaheim SJAPCD March 28-29, 2017 Fresno BAAQMD April 4-5, 2017 Emeryville CA Waste and Water Regulations Bay Area March 21-22, 2017 Emeryville Los Angeles April 11-12, 2017 Anaheim http://yorkeengr.com/classes/ 38