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Navigating CARBs Diesel Vehicle Regulations

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Title: Navigating CARBs Diesel Vehicle Regulations


1
Navigating CARBs Diesel Vehicle Regulations
2
Current CARB Diesel Regulations
  • On Highway
  • Municipal and Utility vehicles
  • Solid Waste Collection Vehicles (SWCV)
  • Transit Bus
  • Port/Drayage trucks
  • Truck and Bus (Private Fleet Rule)
  • Off Highway
  • Mobile vehicles
  • Cargo Handling vehicles
  • Portable Equipment
  • TRUs
  • Locomotives
  • Agriculture
  • Marine
  • Commercial Harbor Craft
  • Ocean Going Vessels

3
Need for Emissions Reductions
  • Reduce Diesel Particulate Matter (PM)
  • Diesel PM responsible for 70 of known cancer
    risk from all air toxics
  • Reduce oxides of nitrogen (NOx)
  • NOx leads to ozone and secondary PM
  • Attain health based 8-hour ozone and PM2.5
    standards
  • Federal Clean Air Act
  • State Implementation Plan (SIP) - a master plan
    developed by ARB and districts that identifies
    how to meet federal clean air deadlines
  • Reduce greenhouse gas emissions (CO2)

4
On-highway Emissions Levels
5
Statewide Truck and Bus Regulation
  • Diesel trucks, buses, and shuttles traveling in
    CA
  • 14,000 GVWR and above
  • Interstate, Intrastate, International vehicles
  • Any person, business, or government agency who
    owns, leases, rents, or sells a vehicle in CA
  • Install PM controls in 2010 and 2011
  • Most vehicles equipped by 2014
  • Phase in 2010 model year engine equivalent
  • One turnover between 2012 and 2022
  • Exhaust retrofits if equivalent emissions

6
Statewide Truck and Bus Regulation
  • Any of 3 compliance options for PM or NOx
  • Best Available Control Technology (BACT)
  • Limits on turnover and retrofits
  • Fleet average
  • Exceptions
  • Emergency, military, tactical vehicles
  • School buses only subject to PM requirement
  • Personal use motorhomes

7
Truck and BusCompliance Option 1 BACT
  • PM BACT
  • Level 3 (highest level)
  • NOx BACT
  • 2010 MY emissions or better
  • 2004-06 MY w/ 85 NOx reduction
  • 2007 MY w/ 70 reduction
  • NO reporting required

8
Truck and BusCompliance Option 2 Turnover
Retrofit limits
  • PM BACT
  • Level 3 (highest level)
  • NOx
  • 2010 MY emissions or better
  • 2004-06 MY w/ 85 NOx reduction
  • 2007 MY w/ 70 reduction
  • Reporting required

9
Truck and BusCompliance Option 3 Fleet Average
  • Can be met by any method (PM, NOx, turnover)
  • Provides opportunity for NOx controls
  • Provides flexibility
  • Allows mix of cleaner and dirtier engines
  • Staggered start dates
  • PM begins in 2010
  • NOx begins in 2012
  • Each year, target (based on fleets makeup and
    emission factors) is lowered
  • Reporting required

10
Truck and Bus Special ProvisionsSmall Fleets
  • Applies to fleets of up to 3 vehicles
  • Exempt from performance requirements in 2010 and
    2011
  • First vehicle upgraded in 2012
  • 2004 emission engine with PM control exempt until
    2017
  • Remaining trucks upgraded 2013-2022
  • Provide additional time for 3 vehicle fleets
  • Subject to reporting requirements

11
Special ProvisionsExempt from Replacement
Requirements
  • Remain subject to PM requirements
  • Subject to reporting requirements

12
Truck and BusOther Special Provisions
  • Specialty farm vehicles exempt from PM until 2017
  • Vehicles used fewer than 1,000 miles and less
    than 100 hours per year are exempt from all clean
    up requirements
  • Vehicles operated exclusively outside
    non-attainment areas
  • Credits for hybrid vehicles expires in 2017
  • Subject to reporting requirements

13
Off-highway Emission Levels
20
90 reduction of NOx (1996-2007)
Unregulated level
54
15
35
10
Oxides of Nitrogen (g/bhp-hr)
40
Tier 1
50
5
Tier 2
?
Tier 3
Tier 4
0
1980
1985
1990
1995
2000
2005
2010
2015
2020
Year
14
Diesel In Use Off Road Regulation Overview
  • Regulation applies to any person, business, or
    government agency who owns or operates any
    diesel-fueled or alternative diesel fueled self
    propelled off-road vehicle within California
  • 25 horsepower
  • Applies to the drive engine only
  • Includes out-of-state vehicles brought into
    California
  • Excludes
  • Vehicles primarily used (gt 50 time) for
    agricultural operations
  • Vehicles used for personal use

15
Diesel In Use Off Road Regulation Overview
  • Reduce PM and NOx emissions
  • Restrictions on adding vehicles to fleet
  • No Tier 0 allowed after 3/1/2009
  • Can not add vehicles causing you to become non
    compliant
  • Labeling requirements
  • EIN (Equipment Identification Number), per engine
  • Idling Limits 5 minutes
  • Annual reporting requirements (DOORS)
  • Compliance options
  • Best Available Control Technology (BACT)
  • Limits on turnover and retrofits
  • Fleet average

16
Fleet Size Definitions Initial Reporting
Dates
Diesel In Use Off Road Regulation
  • Fleets must report their fleet information as it
    was on March 1, 2009

17
Diesel Off Road Compliance Option 1 BACT
  • If a fleet is unable to meet the emissions
    targets (Fleet Average method), they must use
    BACT
  • NOx BACT
  • Requires turnover/repower of 8 of total fleet Hp
    to meet NOx
  • PM BACT
  • Requires retrofitting of 20 of total fleet Hp to
    meet PM
  • Previously retrofitted engines, exempted
    vehicles, designated low use vehicles, etc., are
    not used in calculation
  • Carryover credits can be applied to future years
    compliance (in 2015 fleet must turnover more than
    10 to generate carryover credits)

18
Diesel Off Road Compliance Option 2 Fleet
Average
  • Medium and Large Fleets starting in 2010
  • Small fleets are subject to PM targets in 2015
  • Fleets must demonstrate that its Emissions Index
    is less than or equal to the calculated Emissions
    target
  • Emission factors based on engine Hp groups
  • Double Credit for early PM retrofits has been
    extended through 2009!
  • Can be applied to future years compliance

19
Diesel Off Road Compliance Option 2 Fleet
Average
  • Can be met by any method
  • PM and/or NOx retrofit
  • Repower, turnover, convert to low use
  • Provides opportunity for NOx controls
  • Provides flexibility
  • Allows mix of cleaner and dirtier engines
  • Specialty equipment that can not be
    retrofit/repowered may continue to be used in
    short/medium term (must be offset with other
    actions)
  • Each year, the target (based on fleets makeup)
    is revised (lowered)

20
Diesel Off Road Compliance Option 2 Fleet
Average
21
CARB Rule Compliance Tools
  • http//www.arb.ca.gov/diesel/mobile.htm
  • CARBs main fleet rule website
  • Access to all mobile rules, on/off highway,
    marine, etc.
  • Fleet Calculators available online
  • Can help fleets develop compliance plans for
    current and future years
  • Truck and Bus Version 4
  • Off Road revised 2/4/09
  • Online Reporting
  • Off Highway DOORS (Diesel Off Road Online
    Reporting System)
  • Emission Factor tables for On and Off Highway

22
3Rs Compliance Strategy
  • Retrofit
  • Can be the most cost effective compliance method
  • Allows continued use of existing vehicle/engine
  • Does not extend the useful life of vehicle
  • May still need to repower or replace in the
    future
  • Repower
  • Replace current engine with 2008 engine
  • Extends the useful life of vehicle
  • Requires significant application engineering
  • May not be cost effective for older equipment
  • Replace/Retire
  • Reduce size of your fleet, if using Average
    method
  • Replace vehicle with a newer used vehicle (with a
    retrofit) to extend final compliance
  • Replace with a 2007/8 model to be compliant with
    rule

23
2009 Tier 3 Engine Repowers
  • Installation/project feasibility considerations
  • How old is the equipment, and is it worth the
    investment?
  • How complex is the installation?
  • Drivetrain considerations
  • New Hp and Torque ratings
  • Cooling package Radiator and Charge Air Cooler
  • New engines typically require additional cooling
    Turbo configuration and exhaust routing
  • Will new exhaust and DPF cause clearance or
    interference issues?
  • Engine electronics compatible with
    chassis/transmission?
  • Cummins to Cummins or other make to Cummins?
  • How many identical trucks do you have?
  • Installation design engineering
  • Financing assistance? Ask us for more
    information!

24
Repower, Whats Involved?
  • Engine Selection
  • Application, Duty Cycle, Operational Environment
  • Performance Needs
  • Mounting - Will the new engine fit in the engine
    compartment? Mounts?
  • Drive considerations
  • Can existing drive handle new Hp/Tq? Try to match
    existing performance.
  • Will engine mount to existing drive?
  • PTO? Or auxiliary drives or pumps?
  • Flywheel modifications? Housing?
  • Cooling package Radiator and Charge Air Cooler
  • Higher heat rejection on new engines require
    greater cooling
  • Configuration, size and mounting
  • Other systems needing cooling transmission,
    torque converter, hydraulic pumps, etc.
  • Custom designed cooling package is typically
    required for off road repowers

25
Repower, Whats Involved?
  • Intake and Exhaust Systems
  • Intake routing, air cleaner size/type
  • Turbo configuration and exhaust routing
  • DPF or aftertreatment required?
  • Active/Passive? Clearance or interference issues?
    Radiant heat issues?
  • Electrical System
  • Are the new engine electronics compatible with
    chassis /transmission/drive system?
  • Charging / Starting system - New Alternator and
    Starter
  • Controls - Pedal, multiple or remote control
    panels
  • New custom engine wiring harness
  • Calibration may require tuning for engine
    speed, governors, throttle response, switches,
    custom applications, etc.
  • Cummins to Cummins or other make to Cummins?
  • Original engine specifications can help in
    ordering new engine configuration
  • Mounting? PTO? Other accessories?

26
Broad Product Range
  • Diesel engine range from 1.4 to 78-liters
  • 6.7 to 15 liter for On Highway
  • Hp ratings from 31 to 3,500
  • Natural Gas ISLG, up to 320 Hp

27
Exhaust AftertreatmentRetrofits
  • Cummins Cal Pacific is an authorized
    dealer/installer for the following DPF
    manufacturers
  • Cleaire
  • Johnson Matthey
  • DCL
  • Emission compliance and funding consulting
  • Custom engineered solutions for both on and off
    highway installations
  • In shop or in the field installation capability
  • 4 cleaning machines throughout our territory
  • Adding Level 2 cleaning machine in Q1 2009

28
Exhaust AftertreatmentRetrofits Things to
consider
  • Your emission compliance strategy
  • How does a DPF help your compliance?
  • Do you need NOx control?
  • Verified Product available?
  • Engine family number, Hp, application
  • CARB VDECS website, http//arb.ca.gov/diesel/verde
    v/vdb/vdb.php
  • Active or Passive regeneration?
  • Data logging / exhaust temperature profile
  • Is electric regeneration feasible? (equipment in
    the field)
  • Age / Value / Condition of equipment and engine
  • Financing assistance? Ask us for more information

29
CARB VDECS Database
30
Contact Information
  • Cummins Cal Pacific
  • 1939 Deere Ave.
  • Irvine, CA 92606
  • www.cumminscalpacific.com
  • Scott Ruhlen, Director of Business Development
  • scott.ruhlen_at_cummins.com
  • (949) 253-6042
  • Locations
  • Irvine Montebello
  • Bloomington El Cajon
  • Ventura Downey
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