Environmental regulations: A look at what CARB is doing and planning

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Since its founding some 40 years ago, the California Air Resources Board (CARB) has worked to find solutions to California's air pollution problem. It has been busy for the past few years taking aim at the trucking industry.

Among other things, it is has established anti-idling rules and is pushing ahead with regulations governing diesel-fueled transport refrigeration units and generator sets, even though these measures have not been federally approved. In addition, in October, it will begin two new clean air initiatives.

In his presentation, Deciphering CARB's Environmental Regulations, American Trucking Associations director of environmental affairs Mike Tunnell gave an overview of what is currently going on, and what lies ahead.

He began by noting that the first compliance phase of the CARB's Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Gen Sets, and Facilities Where TRUs Operate will take effect at the end of this year. “Adopted in 2004 before the state's ozone implementation plans were put in place, it is purely focused on particulate matter (PM).”

CARB needs federal approval to put this regulation, commonly referred to as TRU ATCM (Airborne Toxic Control Measure), in place because it established new engine standards,” Tunnell pointed out. “It was submitted for approval to the US EPA in 2005, and it's been there ever since.”

Basically, there are two parts to the regulation. Facilities with 20 or more doors serving refrigerated areas were supposed to have registered with CARB by January 2006.

The second part is the initial phase for TRU ATCM compliance. It requires owners and operators of TRU and TRU generator set engines that operate in California to meet in-use performance standards, starting December 31, 2008, and to meet reporting requirements in January 2009. This affects TRUs on trailers, trucks, railcars, and shipping containers.

TRU compliance

“Both of these requirements are pending EPA approval,” Tunnell noted, “which has not been granted.”

This first compliance phase mandates that any TRU model 2001 and older must have 50% PM emission controls. Compliance gradually increases for various model years to 2013 engines, which are considered compliant.

Compliant options, said Tunnell, include operating a TRU seven years old or less, repowering with an 2008 engine or an engine less than seven years old, retrofitting with a diesel particulate filter, segregating a fleet to send only compliant equipment to California, and using alternative power, such as biodiesel and electric standby.

When CARB adopted the TRU ATCM “it figured that retrofit filters on TRUs were the solution. It didn't quite work out that way. The 50% control devices have limitations and cost as much as repowering with another engine. Practical retrofit devices are still being developed.”

Regulation waiver

Shortly after CARB submitted its TRU ATCM to the US EPA in 2005, ATA and others asked the EPA for a waiver hearing, making the case why the regulation should not be adopted, Tunnell explained.

Among the reasons given: the measure has significant impacts well beyond California, and “it's technology forcing nature that focuses on users who don't necessarily have the technical resources that a manufacturer has. Plus, there is no incentive to develop retrofits, so the result has become scrap the old engines and TRUs and replace them with new ones.”

Tunnell said the EPA has been evaluating the waiver on and off, and at this point, it is unclear when, or if, the waiver will be granted.

New projects

“Our next step is dependent upon EPA's decision on the waiver. ATA is well positioned to pursue legal options to invalidate the regulation, and is financially vested and prepared to pursue legal options should an adverse decision be made.”

This October, there are two CARB initiatives - part of its strategy for attaining clean air and reducing greenhouse gas emissions - that will have a major impact on trucking fleets, Tunnell said.

One is an equipment mandate requiring any model year 2011 53-ft or longer van trailer be US EPA Certified SmartWay, meaning it must have features and components for environmental and fuel efficiency gains. These include side skirts, weight-saving technologies, areodynamic devices, and low-rolling resistance tires.

Further, any model year 2011 tractor pulling a 53-ft or longer van trailer needs to be SmartWay certified as well, unless it is a daycab tractor, which must have SmartWay approved tires.

By 2012, all pre-2011 sleeper tractors and daycabs would need SmartWay approved tires. Come 2014, all pre-2011 53-ft trailers would need to have SmartWay certified technologies.

Also scheduled for October is the “private fleet rule,” the goal of which is to have the entire heavy-duty truck fleet operating in California meet 2007 emission standards by 2014.

“This is really the center piece of CARB's air quality strategy,” Tunnell pointed out. “And it's very reliant on SCR (selective catalytic reduction) retrofits to reduce emissions.”

The ultimate goal of the private fleet rule, he said, is to have the entire heavy-duty truck fleet meet 2010 emission standards by 2022.

Tunnell mentioned that idling regulations already in effect in California limit truck idling to five minutes. However, idling is allowed for low-NOx (nitrogen oxides) engines certified by CARB as clean idle. Otherwise, trucks will need some type of cab comfort device.

Electric auxiliary power units (APU) are considered compliant. Diesel-fired APUs are okay for trucks with pre-2007 engines, while these APUs need a diesel particulate filter for trucks with 2007 or newer engines.

In closing, Tunnell said: “We can expect more to come from CARB because, as the current chairman of the CARB Mary Nichols stated: ‘The transition from fossil fuels to a clean-energy future is not a choice for California; it's a necessity.’”

Transport Refrigeration Units

The California Air Resources Board Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Gen Sets, and Facilities Where TRUs Operate requires that:

• 2001 and older units must reduce particulate (PM) emissions by 50% by year-end 2008; 85% by 2015.

• 2002 units must reduce PM emissions by 50% by year-end 2009; 85% by 2016.

• 2003 units must reduce PM emissions by 85% by year-end 2010.

• 2004 units must reduce PM emissions by 85% by year-end 2011, and so on until TRUs with 2013 diesel engines become available.

CARB Emissions Timeline

1998 - Identified particulate matter (PM) emissions from diesel-fueled engines as a toxic air contaminant (versus EPA “likely” determination).

2000 - Adopted a diesel risk reduction plan to reduce exposure to diesel exhaust (commits to engine retrofits).

2007 - Adopted a state implementation plan to reduce ozone precursors, including NOx emissions (commits to accelerate engine retrofits and/or replacements).

2007 - Adopted “early actions” plan to reduce greenhouse gas emissions (commits to a SmartWay equipment mandate).