Office of Transportation EPA420-S-05-011 

and Air Quality September 2005 

Model State Idling Law 

Workshop — Chicago, 

Illinois 

Meeting Summary 
EPA420-S-05-011 

September 2005 

Model State Idling Law Workshop —

Chicago, Illinois

Meeting Summary 

Transportation and Regional Programs Division 

Office of Transportation and Air Quality 

U.S. Environmental Protection Agency 

NOTICE

This Technical Report does not necessarily represent final EPA decisions or positions.

It is intended to present technical analysis of issues using data that are currently available.

The purpose in the release of such reports is to facilitate an exchange of

technical information and to inform the public of technical developments.
The U.S. Environmental Protection Agency (EPA) sponsored meeting on June 28, 2005, in 

Chicago, Illinois, to develop a model state idling law. Participants included representatives from 

states and local governments, trucking industry, and environmental and community groups. The 

views and opinions expressed below do not necessarily represent official EPA policy, positions, 

or views. The purpose of this meeting was, among other things, to reach consensus on a model 

state idling law. EPA takes no position on state or local idling laws. EPA’s role in these 

meetings was that of organizer and facilitator only. 

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List of Issues 

A: Exempt a vehicle when forced to remain motionless because of traffic, an official traffic


control device or signal, or at the direction of a law enforcement official. ............... 1


B: Exempt a vehicle when adverse weather conditions affect the safe operation of the vehicle


(operating defrosters, heaters, air conditioners, or other equipment) solely to prevent a safety


or health emergency. ........................................................ 1


C: Exempt idling of a police, fire, ambulance, public safety, military or any other emergency or


law enforcement vehicle while in an emergency or training mode, or as part of its standard


operating procedure. ......................................................... 1


D: Exempt a vehicle when the primary propulsion engine is idling for maintenance, servicing,


repairing, or diagnostic purposes at a recognized facility for such operations. ............ 1


E:	 Exempt idling when a vehicle is required to do so by law to verify that all equipment is in


good working order, either as part of a daily vehicle inspection or State/Federal inspection,


provided that such engine idling is mandatory for such verification. ................... 2


F:	 Exempt a vehicle when the primary propulsion engine is providing a power source necessary


for mechanical or electrical operations other than propulsion, such as loading or unloading,


mixing or processing cargo, straight truck refrigeration, or providing a mechanical extension


to perform work functions. ................................................... 2


G: Exempt any vehicle with an independent engine used for the sole purpose of controlling


cargo temperature. .......................................................... 2


H: Exempt vehicle idling to conform to the engine manufacturer’s recommended time for


warming-up and cooling down the engine up to a maximum of 5 minutes. .............. 2


I:	 Establishing a general time limit. ............................................... 3


J:	 Exempting mechanical difficulties provided that the problem is fixed. ................. 3


K: Research & Development: 	Should you exempt a vehicle when the primary engine, vehicle,


or device is idling when operated by the engine or truck manufacturer or their partners


(including labs, research facilities, and trucking companies). ......................... 3


L:	 Sleeper Berth Exemption: Should you exempt all trucks with sleeper berths? ........... 4


M: Temperature exemption for non-sleeper trucks. ................................... 4


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N: Should you exempt a mobile idle reduction technology (e.g., generator sets, auxiliary power


units, direct fired heaters) operating to provide heating, air conditioning, or auxiliary power to


the vehicle. ................................................................ 4


O: Exempt natural gas, hybrid, or 2007+ diesel vehicles. .............................. 5


P: Penalties .................................................................. 5


Q: Enforcement ............................................................... 5


R: Future truck at low idle emission ............................................... 5


S: Light duty vehicle remote starting .............................................. 6


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A 

Issue:	 Exempt a vehicle when forced to remain motionless because of traffic, an official 

traffic control device or signal, or at the direction of a law enforcement official. 

Discussion:	 Discussion focused on the fact that allowing this exemption is common sense. 

Some discussion on if this applies to a queue at a distribution center (DC), and 

who is responsible for the wait time: driver or DC owner. In some cases the DC 

owner may be responsible for delays resulting in more idling, and in other cases, if 

a driver shows up early, the driver may be the cause of the idling. 

Consensus:	 General consensus on this issue, but no consensus on if this applies to queuing. 

B 

Issue: Exempt a vehicle when adverse weather conditions affect the safe operation of the 

vehicle (operating defrosters, heaters, air conditioners, or other equipment) solely 

to prevent a safety or health emergency. 

Discussion: Discussion focused on uncertainty with the terms “adverse weather” and “solely 

to prevent a safety or health emergency.” The need here is to condition the truck 

and not necessarily the driver. May need to better define “adverse.” General 

sense that this exemption is too broad, but equal concern of having to define every 

word or term. 

Consensus: General consensus reached on this issue provided that the phrase “solely to 

prevent a safety or health emergency” is deleted. 

C 

Issue:	 Exempt idling of a police, fire, ambulance, public safety, military or any other 

emergency or law enforcement vehicle while in an emergency or training mode, or 

as part of its standard operating procedure. 

Discussion:	 Discussion focused on the phrase “as part of its standard operating procedure.” 

The groups felt that this was a loophole that was ripe for abuse. Anyone can 

claim that idling is part of their SOP. How would an enforcement official prove 

that this was not true? Many felt that the idling had to be a necessary part of their 

operation to be exempted. 

Consensus:	 General consensus reached on this exemption provided that the phrase about SOP 

is deleted. 

D 

Issue:	 Exempt a vehicle when the primary propulsion engine is idling for maintenance, 

servicing, repairing, or diagnostic purposes at a recognized facility for such 

operations. 

Discussion:	 Discussion focused on the term “recognized facility.” Many felt that this needed 

to be defined. Others felt that repairs could be done by a service truck or the truck 

owner, and that only exempting “recognized facilities” penalizes owners who do 

their own repairs. 

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Consensus: General consensus reached on this exemption provided that the phrase “at a 

recognized facility” is deleted. 

E 

Issue: Exempt idling when a vehicle is required to do so by law to verify that all 

equipment is in good working order, either as part of a daily vehicle inspection or 

State/Federal inspection, provided that such engine idling is mandatory for such 

verification. 

Discussion: Discussion focused on the fact that this was common sense if a law required the 

engine to idle during the inspection process. 

Consensus: General consensus reached on this exemption. 

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F 

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Issue: Exempt a vehicle when the primary propulsion engine is providing a power source 

necessary for mechanical or electrical operations other than propulsion, such as 

loading or unloading, mixing or processing cargo, straight truck refrigeration, or 

providing a mechanical extension to perform work functions. 

Discussion: Discussion focused on the fact that much of this is common sense, and that when 

performing a work function the operation of the engine is necessary. 

Consensus: General consensus reached on this exemption. 

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G 

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Issue: Exempt any vehicle with an independent engine used for the sole purpose of 

controlling cargo temperature. 

Discussion: Discussion focused on the fact that this operation is not technically idling. Others 

stressed that the exemption should apply to the independent engine and not the 

whole truck. 

Consensus: General consensus reached on this exemption provided that the words “any 

vehicle” is deleted and replaced with “any independent engine.” 

H 

Issue:	 Exempt vehicle idling to conform to the engine manufacturer’s recommended 

time for warming-up and cooling down the engine up to a maximum of 5 minutes. 

Discussion:	 Discussion focused on the need to warm up and cool down a diesel engine, but the 

time limit of 5 minutes was seen as impractical in extremely cold weather. Some 

suggested that temperature ranges be provided with correlating times. Others 

believed that if a truck owner operated in cold weather areas they should invest in 

a block heater or other technology to protect the engine instead of using the main 

engine. The discussion focused on creating incentives to reduce main engine 

idling by not simply exempting every possible reason to idle the main engine. 

Additional comment on changing the word “time” to “procedures.” 

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Consensus:	 General consensus reached on this exemption based largely on the need to create 

an incentive to purchase an alternative device for those vehicles that operate in 

cold weather. Agreement to change “time” to “procedures.” 

I 

Issue: Establishing a general time limit. 

Discussion: Discussion focused on a rationale for a general time limit. A few exemptions can 

be folded into this general time limit: engine warm-up/cool-down, pre-trip 

inspection, and conditioning a bus prior to passenger boarding. Many drivers 

noted that during the pre-trip inspection the engine only needed to idle to check 

the air brake pressure, and this would only require about 5 minutes of idling. As 

for conditioning a bus, many felt that 5 minutes would be sufficient in moderate 

weather, but in weather extremes the bus would need more time. The issue of 

creating incentives came up with bus conditioning. Many felt that buses, like 

trucks during warm-up, should invest in a technology that cooled or warmed the 

interior instead of simply exempting them. Some people recommended doing 

away with a general time limit and basing everything on temperature. 

Consensus: General consensus on the need for a rationally based general time limit. 

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J 

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Issue: Exempting mechanical difficulties provided that the problem is fixed. 

Discussion: Discussion focused on recognizing that not all truck owners have the problem 

fixed at a repair facility, so these people should be allowed to submit the product 

receipt to demonstrate the problem was fixed. Many noted that this approach is 

similar to DOT’s approach (the “fix-it-ticket”). Some believed that this exemption 

falls under the maintenance discussion in (D) above, but this differs from (D) in 

that the truck is not in the process of being repaired at the time. 

Consensus: General consensus reached on this exemption provided that people are permitted 

to submit repair paperwork to demonstrate that the problem was fixed. 

K 

Issue:	 Research & Development: Should you exempt a vehicle when the primary 

engine, vehicle, or device is idling when operated by the engine or truck 

manufacturer or their partners (including labs, research facilities, and trucking 

companies). 

Discussion:	 Discussion focused on the actual practicality of this situation. Many, including 

engine manufacturers, felt that this situation is so rare that the exemption is not 

necessary. 

Consensus:	 General consensus reached on deleting this exemption. 

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L 

Issue:	 Sleeper Berth Exemption: Should you exempt all trucks with sleeper berths? 

Discussion:	 Discussion focused on balancing needs of the state with that of the truck driver. 

States want the emission reductions, truck owners want the fuel savings, and truck 

drivers want to rest comfortably. To balance these needs, the industry needs to 

consider alternatives to main engine idling. They should be given time to evaluate 

and finance the purchase of alternatives. States need to give industry a fair 

amount of time to do this. In the interim, the law should exempt sleeper berth 

idling but remove this exemption at some point. This will put industry on notice 

that they have a certain amount of time to install or adopt an alternative means to 

main engine idling. 

Consensus:	 General consensus reached on the need to allow sleeper berth idling for a certain 

amount of time, whereupon the exemption goes away (“sunsets”), and industry 

must adopt alternatives. 

M 

Issue: Temperature exemption for non-sleeper trucks. 

Discussion: Discussion focused immediately on who was responsible for this delay: the truck 

driver or the facility owner. Many truck drivers noted that they may arrive to 

pick-up or drop-off a load only to be told by the facility that they are not ready to 

be processed. The truck drivers must then wait for hours until the facility is ready 

to process them, and during this wait, if the temperatures warrants, the driver will 

idle to run the air or heat. Putting aside who is responsible for the enforcement 

section, many noted the similarity between this exemption and the sleeper berth 

exemption. There is a need to create an incentive for truck drivers that must wait 

to load or unload, for both sleeper or non-sleeper trucks, to invest in an alternative 

other than main engine idling. 

Consensus: General consensus reached on the need to allow truck idling during loading or 

unloading wait times up until a certain date, whereupon the exemption goes away 

(“sunsets”), and industry must adopt alternatives. 

N 

Issue:	 Should you exempt a mobile idle reduction technology (e.g., generator sets, 

auxiliary power units, direct fired heaters) operating to provide heating, air 

conditioning, or auxiliary power to the vehicle. 

Discussion:	 Discussion focused on California’s proposed rule that would require auxiliary 

engines installed on post 2006 MY trucks to be cleaner. Much discussion ensued 

on whether or not auxiliary engines emitted more particulate matter and nitrogen 

oxides during the long duration idling mode than the newer trucks. The group felt 

that more testing was necessary to determine if this was true. 

Consensus:	 No consensus was reached on this issue, but a request to obtain more information 

was made. 

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O 

Issue:	 Exempt natural gas, hybrid, or 2007+ diesel vehicles. 

Discussion:	 Discussion focused on the fact that one of the purposes of this model law is to 

conserve fuel, and that exempting vehicles that may emit less does not fulfill the 

purpose of conserving fuel. 

Consensus:	 General consensus reached on removing this exemption. 

P 

Issue: Penalties 

Discussion: Discussion focused on who should pay the fine: driver vs. company owner. 

Owners and drivers staked out opposing views. Some owners stated that if they 

received the ticket they would usually pay the fine as the cost of doing business in 

that state. Some owners may pass the fine onto the driver, but driver retention is a 

concern. 

Consensus: No general consensus reached on who is responsible for paying the fine, but the 

conversation leaned towards making the truck owner liable for fines as an 

incentive for them to purchase alternative technologies. 

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Q 

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Issue: Enforcement 

Discussion: Discussion focused on enforcing against facility owners versus truck owners. 

Truck stops were also discussed. The cause of queue idling was attributed to 

facility owners who caused delays. In some cases, truck drivers showing up at the 

facility too early was the reason for the wait. They key issue is determining who 

causes the wait time. If it is the facility owner, they should be liable. If it is the 

truck driver, they should be liable. The issue of truck stop owners was discussed 

in terms of what, if any, control they have over the trucks visiting their location. 

The thought was that the less control, the less culpability. 

Consensus: No consensus reached on fining facility owner versus truck driver. General 

consensus reached on not fining the truck stop owner for truck driver behavior 

largely outside their control. 

R 

Issue:	 Future truck at low idle emission 

Discussion:	 Some discussion on the need for an exemption if truck engines were designed to 

emit at a lower rate during long duration idling periods. The thought is that if an 

engine OEM designed a low idle emission engine then we should exempt these 

engines. This would not address the fuel consumption issue unless the engine 

also did not consume as much in idle. 

Consensus:	 No consensus reached on including this because of its speculative nature. If 

OEMs were to design a low emission engine with low fuel consumption during 

long duration idling then states should consider exempting it. 

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S 

Issue:	 Light duty vehicle remote starting 

Discussion:	 One participant educated the group about the rising popularity with remote start 

on light duty vehicles. Remote starting allows the vehicle owner to start the 

vehicle from outside the vehicle. Vehicle owners may want this function if they 

want to warm or cool the interior prior to entering. However, this new and 

growing option for vehicle purchasers may exacerbate idling by having car owners 

idle their engines for much longer periods than necessary. While diesel is the 

focus of this model law, the increase in light duty gasoline engine idling may 

cancel the benefits of diesel idling reductions. 

Consensus:	 No consensus sought on this issue. 

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