## Appendix H

Public Outreach and ImplementationH-1 PUBLIC OUTREACH AND IMPLEMENTATION

Appendix H discusses staff’s efforts to reach out t o stakeholders regarding the proposed amendments, requirements and regulation im plementation such as ARB’s enforcement activities and VDECS availability and f easibility.

A. Public Outreach
1. Proposed Amendments
In addition to the public workshops staff conducted on the proposed amendments, staff also contacted the companies and organizations list ed in Table 1 regarding the proposed amendments.

Table 1: Companies and Organizations Contacted to Discuss the Truck and Bus Regulation
American Lung Association Environmental Defense Fun d American Trucking Association Foster Farms Anderson Logging Granite Construction Associated California Loggers Harris Ranch Beef Com pany Bay Counties Dump Truck Association J.G. Boswell Co mpany The Better World Group Kings Canyon Unified School District California Agricultural Aircraft Association Lakepoint Unified School District

California Air Pollution Control Officers Association Los Angeles Unified School District

California Association of Winegrape Growers Lumber Association of California and Nevada California Bus Association Manufacturers of Emissio n Controls Association California Cattlemen’s Association Mid-Placer Trans portation Agency California Citrus Mutual National Association of Fl eet Administrators California Cotton Ginners and Growers Association Natural Resources Defense Council

California Farm Bureau Federation Nisei Farmers Lea gue California Association of School Transportation Officials North American Power Sweeping Association California Association of Winegrape Growers Poway Unified School District

California Forestry Association Robinson Enterprise s California Groundwater Association School Bus Trans portation Coalition California Independent Oil Marketers Association Southwestern Transportation Agency

California Rice Commission Stanislaus County Farm B ureau California Teamsters United Motorcoach AssociationH-2

California Trucking Association Union of Concerned Scientists Classic Charter West Coast Collaborative California Forestry Association School Bus Transpor tation Coalition California Groundwater Association West County Tran sportation Agency Coach USA Coalition for Clean Air Crop Production Services .

2. Outreach Efforts
ARB staff, in cooperation with affected industries, has been developing and conducting an extensive outreach campaign to ensure affected p arties are aware of their responsibilities under the regulation. This includ es development of an outreach plan with input from industry representatives, distribut ing information through dealers and other state and local agencies, and conducting trai ning seminars and presentations throughout the State.

Staff developed a comprehensive outreach plan to no tify truck owners about in-use regulations that apply to them. The outreach plan will be modified to inform fleets about any changes and what options they have to comply. Education efforts include training seminars, public workshops, and individual meetings with affected stakeholders throughout the State and continuation of the succes sful TruckStop website and the toll free phone number, 866-6DIESEL. Outreach efforts a lso include traditional media efforts and utilizing e-mail listservs. California Truck’n News was developed to provide print ready materials for newsletters directed to t hose affected by the regulations. Staff will also continue to work with industry representa tives and associations on additional ways to educate different stakeholders on the amend ments to the regulations.

To assist in the successful implementation of the r egulations, the Truck Regulations Advisory Committee (TRAC) was formed to facilitate communication with affected stakeholders and to obtain stakeholder feedback on the implementation of the regulations. TRAC helps staff fine tune outreach, training, implementation materials, proposed amendments, and provides a mechanism for s takeholders to discuss other implementation issues. Specific subcommittees were also formed to address issues that affect outreach, small businesses, reporting, and specific source category implementation issues. TRAC has held four meetings . All of the meetings have been held in Sacramento and have been webcast with the o pportunity to comment via email, to provide flexibility to stakeholders. The meetin gs were held on September 1, 2009, November 10, 2009, February 17, 2010, and July 14-1 5, 2010. The next meeting is set for January 2011.

ARB continues to work with TRAC to identify the bes t approaches to outreach and how to best reach different stakeholder groups and to s eeks members input on the implementation of the regulations and on the develo pment of outreach and compliance materials, including fact sheets, posters, and flye rs.H-3

ARB staff established informational networks used b y vehicle and equipment dealers, local air districts, and state agencies such as the Department of Motor Vehicles and the California Highway Patrol to distribute information al materials about the regulations. For example, information on all ARB truck regulations i s included in the DMV Commercial Drivers Handbook and local districts and vehicle an d equipment dealers are provided with up-to-date materials to educate those affected by the regulations.

Since the beginning of 2009, staff has provided tra ining and presentations on the truck regulation requirements at over 200 events as descr ibed in Table 2. This outreach provided a range of information, from a general ove rview of the requirements to focused compliance options and reporting requirements. ARB staff will continue these outreach efforts statewide. Besides in person and via webca st, ARB staff has also offered training sessions using a webinar program (GoToMeet ing). GoToMeeting allows ARB to host an interactive training where participants can attend online from remote locations at a date and time of their convenience. The most recent GoToMeeting training ARB staff offered was to vehicle and equipment sellers who were not able to attend the trainings held on July 21 and July 22, 2010. Staff held five training webinars and received positive feedback from participants. Staf f plans to continue to offer training through the webinar program. ARB also provides on going classroom training through ARB’s Compliance Training 500 Series courses for mo re established programs such as Course 511: Diesel Emissions and Controls, Course 5 12: In-Use Diesel Engine Regulations Overview, and Course 513: Drayage Truck

.

Table 2: Public Outreach Events

Date Location Event
2/11/2009 Tulare World Ag Expo 2/14/2009 Anderson Sierra Logging Conference 2/17/2009 Phone Conference ED BAAQMD 2/18/2009 Sacramento CA Groundwater Association 3/3/2009 Salinas Monterey Ag Expo 3/10/2009 Pleasant Grove CAT Customer Outreach 3/11/2009 West Sacramento CAT Customer Outreach 3/12/2009 Stockton CAT Customer Outreach 3/16/09-3/18/09 Los Angeles Clean Heavy Duty Vehicl e Expo 3/18/2009 Diamond Bar VIP and Diesel Outreach 3/18/2009 San Diego CAT Customer Outreach 3/19/2009 Sacramento VIP and Diesel Outreach 3/23/2009 Fresno VIP and Diesel Outreach 3/23/2009-3/24/2009 Long Beach Faster Freight Clean er Air 3/25/2009 Sacramento Lumber Association of CA and N V 3/25/2009 Sacramento Environmental Policy Committee 4/1/2009 Oakland TEC Equipment, Inc. Customer Outre ach 4/9/2009 Ontario Transportation Logistics Summit 4/16/2009 Riverside CA Groundwater Association

4/23/2009 Stockton CA Trucking Association Quarterly Chapter Meeting 5/5/2009 San Leandro CAT Customer Outreach 5/8/2009 Redding CAT Customer OutreachH-4

Date Location Event

5/13/2009 Fresno CAT Customer Outreach 5/13/2009 Fresno Sequoia Equipment/ Harris Construc tion 5/14/2009 San Luis Obispo District Outreach 5/14/2009-5/15/2009 Stockton Western Truck Center 5/15/2009 Sacramento Motor Carrier Industry Meeting 5/20/2009 City of Industry CAT Customer Outreach 5/21/2009 Fremont Bay Counties Dump Truck Associati on 5/22/2009 Sonora Diesel Vehicle Workshop 6/1/2009 Davis Green Acres, Blue Skies II 6/4/2009 San Leandro NorCal Kenworth 6/23/2009 San Diego CA Independent Oil Marketers Association Annual Meeting 6/30/2009 El Monte Ontario Trucking Association 7/8/2009-7/10/2009 La Jolla Truckload Carriers Asso ciation 7/14/2009 French Camp CA Trucking Association Steer ing Meeting 7/16/2009 Lodi Municipality, Utility and Fleet Trai ning 7/16/2009 Sacramento Clean Technologies Forum 7/16/2009 Fontana Rush Truck Center 7/25/2009-7/27/2009 Las Vegas The Great West Truck Show 7/29/2009 Irvine GE Capital Fleet Services 7/30/2009 San Diego Engineering and General Contrac tors Association 7/30-31/2009 Lowell, AR J.B. Hunt 8/20/2009 Dallas, TX The Great American Trucking Sh ow 8/22/2009 Santa Rosa Opperman & Sons 8/25/2009 Malloy Imrie & Vasconi Insurance, LLC 8/28/2009 Sacramento Tiechert Truck Appreciation 9/2/2009 Sacramento CA Trucking Association Sacrame nto Unit

9/3/2009 Sacramento In-Use Diesel Engine Regulations Overview: Course #512

9/10/2009 Sacramento In-Use Diesel Engine Regulations Overview: Course #512

9/15/2009 Nationwide Technology and Maintenance Council with Dave Nemo- Radio Show 9/16/2009 Raleigh, NC American Trucking Association Technology and Maintenance Council

9/17/2009 San Francisco In-Use Diesel Engine Regulations Overview: Course #512 9/21/2009 Elk Grove FedEx 9/22/2009 Newark FedEx

9/22/2009 Bakersfield In-Use Diesel Engine Regulations Overview: Course #512 9/23/2009 Vallejo FedEx

9/23/2009 Fresno In-Use Diesel Engine Regulations Overview: Course #512 9/24/2009 Elk Grove FedEx 9/28/2009 Ontario FedEx

9/29/2009 Lancaster In-Use Diesel Engine Regulations Overview: Course #512 9/29/2009 Glendale FedEx 9/29/2009 Ontario FedEx 9/30/2009 Riverside Valley Power SystemsH-5

Date Location Event

9/30/2009 Victorville In-Use Diesel Engine Regulations Overview: Course #512 9/30/2009 San Diego FedEx 10/1/2009 Long Beach FedEx

10/7/2009 Jackson In-Use Diesel Engine Regulations Overview: Course #512 10/8/2009 Healdsburg Opperman & Sons 10/8/2009 Salinas Pacific Truck Parts 10/12/2009 Stockton Cargill Incorporated 10/12/2009 San Luis Obispo In-Use Diesel Engine Regulations Overview: Course #512

10/13/2009 Oxnard In-Use Diesel Engine Regulations Overview: Course #512 10/15/2009 Livermore CA Tow Truck Association 10/15/2009 Squaw Valley CA Construction and Industrial Materials Association 10/17/2009- 10/18/2009 Pomona Truck Show Latino

10/20/2009 Diamond Bar In-Use Diesel Engine Regulations Overview: Course #512 10/21/2009 Portland Oregon Trucking Association 10/21/2009 Ord Bend CA Bee Breeders Association 10/22/2009 Orange County In-Use Diesel Engine Regulations Overview: Course #512

10/26/2009 Auburn In-Use Diesel Engine Regulations Overview: Course #512 10/27/2009 Modesto California Moving and Storage As sociation 11/3/2009 Los Angeles Armored Car Association 11/3/2009 Carlsbad CA Bus Association Annual Conven tion

11/3/2009 Sacramento In-Use Diesel Engine Regulations Overview: Course #512

11/4/2009 Sacramento In-Use Diesel Engine Regulations Overview: Course #512 11/4/2009 French Camp Arrow Truck Sales Open House 11/4/2009 Ontario CA Trucking Association Meeting 11/5/2009 French Camp Arrow Truck Sales Open House 11/5/2009 Sacramento CA Trucking Association Meetin g 11/7/2009 Reno, NV CA Groundwater Association Air E missions

11/10/2009 Santa Rosa In-Use Diesel Engine Regulations Overview: Course #512 11/12/2009 Tracy J.B. Hunt-C.A.R.B. Seminar 11/13/2009 Irvine J.B. Hunt-C.A.R.B. Seminar 11/13/2009 Portland, OR Oregon Trucking Association Maintenance Fair 11/15-17/2009 Anaheim Intermodal Expo 11/17/2009 Riverside California Moving and Storage Association 11/18/2009 Knightsen Contra Costa County Dept. of A griculture 11/18/2009 Sacramento School Transportation Meeting 11/19/2009 Anaheim Fleet Services Inc. Fleet Traini ng
12/3/2009 Sacramento In-Use Diesel Engine Regulations Overview: Course #512 12/2-4/2009 Dallas, TX Supply Chain and Logistics S ummit 12/4/2009 Santa Maria California Moving and Storage AssociationH-6

Date Location Event
12/7/2009 Anaheim CA Farm Bureau Annual Meeting

12/7-10/2009 Sacramento CA Agricultural Commissioners and Sealers Association 12/8/2009 Knightsen Contra Costa County Dept. of Ag 12/16/2009 San Francisco Motorcoach Operators 12/17/2009 Fresno Central Valley Bee Keepers Associ ation 12/17/2009 Otay Mesa San Diego Association of Gover nments 12/17/2009 Sacramento Ryder Tractor Trailer GHG Tra ining

1/5/2010 Sacramento Hybrid Truck and Bus Voucher Incentive Program Dealer Training 1/6/2010 Commerce Bullet Freight

1/6/2010 San Francisco Hybrid Truck and Bus Voucher Incentive Program Dealer Training 1/13/2010 Bay Area Diesel Emissions and Controls: C ourse #511

1/13/2010 Fresno Hybrid Truck and Bus Voucher Incentive Program Dealer Training 1/14/2010 Medford, OR Southern Maintenance Council

1/21/2010 Diamond Bar In-Use Diesel Engine Regulations Overview: Course #512 1/21/2010 Yuba City Yuba Sutter Farm Bureau

1/22/2010 Pacoima In-Use Diesel Engine Regulations Overview: Course #512 1/26/2010 San Francisco Green Airport Fleets Worksh op and Expo 1/27/2010 Sacramento Diesel Emissions and Controls: Course #511 2/2/2010 San Diego Diesel Emissions and Controls: C ourse #511

2/3/2010 Sacramento Hybrid Truck and Bus Regulation and Test Procedure Workshop 2/3/2010 San Diego Diesel Emissions and Controls: C ourse #511 2/8/2010 Auburn Placer County Department of Agricul ture 2/9/2010 Imperial In-Use Diesel Engine Regulations Overview: Course #512 2/10/2010 Tulare World Ag Expo 2/10/2010 San Diego In-Use Diesel Engine Regulations Overview: Course #512 2/11-13/2010 Redding Cascade Sierra Logging Confere nce 2/16/2010 Diamond Bar Westrux International Safety Conference 2/17/2010 Redding Diesel Emissions and Controls: Co urse #511 2/17/2010 Sacramento Drayage Truck: Course #513

2/18/2010 Sacramento/webcast In-Use Diesel Engine Regulations Overview: Course #512 2/21/2010 Florida Retail Industry Leaders Associati on Logistics 2/24/2010 El Monte Truck and Bus/GHG Reporting Trai ning 2/24/2010 Santa Barbara CA Trucking Association 2/25/2010 Fresno Truck and Bus/GHG Reporting Traini ng 2/25/2010 Fresno Truck and Bus/GHG Reporting Traini ng 3/1/2010 San Andreas Truck and Bus/GHG Reporting Tr aining 3/2/2010 Santa Barbara Diesel Emissions and Control s: Course #511

3/2/2010 Sacramento Truck and Bus/GHG Reporting Tra ining 3/3/2010 Sacramento Truck and Bus/GHG Reporting Tra ining
3/3/2010 Corona, Diamond Bar In-Use Diesel Engine Regulation Overview: Course #512H-7

Date Location Event
3/4/2010 Riverside Truck and Bus/GHG Reporting Trai ning 3/8/2010 Monterey Truck and Bus/GHG Reporting Train ing 3/10/2010 Modesto Western United Dairymen 3/10/2010 Calexico CA Highway Patrol Industry Days 3/11/2010 Napa Truck and Bus/GHG Reporting Training 3/13-15/2010 Monterey CA Association of School Transportation Officials 2010 42 nd Annual State Conference 3/15/2010 El Centro Truck and Bus/GHG Reporting Tra ining 3/16/2010 San Diego Truck and Bus/GHG Reporting Tra ining 3/17/2010 Diamond Bar Diesel Emissions and Controls : Course #511 3/17/2010 Webinar Missouri Trucking Association 3/17/2010 Webinar Washington Trucking Association 3/18/2010 Sacramento Truck and Bus/GHG Reporting Tr aining 3/18/2010 Sacramento Truck and Bus/GHG Reporting Tr aining 3/22/2010 Santa Rosa Sonoma County Farm Bureau 3/22/2010 Marysville Truck and Bus/GHG Reporting Tr aining 3/23/2010 San Diego Drayage Truck: Course #513 3/23/2010 Colusa Truck and Bus/GHG Reporting Traini ng 3/24/2010 Ventura Truck and Bus/GHG Reporting Semin ar 3/24/2010 Long Beach Drayage Truck: Course #513 3/24/2010 Oakland CA Trucking Association/ NorCal I ntermodal 3/25-27/2010 Ukiah Redwood Logging Conference 3/25/2010 Bakersfield Truck and Bus/GHG Reporting T raining 3/25/2010 Tulare Truck and Bus/GHG Reporting Traini ng 3/26/2010 Fresno Truck and Bus/GHG Reporting Traini ng 3/30/2010 Sacramento Process Equipment Manufactures Association 3/31/2010 Sacramento Safety Expo 2010

4/1/2010 Sacramento In-Use Diesel Engine Regulation Overview: Course #512

4/2/2010 Sacramento In-Use Diesel Engine Regulation Overview: Course #512 4/6/2010 Fullerton Rotary Club Meeting 4/6/2010 Sacramento Diesel Emissions and Controls: Course #511 4/13/2010 Fresno Diesel Emissions and Controls: Cou rse #511 4/21/2010 Sacramento CA Bus Association 4/21/2010 Sacramento (webcast) Diesel Emissions and Controls: Course #511 4/22/2010 Sacramento (webcast) Diesel Emissions and Controls: Course #511 4/22/2010 Otay Mesa CA Highway Patrol Industry Days 4/27/2010 National Association of Clean Air Agenc ies

4/27/2010 Riverside Western Riverside Council of Governments Advancing the Choice 4/28/2010 Fontana Inland Kenworth/ Engine Control S ystems 4/29/2010 Montebello Inland Kenworth/ Engine Contro l Systems 4/29/2010 Redding In-Use Diesel Engine Regulation Overview: Course #512

4/30/2010 Eureka In-Use Diesel Engine Regulation Overview: Course #512 5/5/2010 Bakersfield Diesel Emissions and Controls: Course #511 5/5/2010 Napa CA Precast Concrete Association 5/11/2010 Bay Area In-Use Diesel Engine Regulation Overview: Course #512H-8

Date Location Event

5/12/2010 North Bay Area In-Use Diesel Engine Regulation Overview: Course #512

5/18/2010 Webcast In-Use Diesel Engine Regulation Overview: Course #512 5/19/2010 Sacramento (webcast) In-Use Diesel Engine Regulation Overview: Course #512 5/26/2010 Oakland Diesel Emissions and Controls: Co urse #511 5/26/2010 Ventura Drayage Truck: Course #513 5/27/2010 Tecate CA Highway Patrol Industry Days 5/27-29/2010 Pleasanton National Convention and Ant ique Truck Show 6/4-5/2010 Galt Shriner’s Cool Truck Show 6/16/2010 Los Angeles Diesel Emissions and Controls : Course #511 6/17/2010 San Jose Coast Counties Peterbilt 6/30/2010 Salinas Diesel Emissions and Controls: Co urse #511

7/13/2010 Santa Barbara In-Use Diesel Engine Regulation Overview: Course #512 7/14/2010 San Luis Obispo In-Use Diesel Engine Regulation Overview: Course #512

7/20/2010 Santa Maria In-Use Diesel Engine Regulation Overview: Course #512 7/20/2010 Pomona California Fleet Solutions 7/21/2010 Santa Maria Diesel Emissions and Controls : Course #511 7/21/2010 El Monte Dealer Training 7/22/2010 Sacramento (webcast) Dealer Training 7/26/2010 GoToMeeting Peterbilt Dealer Training 7/27/2010 Sacramento Drayage Truck: Course #513

7/28/2010 Sacramento (webcast) In-Use Diesel Engine Regulation Overview: Course #512 7/30/2010 GoToMeeting Northwest Equipment Dealer Training 7/31/2010 Clovis Central Valley Commercial Truck Sh ow 8/2/2010 GoToMeeting Meinhiem Dealer Training 8/16/2010 GoToMeeting MidWest Utility 8/17-18/2010 San Diego Diesel Emissions and Controls: Course #511 8/19/2010 Sacramento Diesel Emissions and Controls: Course #511 8/19/2010 GoToMeeting Future Ford Dealer Training 8/23/2010 Sunol CA Highway Patrol Driver Appreciati on Day 9/19/2010 Anaheim California Vehicle Safety Summit

9/21&22/2010 GoToMeeting Ford Commercial Account Managers Dealer Training 9/22/2010 San Diego CA Construction and Industrial Materials Association 9/28/2010 Cottonwood CA Highway Patrol Driver Appre ciation Day

10/9/2010 San Francisco National Truck and Heavy Equipment Claims Council 10/13/2010 Nevada City Gold Country Chapter of Asso ciated Loggers 10/16-17/2010 Pomona Golden State (Latino)Truck Sho w

3. Other Efforts
To facilitate stakeholder access to regulatory info rmation, ARB established a toll free hotline and a consolidated website to access inform ation that affects truckers. Since its inception, ARB’s toll free number, 866-6DIESEL, has assisted over 25,000 callers withH-9

questions on the truck and bus regulation and other diesel vehicle regulations. The TruckStop website streamlines access to information affecting diesel trucks and trailers. Since January 8, 2010, there have been over 47,000 hits on the truck and bus regulation website and over 236,000 hits combined o n all of the diesel program websites.

B. Enforcement
Enforcement of the regulation will be conducted sim ilarly to the enforcement of ARB’s in-use fleet rules. Staff will use the inspection and audit methods they have developed during their many years of experience enforcing the Heavy-Duty Vehicle Inspection Program (adopted into law in 1988) and the Periodic Smoke Inspection Program (adopted into law in 1990). Enforcement activities will include inspections at border crossings, CHP weigh stations, fleet facilities, an d randomly selected roadside locations, and audits of records. These activities could result in corrective actions and substantial civil penalties for non-compliance with the regulation. The 2009 Annual Enforcement Report summarizes their enforcement act ivities and can found at http://www.arb.ca.gov/enf/reports/reports.htm

. The proposed amendments to the regulation will not have an impact on the enforcement policies of ARB. It is ARB’s policy to ensure unif orm compliance with all its regulations so that no one entity obtains an unfair economic ad vantage by not complying with applicable regulatory requirements. For the regula tion to be fair to fleets that would spend considerable funds and effort to comply, flee ts must be assured that their competitors are held accountable for compliance. S taff recognizes that creating a level playing field for all affected fleets is important, and is committed to obtaining the resources necessary to provide outreach, compliance assistance, and enforce the regulation.

C. VDECS Availability and Feasibility
1. Technology Available to Meet Regulatory Requirem ents This section discusses the availability of technolo gy to meet the requirements of the proposed amendments to the regulation, with a parti cular focus on retrofit strategies and their feasibility.

a) Verification
The regulation only provides credit for diesel emis sion control strategies that have been verified by ARB. ARB adopted a procedure to verify retrofit diesel emission control strategies in 2003 with updates approved by the Boa rd in 2008 (ARB, 2009). Verification is an approval from ARB, which tells e nd users that the verified device achieves the advertised emission reductions and is durable. To be verified, retrofit devices must demonstrate the efficacy and durabilit y of their products and provide a warranty. The warranty guarantees the retrofit’s e fficacy for 5 years or up to 150,000 miles or more, depending on engine size and age, an d warrants that the retrofit will not cause engine damage.H-10

ARB’s verification procedure is a multi-level verif ication system consisting of three PM reduction Levels and optional NOx reduction levels (see Table 3). Reductions in NOx are not required for verification, but ARB’s proced ure recognizes and verifies NOx reductions that are greater than or equal to 25 per cent in 15 percent increments. This system has broadened both the spectrum of control t echnologies available to participate in California’s diesel emission control effort and the number and types of vehicles and engines that can be controlled. This multi-level a pproach to verification is consistent with the goal of achieving the maximum reductions i n diesel PM emissions that are economically and technologically feasible. At this time, nearly all the verified emissions control strategies are retrofit exhaust after treat ment devices.

Table 3: VDECS Levels (as adopted by the Board in January 2008)

Pollutant Reduction Classification < 25% Not verified

> 25% Level 1

> 50% Level 2 PM

> 85%,

or < 0.01g/bhp-hr Level 3

< 25% Not verified

> 25% Mark 1

> 40% Mark 2

> 55% Mark 3

> 70% Mark 4 NOx

> 85% Mark 5

b) Regulatory Requirements
The Truck and Bus regulation requires PM BACT. PM BACT is defined as an engine equipped with the highest level VDECS for PM or an engine originally equipped with a diesel particulate filter and certified to meet the 0.01 g/bhp-hr certification standard.

A typical Level 3 DECS consists of a ceramic wall-f low monolith or a silicon carbide substrate that captures PM before it can be release d to the atmosphere. The accumulated soot is then burned off (regenerated) e ither through an active or passive process. In passively regenerated diesel particulat e filters, the substrate is coated with a catalyst that burns off the collected PM during “re generation.” In actively regenerated diesel particulate filters, an external source of h eat such as an electrical heater or fuel burner is used to oxidize the collected PM. Vehicl es with 2007 MY engines are already equipped with PM filters. Currently, the only tech nology that achieves the required NOx performance standard is a 2010 model year engine.

c) Devices Verified for On-Road Vehicles
There are currently 14 Level 3 PM retrofit devices for on-road use that have been verified by ARB. Of these, two Level 3 PM devices also provide verified NOxH-11

reductions. More information about VDECS, and appl icable engine families, is available at http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm

. d) Devices Funded by Various Programs
Air districts reported to ARB by the June 28, 2010 deadline and made available the data on all 11,985 engines that were retrofit from 2007 to 2010. There were 1,142 on-road retrofits funded through the Carl Moyer Program; 73 9 retrofits funded through the Low Emission School Bus Program; 2,011 retrofits funded for drayage trucks; 5,508 retrofits funded for solid waste collection vehicles; and 2,5 85 retrofits funded through the Transit Bus Program. In addition, 86 school buses have bee n retrofit using Diesel Emission Reduction Act funds and 1,000 Level 3 retrofits hav e been funded by the Goods Movement Emission Reduction Program.

2. Feasibility Several fleets have informed staff that they have c oncerns regarding VDECS. These concerns include:

• Availability for short haul/low mileage vehicles

• Availability for older engines

• Technical feasibility with newer engines

As reported in Chapter VII of the Technical Support Document (ARB, 2008) hundreds of thousands of diesel PM filters have been installed successfully on trucks and buses throughout the world, both in new vehicles and in n umerous on-road retrofit applications. Most medium-heavy and heavy-heavy du ty diesel engines produced since 2007 have been equipped by the manufacturer with PM filters. In California, thousands of VDECS have been funded through the Carl Moyer pr ogram, and have been installed in response to existing regulations targeting urban buses, transit fleet vehicles, solid waste collection vehicles, vehicles owned by public agencies, drayage trucks, off-road vehicles, and others. Over 5,500 solid waste colle ction vehicles and over 2,500 transit fleet vehicles already have VDECS installed on them . VDECS can be designed, installed, and operated to provide effective, relia ble, and durable performance for most engines. If a VDECS is not technically feasible fo r the vehicle, the regulation allows a compliance extension until 2018.

ARB has verified 9 passive and 5 active Level 3 VDE CS for on-road vehicles. In short haul and low speed applications, a passive VDECS ma y not be a suitable choice because of the temperature requirements to burn off the trapped diesel PM (regeneration). However, an active VDECS can be us ed, which regenerates with a separate power unit to heat up the exhaust system t o reach the required temperature. This can be done when the vehicle is moving or park ed after the shift. Currently, three devices (HUSS, ECS Purifilter, and Cleaire Horizon) have been verified to work on a wide variety of model engines including pre-1994 me chanical fuel injected engines. Almost all vehicles with 2007 and newer engines are already equipped with PM filtersH-12

and are under the manufacturer’s warranty. The Ame rican Trucking Association’s transport topic magazine cites positive results for the 2007 systems. (ATA, 2008)

ARB’s verification program is designed to evaluate the effectiveness of a retrofit device to reduce PM and/or NOx emissions from specific die sel engines. As part of that evaluation, the compatibility of the device with th e engine is considered through testing that includes durability testing on operating vehic les. The device manufacturer must also demonstrate that the emission control device d oes not damage the engine and does not hinder the vehicle’s ability to perform it s normal functions. Also, the device manufacturer is required to provide a warranty agai nst engine damage caused by the VDECS. The warranty requirements for on-road VDECS are summarized in Table VII-5 of the Technical Support Document (ARB, 2008). The verification process in conjunction with the required warranty provides the fleet owner with confidence that a verified device will perform as advertised and, in the event that a VDECS malfunctions, they have recourse through the warranty. The most current list of VDECS, applicable engine families, as well as EO letters may be found on the ARB website at: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm

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References:

ARB, 2008. California Air Resources Board. Technical Support Document: Proposed Regulation for In-Use On-Road diesel Vehicles. October 2008. http://www.arb.ca.gov/regact/2008/truckbus08/tsd.pd f

ARB, 2009. California Air Resources Board. Final Regulation Order. California Code of Regulations, Title 13, Division 3 Chapter 14. Ve rification Procedure, Warranty and InUse Compliance Requirements for In-Use Strategies t o Control Emissions from Diesel Engines. January 2009. http://www.arb.ca.gov/diesel/verdev/reg/procedure_j an1009.pdf

ATA, 2008, American Trucking Association’s Transpor t Topic Magazine. March 10, 2008. http://ttnews.com/articles/basetemplate.aspx?storyi d=19317