Appendix H 

Public Outreach and Implementation

H-1 

PUBLIC OUTREACH AND IMPLEMENTATION 

Appendix H discusses staff’s efforts to reach out to stakeholders regarding the 

proposed amendments, requirements and regulation implementation such as ARB’s 

enforcement activities and VDECS availability and feasibility. 

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 listed 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 Fund 

American Trucking Association Foster Farms 

Anderson Logging Granite Construction 

Associated California Loggers Harris Ranch Beef Company 

Bay Counties Dump Truck Association J.G. Boswell Company 

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 Emission Controls 

Association 

California Cattlemen’s Association Mid-Placer Transportation Agency 

California Citrus Mutual National Association of Fleet 

Administrators 

California Cotton Ginners and Growers 

Association 

Natural Resources Defense Council 

California Farm Bureau Federation Nisei Farmers League 

California Association of School 

Transportation Officials 

North American Power Sweeping 

Association 

California Association of Winegrape 

Growers 

Poway Unified School District 

California Forestry Association Robinson Enterprises 

California Groundwater Association School Bus Transportation Coalition 

California Independent Oil Marketers 

Association 

Southwestern Transportation Agency 

California Rice Commission Stanislaus County Farm Bureau 

California Teamsters United Motorcoach Association 
H-2 

California Trucking Association Union of Concerned Scientists 

Classic Charter West Coast Collaborative 

California Forestry Association School Bus Transportation Coalition 

California Groundwater Association West County Transportation 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 parties are aware of their 

responsibilities under the regulation. This includes development of an outreach plan 

with input from industry representatives, distributing information through dealers and 

other state and local agencies, and conducting training seminars and presentations 

throughout the State. 

Staff developed a comprehensive outreach plan to notify 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 successful TruckStop website and the toll 

free phone number, 866-6DIESEL. Outreach efforts also include traditional media 

efforts and utilizing e-mail listservs. California Truck’n News was developed to provide 

print ready materials for newsletters directed to those affected by the regulations. Staff 

will also continue to work with industry representatives and associations on additional 

ways to educate different stakeholders on the amendments to the regulations. 

To assist in the successful implementation of the regulations, 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 stakeholders 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 opportunity to comment via email, 

to provide flexibility to stakeholders. The meetings were held on September 1, 2009, 

November 10, 2009, February 17, 2010, and July 14-15, 2010. The next meeting is set 

for January 2011. 

ARB continues to work with TRAC to identify the best approaches to outreach and how 

to best reach different stakeholder groups and to seeks members input on the 

implementation of the regulations and on the development of outreach and compliance 

materials, including fact sheets, posters, and flyers. 

 
H-3 

ARB staff established informational networks used by vehicle and equipment dealers, 

local air districts, and state agencies such as the Department of Motor Vehicles and the 

California Highway Patrol to distribute informational materials about the regulations. For 

example, information on all ARB truck regulations is included in the DMV Commercial 

Drivers Handbook and local districts and vehicle and equipment dealers are provided 

with up-to-date materials to educate those affected by the regulations. 

Since the beginning of 2009, staff has provided training and presentations on the truck 

regulation requirements at over 200 events as described in Table 2. This outreach 

provided a range of information, from a general overview of the requirements to focused 

compliance options and reporting requirements. ARB staff will continue these outreach 

efforts statewide. Besides in person and via webcast, ARB staff has also offered 

training sessions using a webinar program (GoToMeeting). 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. Staff 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 more established programs such as 

Course 511: Diesel Emissions and Controls, Course 512: 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 Vehicle 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 Cleaner Air 

3/25/2009 Sacramento Lumber Association of CA and NV 

3/25/2009 Sacramento Environmental Policy Committee

4/1/2009 Oakland TEC Equipment, Inc. Customer Outreach 

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 Outreach 
H-4 

Date Location Event 

5/13/2009 Fresno CAT Customer Outreach 

5/13/2009 Fresno Sequoia Equipment/ Harris Construction 

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 Association 

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 Association 

7/14/2009 French Camp CA Trucking Association Steering Meeting 

7/16/2009 Lodi Municipality, Utility and Fleet Training 

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 Contractors Association 

7/30-31/2009 Lowell, AR J.B. Hunt 

8/20/2009 Dallas, TX The Great American Trucking Show 

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 Sacramento 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 Systems 
H-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 Association 

11/3/2009 Los Angeles Armored Car Association 

11/3/2009 Carlsbad CA Bus Association Annual Convention 

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 Meeting 

11/7/2009 Reno, NV CA Groundwater Association Air Emissions 

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 Agriculture 

11/18/2009 Sacramento School Transportation Meeting

11/19/2009 Anaheim Fleet Services Inc. Fleet Training 

12/3/2009 Sacramento In-Use Diesel Engine Regulations Overview: 

Course #512 

12/2-4/2009 Dallas, TX Supply Chain and Logistics Summit 

12/4/2009 Santa Maria California Moving and Storage Association 
H-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 Association 

12/17/2009 Otay Mesa San Diego Association of Governments 

12/17/2009 Sacramento Ryder Tractor Trailer GHG Training 

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: Course #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 Workshop and Expo 

1/27/2010 Sacramento Diesel Emissions and Controls: Course #511 

2/2/2010 San Diego Diesel Emissions and Controls: Course #511 

2/3/2010 Sacramento Hybrid Truck and Bus Regulation and Test 

Procedure Workshop 

2/3/2010 San Diego Diesel Emissions and Controls: Course #511 

2/8/2010 Auburn Placer County Department of Agriculture 

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 Conference 

2/16/2010 Diamond Bar Westrux International Safety Conference 

2/17/2010 Redding Diesel Emissions and Controls: Course #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 Association Logistics 

2/24/2010 El Monte Truck and Bus/GHG Reporting Training 

2/24/2010 Santa Barbara CA Trucking Association 

2/25/2010 Fresno Truck and Bus/GHG Reporting Training 

2/25/2010 Fresno Truck and Bus/GHG Reporting Training 

3/1/2010 San Andreas Truck and Bus/GHG Reporting Training 

3/2/2010 Santa Barbara Diesel Emissions and Controls: Course #511 

 

3/2/2010 Sacramento Truck and Bus/GHG Reporting Training 

3/3/2010 Sacramento Truck and Bus/GHG Reporting Training 

3/3/2010 Corona, Diamond Bar In-Use Diesel Engine Regulation Overview: 

Course #512 
H-7 

Date Location Event 

3/4/2010 Riverside Truck and Bus/GHG Reporting Training 

3/8/2010 Monterey Truck and Bus/GHG Reporting Training 

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 42nd Annual State Conference 

3/15/2010 El Centro Truck and Bus/GHG Reporting Training 

3/16/2010 San Diego Truck and Bus/GHG Reporting Training 

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 Training 

3/18/2010 Sacramento Truck and Bus/GHG Reporting Training 

3/22/2010 Santa Rosa Sonoma County Farm Bureau 

3/22/2010 Marysville Truck and Bus/GHG Reporting Training 

3/23/2010 San Diego Drayage Truck: Course #513 

3/23/2010 Colusa Truck and Bus/GHG Reporting Training 

3/24/2010 Ventura Truck and Bus/GHG Reporting Seminar 

3/24/2010 Long Beach Drayage Truck: Course #513 

3/24/2010 Oakland CA Trucking Association/ NorCal Intermodal 

3/25-27/2010 Ukiah Redwood Logging Conference 

3/25/2010 Bakersfield Truck and Bus/GHG Reporting Training 

3/25/2010 Tulare Truck and Bus/GHG Reporting Training 

3/26/2010 Fresno Truck and Bus/GHG Reporting Training 

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: Course #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 Agencies 

4/27/2010 Riverside Western Riverside Council of Governments 

Advancing the Choice 

4/28/2010 Fontana Inland Kenworth/ Engine Control Systems 

4/29/2010 Montebello Inland Kenworth/ Engine Control 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 #512 
H-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: Course #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 Antique 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: Course #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 Show 

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 Appreciation 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 Appreciation Day 

10/9/2010 San Francisco National Truck and Heavy Equipment Claims 

Council 

10/13/2010 Nevada City Gold Country Chapter of Associated Loggers 

10/16-17/2010 Pomona Golden State (Latino)Truck Show 

3. Other Efforts 

To facilitate stakeholder access to regulatory information, ARB established a toll free 

hotline and a consolidated website to access information that affects truckers. Since its 

inception, ARB’s toll free number, 866-6DIESEL, has assisted over 25,000 callers with 
H-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 on all of the diesel program 

websites. 

B. Enforcement 

Enforcement of the regulation will be conducted similarly 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, and 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 activities 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 uniform compliance with all its regulations 

so that no one entity obtains an unfair economic advantage by not complying with 

applicable regulatory requirements. For the regulation to be fair to fleets that would 

spend considerable funds and effort to comply, fleets must be assured that their 

competitors are held accountable for compliance. Staff 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 Requirements 

This section discusses the availability of technology to meet the requirements of the 

proposed amendments to the regulation, with a particular focus on retrofit strategies and 

their feasibility. 

a) Verification 

The regulation only provides credit for diesel emission 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 Board in 2008 (ARB, 2009). 

Verification is an approval from ARB, which tells end users that the verified device 

achieves the advertised emission reductions and is durable. To be verified, retrofit 

devices must demonstrate the efficacy and durability of their products and provide a 

warranty. The warranty guarantees the retrofit’s efficacy for 5 years or up to 150,000 

miles or more, depending on engine size and age, and warrants that the retrofit will not 

cause engine damage. 
H-10 

ARB’s verification procedure is a multi-level verification 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 procedure recognizes and verifies NOx 

reductions that are greater than or equal to 25 percent in 15 percent increments. This 

system has broadened both the spectrum of control technologies 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 approach to verification is consistent 

with the goal of achieving the maximum reductions in diesel PM emissions that are 

economically and technologically feasible. At this time, nearly all the verified emissions 

control strategies are retrofit exhaust after treatment 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-flow monolith or a silicon carbide 

substrate that captures PM before it can be released to the atmosphere. The 

accumulated soot is then burned off (regenerated) either through an active or passive 

process. In passively regenerated diesel particulate filters, the substrate is coated with a 

catalyst that burns off the collected PM during “regeneration.” In actively regenerated 

diesel particulate filters, an external source of heat such as an electrical heater or fuel 

burner is used to oxidize the collected PM. Vehicles with 2007 MY engines are already 

equipped with PM filters. Currently, the only technology 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 NOx 
H-11 

reductions. More information about VDECS, and applicable 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; 739 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 2,585 retrofits funded through the Transit 

Bus Program. In addition, 86 school buses have been retrofit using Diesel Emission 

Reduction Act funds and 1,000 Level 3 retrofits have been funded by the Goods 

Movement Emission Reduction Program. 

2. Feasibility 

Several fleets have informed staff that they have concerns 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 numerous on-road retrofit 

applications. Most medium-heavy and heavy-heavy duty 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 program, 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 collection vehicles and over 2,500 transit 

fleet vehicles already have VDECS installed on them. VDECS can be designed, 

installed, and operated to provide effective, reliable, and durable performance for most 

engines. If a VDECS is not technically feasible for the vehicle, the regulation allows a 

compliance extension until 2018. 

ARB has verified 9 passive and 5 active Level 3 VDECS for on-road vehicles. In short 

haul and low speed applications, a passive VDECS may not be a suitable choice 

because of the temperature requirements to burn off the trapped diesel PM 

(regeneration). However, an active VDECS can be used, which regenerates with a 

separate power unit to heat up the exhaust system to reach the required temperature. 

This can be done when the vehicle is moving or parked 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 mechanical fuel injected engines. 

Almost all vehicles with 2007 and newer engines are already equipped with PM filters 
H-12 

and are under the manufacturer’s warranty. The American 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 diesel engines. As part of that 

evaluation, the compatibility of the device with the engine is considered through testing 

that includes durability testing on operating vehicles. The device manufacturer must 

also demonstrate that the emission control device does not damage the engine and 

does not hinder the vehicle’s ability to perform its normal functions. Also, the device 

manufacturer is required to provide a warranty against 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. 

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.pdf

ARB, 2009. California Air Resources Board. Final Regulation Order. California Code 

of Regulations, Title 13, Division 3 Chapter 14. Verification Procedure, Warranty and InUse Compliance Requirements for In-Use Strategies to Control Emissions from Diesel 

Engines. January 2009. 

http://www.arb.ca.gov/diesel/verdev/reg/procedure_jan1009.pdf 

ATA, 2008, American Trucking Association’s Transport Topic Magazine. 

March 10, 2008. 

http://ttnews.com/articles/basetemplate.aspx?storyid=19317