# Reducing Diesel Emissions in the Denver Region

Report to the Regional Air Quality Council

and the Air Quality Control Commission Diesel Stakeholders Work Group May 2002We wish to thank all the individuals who participated in the Diesel Stakeholders Work Group and offered their time, expertise, and assistance to this effort. CO-CHAIRS David Sladek, P.E. Douglas Lawson, Ph.D. RegionalAir Quality Council (RAQC) Air Quality Control Commission (AQCC) REGULAR WORK GROUP PARTICIPANTS Jim Carothers Bob Farmer Lou Ha Jim Scherer Douglas County Citizen Regional Transportation RegionalAir Quality District Council Michael Castine Kerri Fiedler E

xhaust Repair EPA Region 8 Justin LaBoe Steve Scoma Tri-County Health Dept. S&S Services Dennis Creamer Charles Flatt Conoco, Inc

. Cummins Rocky Mountain Doug Lempke Dan TePoel Air Quality Control Comm

. The Emissions Clinic Joe Crowley Greg Fulton Progressive Auto Colorado Motor Carriers Robert Lowdermilk Gregg Thomas Performance Association Air Qualtiy Control Comm

. DenverDept. of Environmental Health Hilary Decker Brian Garber Marcy Mrozinski Environmental Defense Colorado Contractors DRCOG Gary Walk Association Douglas Co. School District Harry Ellison Mike Parsons Central Motive Power Frank Grasmugg Front Range Diesel Melissa Young City of Westminster Colorado Rock Products Association OTHER WORK GROUP ATTENDEES Karl Anderson Jeff Hajdu Robert McCormick Lucinda Smith Diesel Inspector Adams County NREL, formerly with City ofFort Collins Colorado School ofMines Kurt Andersen Jim lves Don Stedman Andersen ' s Foreign Car City ofAurora AI Papay University ofDenver Service Diesel Testing Center Mitch Jackson Laurence Tempest AI Andersen FedE x E x

press Allen Schaeffer Douglas Co

. School District Diesel Technology Forum Andersen' s Foreign Car Frank Johnson Blane West Service Colorado Attorney Steve Sherman Colorado Diesel General's Office CO Dept. of Transportation W. Gale Biggs Bud West W. G
. Biggs Associates Patricia Ludlow Lisa Silva Colorado Diesel Lockheed Martin CO Dept

. ofPublic Health and Environment Gene Woodekemper John Coil DRCOG Randy Matsushima Arrow Stage Lines Valero Energy Corp

. Jerry Gallagher J. Gallagher&Associates
REGIONAL AIR QUALITY COUNCIL STAFF Ken Lloyd, E

xecutive Director Gerald Dilley Misty Howell Sara O'Keefe Gary Smith Central Motive Power Ron Yeager UPS

CO DEPT. OF PUBLIC HEALTH & ENVIRONMENT MOBILE SOURCES PROGRAM STAFF Shirleen Tucker, Director , Mobile Sources Program Michael O'Toole Doug Decker Mike Bywater Ray Elick Art Hale Ted Hollman Rob Livo Richard Robison

# Table of Contents Glossary of Abbreviations & 

### Acronyms

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### Chapter I. Executive Summary

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### 1-1 Diesel Emissions Overview

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### 1-1 Work Group Overview

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### 1-3 Recommendations

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### 1-4 Implementation of Recommendations

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### 1-8 Chapter II. Overview

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### 11-1 Current Air Quality And Emissions

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### 11-1 Estimated Diesel Contribution to PM-20 5, NOx, and Visibility Impairment

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### 1 1 -4 Historical and Future Diesel Engine Standards

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### 11-5 Future Diesel Emissions Trends

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### 11-8 Chapter Ill. On-Road Diesel Vehicles

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### 111-1 Overview

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### 111-1 Recommendations

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### 111-1 Chapter IV. Diesel Inspection and Maintenance

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### IV-1 Background

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### IV-1 Current Colorado Programs

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### IV-2 Diesel 1/M Testing Procedures

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### IV-4 Programs in Other States

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### IV-6 Recommendations

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### IV-8 Summary of Diesel 1/M Recommendations

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### IV-19 Opacity Cutpoints

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### IV-20 Chapter V. Off-Road Diesel Vehicles

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### V-1 Overview

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### V-1 Recommendations

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### V-2 Appendix A National and Local Voluntary Diesel Retrofit Pilot Programs

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### A-1

## Glossary of Abbreviations 

## &Acronyms APCD Air Pollution Control Division 

### MY model year 

### AQCC Air Quality Control Commission 

### MOBILES EPA's new emissions estimation model 

### CARB California Air Resources Board 

### NA Naturally-aspirated (diesel engine) 

### CDPHE Colorado Department of Public Health and 

### NAAQS National Ambient Air Quality Environment Standards 

### CMCA Colorado Motor Carriers Association 

### NEMPPA Northeast Metro Pollution Prevention Alliance 

### CNG compressed natural gas 

### NFRAQS Northern Front Range Air Quality Study 

## co Carbon monoxide 

### NOV notice ofviolation 

### CY calendar year 

### NOX Oxides of nitrogen 

### DFSCP Diesel Fleet Self-Certification Program 

### OEM original equipment manufacturer 

### DOIP Diesel Opacity Inspection Program 

### PARTS EPA's mobile source particulate emissions model 

### DRCOG Denver Regional Council of Governments 

### PM Particulate matter 

### EPA Environmental Protection Agency 

### PM-2.5 particulate matter less than 2
.5 microns in diameter 

### G/BHP-HR grams per brake horsepower hour 

### PM-10 particulate matter less than 10 microns in diameter 

### G/Mi grams per mile 

### PPB parts per billion 

### GVWR gross vehicle weight rating 

### PPM parts per million 

### HC Hydrocarbon 

### PSIP Periodic Smoke Inspection Program (California) 

### HDDT heavy-duty diesel truck 

### RAQC Regional Air Quality Council 

### HDDV heavy-duty diesel vehicle 

### RPM revolutions per minute 

### 1/M Inspection/Maintenance 

### RSD Remote Sensing Device technology 

### LDDT light-duty diesel truck 

### SCR selective catalytic reduction 

### LDDV light-duty diesel vehicle 

### SIP State Implementation Plan 

### LDGT light-duty gasoline truck 

### TC turbo-charged (diesel engine) 

### LDGV light-duty gasoline vehicle 

### TPD tons per day 

### VMT vehicle miles traveled

# Chapter I. Executive Summary
Diesel Emissions Overview Diesel engines play Diesel engines have long been an important part ofthe American an important role in landscape and a critical part ofthe U

.S

. economy. From trucks on our the U.S. economy roadways to buses in our urban areas to off-road equipment in major construction projects, diesel engines provide a reliable , economical , and durable source of power for many commercial , industrial and transportation applications

. Many parts ofthe nation's economy - agriculture, freight movement, bus transportation , construction , mining -depend on diesel engines to provide the necessary power and performance to get the job done efficiently and effectively

. Diesel engines power 94% of all freight movement in the U.S

., through trucks, rail , barge or tractor
. Nationwide, diesel trucks haul 73% of all freight shipments, while in Colorado 90% of all freight manufactured in the state is moved by truck

. Diesel fuel contains more energy per unit volume than gasoline. Combined with their more efficient combustion process, diesel engines provide for as much as 45-60% better fuel economy than gasoline engines

. Because of the greater efficiency of diesel engines and greater fuel economy, diesel engines emit 30-35% fewer greenhouse gas emissions

. Airqualityand Despite many ofthe inherent advantages of diesel engines, diesel

public health emissions have important air quality and public health implications in many

implications urban areas around the country, including the Denver area. The Denver area has achieved remarkable success in improving its air quality and achieving EPA's health-based air quality standards

. The region has been in compliance with EPA standards for carbon monoxide, ozone (1-hour standard) and PM-1 0 for a number ofyears and is on the verge and gaining official attainment designation for all three pollutants

. In 1997 EPA set new, tougher standards for ozone (8-hour standard) and fine particulate matter (PM-2

.5)

. While the Denver region currently attains these standards, there is little room to spare and these standards will likely provide continued challenges in coming years.

1-1Significant advances in diesel technology will reduce emissions Chapter 1: Executive Summary In addition , the Denver area has long been plagued by its infamous "Brown Cloud ." The region typically exceeds the state's urban visibility standard , which establishes acceptable visual air quality, 50-85 days per winter season . Diesel engines are important contributors to these air quality challenges

. While there is uncertainty to the precise contribution , diesel emissions contribute: 

### .I 10-16% of regional primary PM-2

.5 emissions 

### .I 20-30% of regional NOx emissions, which contribute to PM-2.5 , ozone and visibility impairment 

### .I 15-23% of regional total PM-2

.5 (primary and secondary) 

### .I 25-40% of regional visibility impairment Small particles and diesel emissions have also been associated with a variety of public health effects, including respiratory and cardiovascular disease, aggravation of existing asthma, acute respiratory illnesses, chronic bronchitis, decreased lung function and even premature death and other toxic effects

. The effect on children , the elderly and those with preexisting illnesses is of particular concern. In addition , EPA has classified diesel emissions as a "likely" human carcinogen

. See Chapter II for more detailed information on airquality impacts ofdiesel emissions

. Over the last decade, there have been significant improvements in diesel technology that have resulted in significant reductions in emissions from new diesel engines

. Improvements in engine design , after-treatment technology, and diesel fuel have all contributed to improved emission performance

. The Diesel Technology Forum estimates that total emissions of PM and NOx from diesel engines have been reduced by 25-35% through the 1990s. Even more dramatic improvements in diesel technology will result in significant emissions reductions when new on-road engine standards take effect in 2004. In 2007, even tighter new engine standards, coupled with the introduction of ultra-low sulfur diesel fuel , will reduce emissions of PM and NOx by more than 90% for new engines

. EPA also set tighter emission standards for off-road diesel engines in 1998 and expects to propose more stringent standards in the near future that will take effect later this decade. While these new standards for on-road and off-road engines are significant, they will not have an immediate effect. Since diesel engines are very durable
1-2Chapter 1: Executive Summary and remain in operation for many years, it take many years to realize the full impact ofthese new standards as the diesel fleet gradually turns over. Nonetheless, significant opportunities exist to introduce new technology into the in-use fleet and take advantage ofthese emission reduction gains sooner. See Chapter II for more detailed information on new diesel engine standards and diesel emission trends.



## Work Group Overview Colorado first established a diesel emissions program in the mid-1980's

. A diesel inspection/maintenance program resulted from the Governor's BlueRibbon Diesel Task Force in 1987 and has remained in operation , essentially unchanged, even since

. The Regional Air Quality Council , the Denver region's lead agency for air quality planning, and Colorado Air Quality Control Commission both have an interest in the effective control of diesel emissions, not only along the Front Range but throughout Colorado. Concern over the potential impact of diesel emissions, coupled with recognition of recent and future advances in diesel engine technology, led the RAQC and AQCC to form a joint Diesel Stakeholders Work Group in August 2001
. The RAQC and AQCC charged the Work Group with four primary tasks: ./ Determine the impact of diesel emissions on Denver area air quality and assess the impact offuture programs; ./ Review the current Diesel Inspection/Maintenance Program and recommend improvements to make the program more efficient and effective; Explore opportunities and incentives for advancing clean diesel technology and other emission reduction techniques in the marketplace sooner; Assess contribution of off-road diesel engines and recommend opportunities for emission reductions

. The Work Group was open to all interested parties

. Participants included representatives from the trucking industry, public and private fleet operators, engine manufacturers, oil companies, emission testing operators, state and local governments, and environmental organizations

.

1-3

### On-Road 

### Diesel Vehicles Chapter 1: Executive Summary The Work Group met 10 times between October 2001 and May 2002 to hear relevant presentations on diesel topics and discuss the issues

. Presentations were made by a number of interested and knowledgeable groups:
PRegional Air Quality Council 

### PCO Dept. of Public Health and 

### PColorado Motor Carriers Association Environment, Air Pollution Control 

### P Diesel Technology Forum Division 

### PColorado Institute for Fuels and 

### PNortheast Metro Pollution Prevention

Engine Research Partnership 

### PColorado Contractors Association 

### PCummins Engine Rocky Mountain 

### P Environmental Defense 

### PWagner Equipment Co. PColorado Diesel Emissions Inspection P ldleAire Corp

.

and Maintenance Assoc

. 

### P EPA Voluntary Diesel Retrofit 

### PCalifornia Air Resources Board Program 

### Recommendations The Work Group is pleased to present the result of its review ofdiesel issues in the Denver region and offers recommendations for consideration by the Regional Air Quality Council and Air Quality Control Commission

. While every Work Group member may not necessarily agree with every recommendation , the recommendations and conclusions presented in this report represent the strong consensus ofthe Work Group

. Likewise, some members may feel strongly about some issues that they feel are not addressed adequately in the report. Even though most agree more work needs to be done, this report represents a solid starting point for addressing diesel issues and programs. Members ofthe Work Group stand ready to assist the RAQC, AQCC, Colorado Department of Health and Environment, the Governor's office, and the General Assembly with implementing these recommendations.
See Chapter Ill formore detail and background on these recommendations
#1 Fleet outreach andawareness program Establish a Fleet Outreach and Awareness Program to encourage voluntary initiatives by fleet operators to reduce diesel emissions from the current in-use fleet. This program could result in significant emissions reductions well in advance of new federal engine and fuel standards

1-4Chapter 1: Executive Summary The program would launch a significant outreach and awareness effort with private and public fleets in the Denver region and recognize fleet operators that undertake voluntary programs to reduce emissions from their fleet of diesel vehicles. Outreach to fleet operators would be accomplished through development and distribution ofwritten information, workshops and training seminars, one-on-one visits , and awards programs. The program would include elements outlined below

. 

### #2 Fleet recognition program Provide public recognition of voluntary efforts by fleet operators to reduce emissions as an incentive to consider programs that will benefit public health and air quality

. 

### #3 Bestpractices program for vehicle maintenance Encourage fleets to utilize best practices for vehicle maintenance by working with the Northeast Metro Pollution Prevention Alliance (NEMPPA) to expand NEMPPA's best practices maintenance program region wide

. #4 Strategies to reduce vehicle idling Work with industry experts to develop and distribute educational materials, conduct workshops, and implement pilot projects on measures to reduce idling and the economic and environmental benefits that could be derived

. #5 Accelerated vehicle retirement, retrofit, andalternative fuelprojects Work with fleet operators, engine manufacturers, fuel suppliers, and others to encourage early introduction of advanced diesel technology in in-use fleets, including accelerated engine replacement, retrofits , and cleaner fuels

. 

### #6 Diesel fleet survey Conduct a survey of public and private fleets in the region to determine the current composition of diesel vehicles in the area and to identify those fleets with innovative programs to reduce emissions

. 

### #7 Clearinghouse ofincentive programs and emission requirements Establish a web-based information clearinghouse to serve as a central repository locally where companies and potential users may quickly find current and accurate information relating to emission requirements, new technology, and potential incentives at the state and federal level to reduce emissions.

1-5

### Diesel Inspection/ Maintenance Program #1 Chapter 1: Executive Summary

See ChapterIVformore detail and background on these recommendations
Evaluation ofprogram effectiveness Review the Diesel Inspection/Maintenance program within the next two years to determine iffurther improvements are necessary and feasible

. Develop a research protocol and necessary funding to conduct periodic evaluations of program effectiveness. Identify further specific information and data needs and questions that need to be answered

. 

### #2 Automated data reporting Automate data reporting and analysis and develop an internet-based system for information exchange

. 

### #3 On-road enforcement Add an on-road enforcement element to the program , either through remote sensing , smoking vehicle hotlines, or limited roadside pullovers (based on probable cause). #4 Weight definition Define heavy-duty diesel vehicles as those greater than 14,000 pounds gross vehicle weight (GVWR) and eliminate the reference to empty weight or curb weight in Regulation No

. 12
. #5 Model year exemptions andbiennial testing Increase model year exemptions to four years for heavy-duty diesel vehicles and decrease test frequency to biennial testing for HDDV 10 model years and newer (beginning with MY 1995) under both programs. 

### #6 Testing ofvehicles operating in area Modify state statute to require testing of all diesel vehicles routinely operated in the program area, notjust those registered , required to be registered or housed in the program area as currently required

. #7 Testing protocols Maintain current testing protocols with the following changes:

- allow SAE J1667 (or other future automated testing protocol) as an option for all HDDV 10 model years and newer in the fleet program ;

- require lugdown test for all HDDV older than 10 model years in both programs; and

- eliminate visual testing , during a two-year phase in period , as an option for all HDDV in the fleet program older than 10 model years.

1-6Chapter 1: Executive Summary 

### #8 Emissions-based testing Since opacity is not a good measure ofemissions for newer technology vehicles, Colorado should work in a joint effort with the Environmental Protection Agency (EPA) and other states to conduct research and pilot studies to develop appropriate emissions-based testing methods for future consideration

. 

### #9 Focus auditprogram Improve audit program by focusing on HDDV fleets with higher than normal out-of-service ratings or fail rates
. #1 0 Technician training Expand repair technician training and technical assistance similar to the efforts for the gasoline vehicle program . #11 Clean screen remote sensing Investigate using remote sensing technology to clean screen light-duty diesel vehicles and identify high-emitting vehicles

. #12 Repair cost waiver



### Off-Road Diesel Vehicles Eliminate or increase the current repair cost waiver for failed diesel vehicles

. See Chapter Vfor more detail and background on these recommendations

. #1 Fleet Outreach andAwareness Program Include off-road fleets and engines in the fleet outreach , awareness and recognition program to encourage voluntary initiatives by fleet and engine operators to reduce diesel emissions from the current in-use equipment. #2 Use oflow-sulfur fuel Improve the understanding ofthe current use of low sulfur fuel (500 ppm) and the population of off road diesel equipment in the Denver metro area . 

### #3 Incentives to encourage use oflow-emitting fuels Based on the need , investigate incentives to encourage the use of low sulfur fuel (500 ppm) and other low emitting fuels and investigate the possibilities of early introduction of ultra-low sulfur fuels (15 ppm)

. #4 Best managementpractices Encourage best management practices regarding engine maintenance, idling and use. #5 Programs forlarge-scale construction projects Encourage low-emitting fuels, retrofits and other low-emitting technology in large-scale construction projects

.

1-7

### Colorado General Assembly Chapter 1: Executive Summary 

## Implementation of Recommendations Implementation ofthe Work Group's recommendations will take a concerted and coordinated effort by a number of parties

. Effective implementation will involve many parties, including CDPHE , AQCC , RAQC, the General Assembly, local governments, industry groups, fleet operators, and engine manufacturers. Specific implementation steps and responsibilities are addressed for each recommendation in Chapter Ill, IV, and V

. The following list summarizes the implementation responsibilities (with a reference to each recommendation #)

. The Work Group recommends the Regional Air Quality Council coordinate the implementation ofthe recommendations

. While the RAQC is not responsible for directly implementing many ofthe recommendations, the Work Group members believed the RAQC should be the organization responsible for facilitating the implementation ofthe recommendations and bringing the various parties together.


### Dieseii/M Program 

### P Authorize effective on-road identification and enforcement program (#3) 

### P Redefine HDDV/LDDV weight classification (#4) 

### P Increase model year exemptions and authorize biennial testing for newer HDDV (#5) 

### P Require testing of diesel vehicles that routinely operate in the program area (#6) 

### P Allow SAE J1667 or other automated testing for newer fleet vehicles (#7) 

### P Authorize clean screen remote sensing for LDDV (#11) 

### P Eliminate or increase current repair cost waiver (#12) 

### P Provide adequate funding for periodic evaluation of program effectiveness, automated data reporting, fleet audits, and technician training (#1,2,9, 10) 

### Fleet Outreach and Awareness Program 

### P Provide funding or tax incentives for upgrading and modernizing equipment through accelerated engine replacements, retrofits, or clean fuel use (#5)

1-8

### Colorado Department of Public Health and Environment Chapter 1: Executive Summary Off-Road Vehicles 

### P Provide funding or tax incentives for upgrading and modernizing equipment through accelerated engine replacements, retrofits, or clean fuel use (#1,3) 

### P Require or encourage large state-sponsored construction contracts to include specifications for upgrading and modernizing equipment through clean engine requirements, retrofits, or clean fuel use (#5)

Diesel liM Program 

### P Develop program evaluation protocol and seek appropriation for necessary funding (#1) 

### P Develop automated data reporting system with Department of Revenue and seek appropriation for necessary funding (#2) 

### P Evaluate on-road identification and enforcement approaches for consideration by General Assembly (#3) 

### P Participate in national efforts to evaluate emissions-based testing methods (#8) 

### P Implement procedures to improve fleet audit program and seek appropriation for additional funding if necessary (#9) 

### P Expand repair technician training and technical assistance program and seek appropriation for additional funding if necessary (#10) 

### P Evaluate feasibility of remote sensing clean screen program for LDDV (#11) Fleet Outreach and Awareness Program 

### P Provide technical assistance and possibly grant support to Green Fleets program (#1-7) Off-Road Vehicles 

### P Provide technical assistance and possibly grant support to Green Fleets program as it relates to off-road fleets (#1-4) 

### P Encourage state agencies to consider, in large state-sponsored construction contracts, specifications for upgrading and modernizing equipment through clean engine requirements, retrofits , or clean fuel use (#5)

1-9

### Air Quality Control Commission

Regional Air Quality Council Chapter 1: Executive Summary Diesel 1/M Program (Revisions to Regulation 12) 

### P Conduct an annual review ofthe Diesel 1/M program (#1) 

### P Define and require compliance with automated data reporting (#2) 

### P Eliminate visual testing , during a two-year phase in period , as an option for all HDDV in the fleet program older than 

### 10 model years (#7) 

### P Promulgate regulation revisions for items enacted by General Assembly (#1-7 , 11, 12) Fleet Outreach and Awareness Program 

### P Provide recognition for exemplary fleets under fleet recognition program (#2) Off-Road Vehicles 

### P Encourage state agencies to consider, in large state-sponsored construction contracts, specifications for upgrading and modernizing equipment through clean engine requirements, retrofits, or clean fuel use (#5)

Overall 

### p Coordinate implementation ofWork Group recommendations endorsed by RAQC and AQCC (all) Dieseii/M Program 

### P Publicize review by Work Group and recommendations endorsed by RAQC and AQCC (all) 

### P Assist CDPHE, AQCC, and General Assembly, as necessary, with evaluating implementing recommendations (all) Fleet Outreach and Awareness Program 

### P Take the lead in working with other program sponsors and supporters to establish and implement the Fleet Outreach and Awareness Program (#1-7) 

### P Coordinate fleet recognition program (#2) 

### P Develop materials and outreach approaches for program (#1-7) 

### P Establish a web-based information clearinghouse (#7) 

### P Seek necessary funding from grants and private contributions to implement the Fleet Outreach andAwareness Program and associated pilot projects (#1-7)

1-10Chapter 1: Executive Summary Off-Road Vehicles 

### P Take the lead in working with other program sponsors and supporters to establish and implement the Fleet Outreach and Awareness Program, which includes off-road fleets (#1-4) 

### P Work with industry associations to determine the use of lowsulfur diesel fuel and the population off-road diesel equipment in the Denver metro area (#2) 

### P Encourage local governments and private develops to consider, in large-scale construction projects, specifications for upgrading and modernizing equipment through clean engine requirements, retrofits, or clean fuel use (#5)

1-11

# Chapter II. Overview
Current Air Quality And Emissions Due to considerable local effort in woodburning , street sanding/sweeping , industrial source control regulation and inspection/maintenance programs for gas vehicles and federal standards the Denver metro area is currently in attainment for all federal air quality standards

. At this time , it appears that the area will most likely attain the new federal 8-hour ozone and PM2
.5 standards

. The State Visibility Standard is consistently exceeded 50-85 times each winter season. 

### Denver Area Air Quality Status Existing federal The Denver area is currently attaining all federal air quality standards, standards including carbon monoxide (CO) , PM-1 0, and one-hour ozone. The Denver area achieved official attainment redesignation status from EPA for one-hour ozone in October 2001 and carbon monoxide in effective January 2002. The attainment redesignation request for PM-1 0 is pending before the Environmental Protection Agency (EPA) , which plans to propose approval ofthe region 's plan and request shortly. New federal The Denver area currently attains EPA's new 8-hour ozone standard, but

standards by only a small margin (less than five percent)

. In 1998, the Denver area recorded elevated levels of ozone throughout the region ,jeopardizing the area's continued attainment ofthe standard. However, during the last three summers (1999-2001 ), ozone readings returned to normal levels

. Though the 8-hour standard is 80 ppb, violation ofthe standard occurs when a three-year rolling average ofthe 4th maximum readings at a monitor in the region is equal or greater than 85 ppb

. 8-hour Ozone The following chart presents the annual 4 th maximum readings ofthe two (of eight) monitors (NREL and Rocky Flats) each with the current (1999- 2001) highest 3 year average of 81 ppb

.
11-1100 90 80 70 60 50 40 30 20 1 0

0 Chapter II: Overview 

### - l 4th Maximum Ozone Levels (ppb) 

## I

## ~------**----------~~, ~** 

.U= ..,-**~** 

# - "'**~** 

## \ l 

# ""' \3 year average 0 f 4th max 

# "" = 85 ppb =violation 

## I 

# """-so ppb 8 - Hour Ozone Standard

1996 1997 1998 1999 2000 2001 1 -+--NREL - Ro cky F lat s 

## I**L_------------~==========~========~--------J** PM-2.5 PM-2

.5 monitoring using EPA's new federal reference method only began in 1999 and therefore a complete, fully representative set of data from the 7 monitoring sites is not available to judge the Denver area's ultimate attainment status
. Violation ofthe 24-hour standard occurs when the 3 year average of the 71h maximum is 65 ug/m 3 or greater
. The current 3 year average (1999- 2001) ofthe 51h maximum readings at CAMP is 33 ug/m3

. The maximum 24-Hour PM-2.5 levels at CAMP are presented in the following chart

.



### 80 70 

### 60 50 40 30 20 10



### 0 Maximum 24-Hour PM2.5 (ug/m3) CAMP-2105 Broadway**~** 65 ug/m3
- 24-Hour Standard / 

# ./'

.- ...c> / .-A

## ~

# ------ v 

### "'

1999 2000 2001 

# -l

-

---

-

-

### ~ 1st Max ----- 2nd Max ----..- 3rd Max 4th Max**~** 5th Max

11-2Chapter II: Overview Violation ofthe annual standard occurs when the 3 year average ofthe annual averages of a monitor is 15 ug/m 3 or greater. The current 3 year average (1999-2001) ofthe annual average readings at Adams City is 11
.5 ug/m 3

. The annual average PM-2

.5 levels at Adams City and CAMP are presented in the following chart.


### Annual Average PM2.5 ug/m3 20 ,-----------------------------------------, 

## ¥" 15 ug/m3- Annual Average Standard 15**+- --~------------------** **----------~ ~~r-----** **~**

## 10**+- --~** **~~~==~====== ----­**  

# ......- 5 

## +------------------------------------------ 0**+-------------,-------------,-------------~** 1999 2000 2001 ! -+-Adams City

### -t~-**CAMP**

State visibility In 1990 the Colorado Air Quality Control Commission (AQCC) established 

### standard an urban visibility standard (0.076/km) to serve as a goal and a measure of visual air quality (i.e

., the Brown Cloud)

. The Denver area typically exceeds the visibility standard during 50-85 days per winter season , with 10-20 ofthose days in the extremely poor category (greater than twice the standard). 

### Visibility Standard Exceedances**100 ~-----------------------------------,**  

### 80**+------- ----------------------~**  

### 60**+- ~~** **-------- --** **L- --------~** **~** 40**+-----------------------------------~ 20** **~-~~._~~~~~~~ ----** **~~**



### 0**+-~--~--~~--~--~~--~--~~--~~** "!),**~** b<**~** !0**~ ~** **~~** "!),**';!)~** ......**~ n~** **~OJ ~Oj** **~Oj !()~** **~9) ~Oj**  

### SS**';!)~** ......**~** Oj**~ ~** **~** OJ Oj Oj**~** OJ**~ ~** **~** 

## I**~** Exceedance Days - Extremely Poor Days 

## I
* Monitoring Equipment out of service for repair at this time

.

11-3Chapter II : Overview 

## Estimated Diesel Contribution to PM-2.5, NOx, and Visibility Impairment Diesel emissions contribute to both PM and NOx. The following presents a range of potential diesel contribution to the total PM-2.5 and NOx for all sources , based on different analytical approaches:

NO/ Primary Sec. Total PM- Visibility PM-2.5* PM-2.5* 2.5* On-road 10-15% 3-12% 3% 10-15% 15-25% diesel Off-road 10-15% 3-5% 2-4% 5-8% 10-15% diesel Total 20-30% 10-16% 5-7% 15-23% 25-40% diesel *Expressed in percent oftotal PM-2

.5 and NOx from all sources. Totals for primary PM-2.5 do not add since the ranges come from different sources. Range of diesel contribution estimates come from a variety of local and national sources based on different analytical approaches

. The on-road diesel contribution is approximately 97% heavy-duty diesel vehicle (HDDV) and 3% light-duty diesel vehicle (LDDV) emissions

. Considerable uncertainty exists on the total diesel contribution and the relative contribution of on-road and off-road sources, but the ranges capture the uncertainty

. The lower end ofthe ranges for primary PM-2.5 come from the 1998 Northern Front Range Air Quality Study (NFRAQS) , which was a PM-2
.5 apportionment study that based its estimates on emission factors derived for the study, ambient measurements ofvarious components , and chemical mass balance modeling

. NFRAQS concluded that diesel engine emissions contribute approximately 15% to total PM-2

.5 (primary and secondary) while gasoline engine emissions contribute approximately 38% to total PM-2.5

. The higher end ofthe ranges come from local and/or national emission inventories

. Local inventories are based on NFRAQS emission factors for diesel vehicles, local diesel fuel usage, and local activity factor estimates

. The local/national inventory data suggest that diesel engine emissions contribute approximately 23% to total PM-2.5 while gasoline engine emissions contribute approximately 15% to total PM-2

.5
.

11-4Historical Certified Emissions Standards Chapter II : Overview Secondary PM-2

.5 estimates are further derived from NOxemission inventory estimates and NFRAQS measurements of ammonium nitrate

. Under stagnant inversion conditions, the contribution to secondary PM-2

.5 from gasoline and diesel vehicles may in fact be higher since mobile NOx emissions will contribute disproportionately to ground-level nitrate concentrations. Estimates of potential visibility impairment are based on light extinction coefficients for various compounds

. Primary diesel emissions are composed of about 80% elemental carbon , which has the greatest light extinction efficiency and about double the contribution of nitrate and organic mass and about 10-20 times greater than dust or other coarse particles

. Diesel vehicles and equipment are relatively insignificant contributors to carbon monoxide (CO), hydrocarbons (HC) and total PM-10 (3% or less).


## Historical and Future Diesel Engine Standards
On-Road Heavy Duty Diesel Emissions Standards 1970-85 - Emissions standards for heavy-duty diesel engines were introduced in 1970 with a 13 mode steady-state test procedure which continued through the 1983 model year. In 1974 HC+NOx and CO standards were introduced

. Additionally, opacity smoke standards were tightened to levels (Accel=20% , Lug=15% and Peak=50%) which are current today. The first NOx emissions standard (10

.7 g/bhp-hr) and an optional transient test were added in 1984
. The steady state test was eliminated in 1985
. 1988-98 -A PM standard (0

.6 g/bhp-hr) was added in 1988 and PM and NOx standards continued to be tightened (6.0 g/bhp-hr) in 1990 and 5
.0 g/bhp-hr in 1991) to their current levels (4

.0 g/bhp-hr in 1998) through this period as shown in the chart on the following page. Technological changes began in 1990 with turbocharging , retarded fuel injection timing , etc., initial use of electronic controls started in 1991 and was used on most engines by 1994 and nearly all engines by 1998
. Oxidation catalysts and improvements to combustion chamber design were introduced in 1994
. Further improvements in turbocharging continued through 1998
. Future Certified 2002-04 - In 2004 a NOx + HC standard of 2
.5 g/bhp-hr, with a HC limit of Emissions Standards 0
.5 g/bhp-hr was introduced

. In a Consent Decree with the federal government, six engine manufacturers agreed to produce engines meeting the 2004 standard by October 2002
. 11-5Chapter II : Overview 

### 2007

- The emissions standards for PM and NOx continue to be lowered in 2007 to 0
.01 g/bhp-hr for PM and 0
.20 g/bhp-hr for NOx as shown on the following chart. To achieve 2007 standards an ultra-low sulfur fuel (sulfur content 15 ppm) is required

. Also , technology to achieve the 2007 standards includes catalyzed traps, oxidation catalysts, NOx absorbers , and selective catalytic reduction systems
.

7
.0 -.::- 6
.0 .s::. 6.. 5
.0 :§ 4.0 

### :§ 3
.0 >< 2
.0 0 

### z 1
.0 0
.0 "" 

## 1On-Highway Heavy Duty Diesel Engine Emissions Standards

"\



# ...r+-**~** 1 \. 

# -

# - 1 \. 1

- 

# - "\**~** 

# - 1990 1993 1996 1999 2002 2005 2008 [- Nox -+-PM [


### On-Road Light-Duty Diesel Emissions Standards**~** 0
.7 0
.6-.::- 0
.5 

### -'r 0.4 

## _g. .c 0
.3 

### c, 0
.2 

# i 0
. 1 

### a.. 0

Tier 1 Standards Light-duty diesel vehicles (LOOV) and light-duty diesel trucks (LOOT) (promulgated 1990) through 2003 require a 1
.0 gram/mile (g/m) NOx standard

. By contrast gasoline fueled vehicles were required to meet a 0
.6 g/mi (light-duty gas vehicle (LOGV) & light light-duty gas trucks (Light LOGT) and 1
.53 g/mi (Heavy LOGT) NOx standard in 1994
. In 1999 NOX standards were further lowered for 0
.3 g/mi (LOGV) , 0
.5 g/mi (Light LOGT). Particulate standards of 0
.10-0
.12 g/m applicable to all light-duty cars and trucks were set to accommodate diesel engine technology

. At the time diesel vehicle could just make the standard , while gasoline-fueled veh icles could easily achieve 0.01 g/mi

. Tier2 Standards All light-duty cars and trucks, including the heavier, light-duty trucks, and (promulgated 1999) regardless offuel will be required to achieve the same standards during a phase-in period beginning in 2004 and ending in 2009
. The light-duty cars and trucks will begin phase in (25% per year) to meet a 0
.07 g/mi NOx standard in 2004
. The heavier light-duty trucks will begin phase in (50% per year) to meet a 0.07 g/m NOx standard in 2008
.

11-6

### Tier 1 Standards (promulgated 1994) Chapter II : Overview During phase in those vehicles not meeting the ultimate standard will meet an interim standard

. The light-duty cars and trucks will meet an average 0
.3 g/mi interim NOx standard

. The heavier light-duty trucks will meet an average 0
.2 g/mi interim NOx standard beginning in 2004
. The light-duty cars and trucks will meet a PM standard 0
.01 to 0
.02 g/mi in 2004 depending on the "bin" selection of the manufacturer. Particulate standards for the heavier light-duty trucks will be in the range of 0
.08 to 0
.06 g/mi from 2004 until 2006. Ultimately by 2007 the PM standard of 0
.01 to g/mi is required

. 

### Off-Road Heavy-duty Diesel Emissions Standards Tier 1 Standards for off-road engines were established in 1994 and began to be phased in for various horsepower ratings in 1996 through 2000
. As shown in the following table, Tier 1 standards will remain in effect until the Tier 2 and/or Tier 3 standards take effect. 

### Tier2 and Tier3 Tier 2 and Tier 3 standards were established in 1998 to be phased in for 

### Standards various horsepower ratings between 2001 and 2008 as shown in the 

### (promulgated 1998) following table

.



### HP <11 11<25 2.5<3) fD<100 100<175 175<m n><aX) 

### Em<

### ?ED

>?ED Off-Road Heavy-Duty Engines NOx+HC and PM Emissions Standards (g/bhp-hr) (NOx + 

### HC I PM) 

# 200)1200112002 2003 

### 2004 2005 

# 2003l200712lm 7.8/Q75 5.610.60 7.1/Q60 

### 5.610.60 7.1/Q60 

### 5.610.45 7.610.72 5.610.30 

# I3.5/- 7.3/0.40 

### 4.9/0.22 

# I 3.0/- 7.3/0.40 4.910.15 3.0/- 7.3/0AOI 4.8/Q15 3.0/- 7.3/0.40 

# I 4.8/Q15 3.0/- NA/0.40 4.8/Q15

11-7Chapter II : Overview Off-Road Fuel Current off-road fuel standards allow 5000 ppm in sulfur content. Work Standards group discussion indicates that most public works and private construction companies are using fuel with 500 ppm sulfur content in off-road equipment. Unlike the current (2006-07) on-road standards that call for a reduction in fuel sulfur content (from 500 ppm to 15 ppm) to help meet stringent new engine standards , the current Tier 2 & 3 off-road standards do not incorporate lowered fuel sulfur content standards

. Tier 2 

### &3 standards are well above the established on-road standards for the same 2006-07 time frame

. 

## Future Diesel Emissions Trends On-Road PM Baseline diesel primary PM-2

.5 emissions for on-road for the Denver metro area have been taken from the 1995 inventories developed by the RAQC for the Blueprint for Clean Airplanning process (1996-98)

. The trend curves however start at the year 2000 since at that time monitored emissions indicated attainment ofthe PM standards. Emissions were based on emissions factors developed during testing of 33 HDDV operating in the metro area for the Northern Front Range Air Quality Study , 1998 and Denver Regional Council of Governments (DRCOG) vehicle miles traveled (VMT) estimates. Trends in future on-road emissions were developed using certified emissions factors and diesel VMT mix over time from MOBILE6

.1 support data and VMT growth rates from the recent PM-10 Maintenance Plan , 2001
. MOBILE6

. 1 national data indicate approximately 70% ofthe VMT is caused by vehicles in the first 10 MY, while the remaining 30% of the VMT is caused by vehicles in the 11 th through 30thmodel year (MY)

. Data from the Air Pollution Control Division (APCD) and the Colorado Motor Carriers Association (CMCA) indicates that the Denver metro area may have a 67%/33% split in VMT. Additionally, difficult economic times for the trucking industry slowing the purchase of newer vehicles was analyzed by assuming 50% ofthe VMT was produced by the first 10 MY and 50% produced by the 11 th through 30t hMY

. The trends are presented in the following chart

.

11-8Chapter II: Overview PM-2.5 Emissions Trend- tons per day

2000 2005 2010 2015 2020 

# 1 - - 50% VMT/1st 10 MY -··-·-. National -Denver

# I
On-Road NOx Baseline diesel NOx emissions for on-road for the Denver metro area in 1995 are based on a recent analysis of MOBILE6.0 by the APCD using certified NOx emissions factors and DRCOG VMT estimates

. Trends in on-road emissions were developed using certified emissions factors and diesel VMT mix over time from MOBILE6

.0 support data and VMT growth rates from the recent PM-1 0 Maintenance Plan , 2001. As discussed above for PM , NOx emissions trends based on the EPA national data, Denver metro data and an assumed hardship condition in the trucking industry slowing the rate of newer vehicles entering the fleet are presented in the following chart. NOx Emissions Trend- Tons per day**,-------------------------------------------~**

0**+--------.--------.--------,,-------~------~** 2000 2005 2010 2015 2020

-- 50% VMT/1st 10 MY ·- ·- ··· National -Denver

11-9Chapter II: Overview 

### Off-Road PM The 1995 baseline PM and NOx emissions are consistent with inventories 

### and NOx from the Blueprint for Clean Airplanning process, which are based on the 20 Cities Study , EPA, 1990. The trend curves start with the year 2000 since the region was attaining all NAAQS at that time. The trends for construction , industrial and rail are based on population , activity and certified emissions factors developed from the EPA Non Road Model by the APCD for the recent PM-1 0 Maintenance Plan , 2001
. The trends for PM and NOx are presented in the following charts

.
Off-road Diesel NOx Emissions Trends EPA Non-road Model Metro Area

2000 2005 2010 2015 l oconstruction •Industrial ORail l

Off-road Diesel PM Emissions Trends EPA Non-road Model

1.8 1
.6 a.. 1
.2 !::.. 1
.0 0 0
.8 

### i 0
.6 a.. 0.4 0
.2 0
.0 Metro Area

2000 2005 2010 2015 

## I 0 Construction •'ndustrial o Rail

11-10

# Chapter Ill. On-Road Diesel Vehicles

Establish 

### a Fleet Outreach and Awareness Program 

## Overview As indicated earlier, significant advances in diesel engine technology have led to considerable reductions in diesel emissions over the last two decades. Diesel engine manufacturers and fuel suppliers have worked together to dramatically reduce emissions from diesel engines while at the same time improving reliability, durability, and fuel efficiency

. Tighter future standards for new diesel engines will continue to reduce emissions over the next 10-20 years. Despite these gains, the turnover ofthe diesel fleet to cleaner engines can take many years because ofthe durability and long road life of diesel engines

. There are still opportunities to reduce emissions from the in-use fleet through proper maintenance, reductions in vehicle idling , accelerated vehicle retirement, add-on equipment retrofits, and use of cleaner diesel fuels

. Fleet operators in many areas ofthe country are currently implementing a variety of programs to introduce new technology sooner and reduce diesel emissions

. EPA has established a national Voluntary Diesel Retrofit Program to help build partnerships among industry, community groups, and state and local officials to implement retrofit projects that result in cleaner, healthier air for their communities

. The Diesel Technology Forum , an organization of diesel engine and emission control manufacturers and petroleum refiners, has also been an active promoter ofthe concept of retrofitting existing diesel engines to reduce emissions as a cornerstone ofthe Forum's overall program to advance clean diesel technology

. 

## Recommendations To take advantage ofthese opportunities to reduce diesel emissions in innovative ways, establish a Fleet Outreach andAwareness Program to encourage voluntary initiatives by fleet operations to reduce diesel emissions from the current in-use fleet.

111-1Chapter Ill : On-Road Diesel Veh icles The Fleet Outreach andAwareness Program would launch a significant outreach and awareness effort with private and public fleets in the Denver region and recognize fleet operators that undertake voluntary programs to reduce emissions from their fleet of diesel vehicles

. Outreach to fleet operators would be accomplished through development and distribution ofwritten information , workshops and training seminars, one-on-one visits, and awards programs. The Fleet Outreach and Awareness Program would include elements outlined below

.
Fleet Recognition Many fleets operators nationally and in the Denver area are implementing Program or planning a variety ofvoluntary programs to reduce emissions from their existing diesel fleet. Public recognition ofthese efforts can give fleet operators an incentive to consider programs that will benefit public health and air quality

. Implementation: A special recognition program would be established to highlight public and private fleets and supporting companies that have undertaken significant voluntary efforts to reduce diesel vehicle emissions

. Criteria would be established for recognition and nominations will be solicited for judging by an independent panel. Exemplary fleets would be recognized at a special ceremony with an award and would be allowed to display a program logo

. Fleets would also be recognized through advertising , media placements, on appropriate web sites, and in promotional materials. The fleet recognition program would be a cooperative effort ofthe Governor's Office, the Regional Air Quality Council (RAQC) , the Colorado Department of Public Health and Environment (CDPHE), the Colorado Motor Carriers Association (CMCA) , and other sponsoring organizations

. Best Practices Well-maintained diesel vehicles produce less pollution than vehicles that Program for Vehicle are not rigorously maintained. By implementing best practices for vehicle Maintenance maintenance, fleet operators not only will reduce vehicle emissions but will also reduce operating and long-term maintenance costs
. Implementation: Building upon a program initiated by the Northeast Metro Pollution Prevention Alliance (NEMPPA) , the Fleet Outreach and Awareness Program will assist with expanding the best practices maintenance program region wide

. Using NEMPPA's Best Practices Manual , the outreach effort will assist companies and truck owners in developing an effective vehicle maintenance program that will reduce diesel emissions. Particular attention will be given to individual truck owners and

111-2Chapter Ill: On-Road Diesel Vehicles smaller fleets who do not possess the expertise or resources associated with maintaining vehicles in optimal running order. The effort will also be coordinated with CDPHE's training program for repair technicians. Strategies to Reduce One area where significant emission reductions can be realized is in the Vehicle Idling area of excessive vehicle idling

. Advances in engine technology and other types of technology makes excessive vehicle idling unnecessary and costly to 

## the truck owner. Excessive engine idling increases fuels costs, maintenance costs and engine wear for truck owners. According to information provided by Cummins Rocky Mountain , engine idling costs a truck owner $0

.75-1
.12 per hour, or $4

.50-6
.75 per day in wasted fuel , and can result in two additional oil maintenance intervals per year at a cost of at least $200. In addition , since oil additive packages tend to degrade more quickly during idling , excessive idling will tend to accelerate the accepted normal rate of engine wear. There are several strategies that can be employed to reduce vehicle idling

. One ofthe first steps is greater education on the economic and environmental impacts of excessive idling

. There are also engine control systems that monitor and control the idling of engines while maintaining block temperature, battery voltage and/or cab temperature
. In addition , truck owners can employ management strategies, such as fuel economy incentives, to encourage drivers to reduce idle time

. Another promising strategy to reduce engine idling is truck stop electrification , where systems are installed at truck stops, rest areas, or terminals

. Such systems provide heat and air conditioning as well as electrical shore power inside and outside stationary trucks, allowing drivers to turn off their truck engines while they rest or wait to load and unload. Pilot projects are underway in several areas ofthe country, including New York and southeast U

.S. Implementation : Greater education on the economic and environmental impact of excessive idling and on idling reduction strategies and equipment could inform truck operators and help reduce emissions

. As part of this effort, the Fleet Outreach andAwareness Program will work with industry experts to develop and distribute educational materials and conduct workshops on measures to reduce idling and the benefits that could be derived

. The program could also work with a local truck stop to implement a pilot project to reduce vehicle idling, including truck stop electrification.

111-3Accelerated Vehicle Retirement, Retrofit, andAlternative Fuel Projects Chapter Ill : On-Road Diesel Vehicles New diesel engine technology, control devices, and fuel changes continue to result in remarkable reductions in diesel emissions

. Opportunities exist to introduce these technological advances into the marketplace sooner through voluntary programs that encourage: • accelerated retirement of pre-1990 trucks and buses and replacement with newer, cleaner engines; • retrofits with after-treatment (post-combustion) control devices, such as catalytic converters and particulate traps; • installation of low-NOx calibration devices in advance of engine rebuild as required by federal consent decree; • use ultra-low sulfur fuel in combination with after-treatment control devices; and • use of alternative fuels, such as compressed natural gas (CNG) and biodiesel. The U.S. Environmental Protection Agency (EPA) has developed the Voluntary Diesel Retrofit Program as an immediate solution to reducing emissions from existing diesel construction equipment and heavy-duty vehicles operating on the road today

. EPA's goal is to reduce emissions from the existing fleet until new diesel standards take effect in 2007
. According to the Diesel Technology Forum , the initial, narrow definition of retrofits has been expanded to include the "5 R's" of upgrading and modernizing diesel equipment- repowering , rebuilding, retirement, refueling, and retrofitting

. The goal ofthe EPA's program was to secure , by the end of 2001 , commitments to retrofit 100,000 trucks, buses, and construction vehicles with commercially available emission control technologies

. As ofthe end of 2001 , EPA calculated over 70,000 vehicles committed to retrofit equipment. See Appendix A for a summary of current voluntary retrofit projects around the nation

. As part of the immediate effort to reduce diesel emissions, EPA developed a web site- www.epa.gov/otaq/retrofit- devoted to helping fleet operators, air quality planners in state/local government, and retrofit manufacturers understand the voluntary program and obtain the information needed to implement voluntary retrofit projects

. In addition , the web site explains the economic incentives to the program and emissions credit trading

. Also, the web site lists verified retrofit technologies, including retrofit manufacturers, type oftechnology, and the percentage of emissions reductions

.

111-4Chapter Ill : On-Road Diesel Veh icles Formore information on EPA ' s Voluntary Diesel Retrofit Program, visit the EPA ' s OTAQ web site at www.epa.gov/otaqlretrofit

. Also consult the Diesel Technology Forum ' s web site at www.dieselforum.org formore information

. Implementation : As part ofthe outreach effort with fleet operators, the Fleet Outreach andAwareness Program will provide information on retrofit/retirement options for reducing emissions and maintain a data base of pilot projects around the country
. Materials will provide information on the costs and benefits ofthese actions

. The program will work with truck owners, vehicle manufacturers, and government agencies on public-private partnerships to fund such projects

. Such incentives could come from grants, tax exemptions or rebates, manufacturers' rebates, and other sources. Diesel Fleet Survey A survey of diesel fleets operating in the Denver area, and possibly along the Front Range, is needed to determine the current composition of diesel vehicles in the area. The survey will be useful for the recognition program by identifying those fleets with innovative programs to reduce emissions

. The survey will also be used to target fleets for particular outreach efforts. Implementation :The RAQC will work with the CMCA and its members to prepare and distribute the survey and compile the results. Clearinghouse of A number of programs exist at the state and federal level which provide Incentive Programs incentives for acquiring low emission vehicles or equipment related to and Emission retrofitting vehicles to reduce emissions

. There are also a myriad of new Requirements and existing emission requirements for diesel vehicles

. According to the industry, truck owners and operators have difficulty finding current and comprehensive information on incentive programs and regulatory requirements

. Implementation : The Fleet Outreach andAwareness Program will serve as a central repository locally where companies and potential users may quickly find current and accurate information relating to emission requirements, new technology, and potential incentives at the state and federal level to reduce emissions

. A web site will be developed to serve as a clearinghouse of information on the fleet program including:
• dates, times, and locations ofworkshops and annual awards ceremony; • recognition of exemplary fleets; 111-5

### Cost and Funding Sources Chapter Ill : On
-Road Diesel Vehicles
• access to NEMPPA's Best Practices Manual ; • information on vehicle idling reduction strategies; • access to database highlighting nationwide pilot projects using accelerated retirement, retrofit, ultra-low sulfur fuel , and alternative fuels; • access to a database containing information relating to emission requ irements and potential incentives at the state and federal level to reduce emissions; • access to all promotional materials created from the fleet program ; and • access to the final report put together at the end ofthe first year, including survey results

. The RAQC staff estimates the first year of the Fleet Outreach and Awareness Program will cost approximately $125 ,000
. This includes the stafftime to develop materials, coordinate events and workshops, visit fleet operators, and document the results

. It also includes costs to produce materials, establish the web site, prepare awards, sponsor workshops and recognition events, and promote the program . The RAQC will take the lead in seeking sources of funding for the program and preparing funding proposals and applications

. Potential sources offunding include various EPA grant programs (including the Voluntary Diesel Retrofit Program , which has expressed significant interest in a retrofit project in the Denver area) , private sector contributions, other public sector grant programs, and foundations

.

111-6

# Chapter IV. Diesel Inspection and Maintenance Background In the mid-1980s concern for the Denver area's "Brown Cloud" led the state legislature to launch diesel emission control activities in the State of Colorado

. Legislation passed in 1986 required all diesel vehicle owners in the AIR Program area to pay a $10 per vehicle registration to fund diesel vehicle emissions control activities ofthe CDPHE and Department of Revenue

. The fee , which remains in effect today, is deposited into the AIR account ofthe highway users tax fund , subject to annual appropriation

. The fee is used to fund the state's diesel inspection program as well as other related studies

. In 1986, the Air Pollution Control Division Mobile Source Program studied the use of a loaded mode test on 13 excessively smoking light-duty diesel vehicles to determine the impacts of maintenance on opacity and emissions reduction

. The Metropolitan Air Quality council, the lead local air quality planning agency at that time, recommended a diesel inspection and maintenance program in a lengthy report (January 1987) to "help significantly reduce "Brown Cloud"-causing particulate emissions from metro area diesel vehicles". In 1987 the EPA designated the Denver metro area as a "Group 1" PM-1 0 nonattainment area due to high levels oftotal suspended particulates in the air

. In September 1987 a Governor's Blue Ribbon Panel was convened to address excess diesel smoke emissions from on-road vehicles

. The Diesel Fleet Self Certification Program , a self-test program for fleets of nine or more heavy-duty vehicles, was established in 1987. The Diesel Opacity Inspection Program (DOIP) for all other diesel vehicles including light-duty cars and trucks and heavy-duty vehicles was established in 1990 and included a $5 fee per tested vehicle to provide support ofthe diesel portion ofthe APCD's Mobile Source Program

. Historically, diesel 1/M programs have focused on smoke emissions not only because of their apparent direct link to air pollution but also because of nuisance and public perception issues

.

IV-1Chapter IV: Diesel Inspection and Maintenance The Colorado Diesel liM program was included in the initial PM-10 State Implementation Plan (SIP) adopted by the AQCC and approved by EPA. However, the AQCC removed the program from the PM-1 0 maintenance plan that was submitted to EPA in July 2001
. Upon final approval of the maintenance plan by EPA, the Diesel 1/M program will no longer be part ofthe federally-enforceable SIP and changes to the program will not require EPA review and approval. 

## Current Colorado Programs Light-dutyDiesel Vehicles- State statute (42-4-406, C

.R.S

.) and Colorado Air Quality OpacityInspection Control Regulation 12 (Regulation No

. 12) requires light-duty diesel Program (DOIP) vehicles registered or required to be registered or operating from a facility in the nine-county AIR Program area to be inspected annually at a state licensed decentralized light-duty diesel testing station under the DOIP

. There are currently 31 state licensed (decentralized) inspection stations in nine-county Front Range AIR Program area. A two model year exemption is currently allowed

. State statute and Colorado Regulation No

. 12 defines a light-duty diesel vehicle as a vehicle weighing 7,500 pounds empty weight (curb weight) or less

. Such vehicles could have a gross vehicle weight (GVWR) up to 16,000 pounds

. Test Procedure - The inspection includes a full-load lugdown test on a light-duty diesel dynamometer with an opacity meter used to measure visible smoke in the exhaust. The opacity cut point for naturally aspirated vehicles is 40% and turbo charged vehicles is 35%
. Approximately 1-2% ofthe vehicles tested in calendar years (CY) 2000 and 2001 failed their first test. Mandatory repairs are required for failing vehicles

. Costs
- In CY 2000 approximately 18,000 vehicles were inspected/tested at an average of $44 per vehicle, which includes a $5/vehicle fee sent to the state
. Also , $10 ofthe vehicle registration fee is sent to the state AIR account. The mean repair costs for a failed LDDV was reported to be $217. Heavy-duty Diesel Vehicles- State statute (42-4-406, C.R.S.) and Regulation No. 12 OpacityInspection requires heavy-duty diesel vehicles registered or required to be Program (DOIP) registered or operating from a facility in the AIR program area to be inspected annually at a state licensed decentralized heavy-duty diesel testing station under the DOIP. There are 31 state licensed (decentralized) inspection stations in the nine-county Front Range AIR Program area. A two model year exemption is allowed.

IV-2Chapter IV: Diesel Inspection and Maintenance State statute and Colorado Regulation No

. 12 defines a heavy-duty diesel vehicle as vehicle weighing greater than 7,500 pounds empty weight. Such vehicles probably will have a GVWR greater than 16,000 pounds. 

### Test Procedure - The inspection includes a full-load lugdown test on a heavy-duty diesel dynamometer with an opacity meter used to measure visible smoke in th· e exhaust. The opacity cut point for naturally aspirated vehicles is 35% and turbo charged vehicles is 20%
. Approximately 1-2% ofthe vehicles tested in CYs 2000 and 2001 failed their test. Mandatory repairs are required for failing vehicles. 

### Costs- In CY 2000 approximately 13,000 vehicles were inspected/tested at an average of $65 per vehicle , which includes a $5/vehicle fee sent to the state
. Also , $10 of the vehicle registration fee is sent to the state AIR account. The mean repair costs for a failed HDDV was reported to be $571. The RAQC staff estimated indirect cost to an owner at $50 per vehicle to take the vehicle in for inspection and return to home base, assuming a total of 2 hours at $25 per hour for a shagger/driver

. Heavy-duty Diesel 

### Vehicles- State statute (42-4-414, C.R.S.) and Regulation No. 12 Fleet Self- requires heavy-duty diesel vehicles in fleets of nine heavy-duty vehicles Certification Program or greater, registered or required to be registered in the AIR program (DFSCP) area, to be inspected annually

. Fleets are allowed to provide an annual self-inspection prior to registration under the Diesel Fleet SelfCertification Program. A two model year exemption is allowed

. 

### Test Procedure- A full load test is required , but lugdown , stall or acceleration options are allowed , and the test can be done on-road or with a dynamometer. Opacity meter measurement or visual assessment of smoke is allowed during the testing

. The opacity cut point for naturally aspirated vehicles is 35% and turbo charged vehicles is 20%. Approximately 0.5% ofthe vehicles tested in CYs 2000 and 2001 failed their first test. Mandatory repairs are required for failing vehicles

. 

### Costs
- Fleets in the self-certification program do not pay a vehicle inspection fee to the state
. However, $10 ofthe vehicle registration fee is sent to the state AIR account. There are approximately 22 ,000 fleet vehicles in the AIR Program area. In CY 2000 approximately 14,580 vehicles were self inspected/tested

. The RAQC staff estimated indirect cost to an owner at $25-30 per vehicle for an inspection , assuming a total of45 minutes per inspection at a $35 per hour rate for an inspector-technician

. The mean repair costs for a failed HDDV

IV-3Chapter IV: Diesel Inspection and Maintenance
was reported to be $927

. No estimate has been made of indirect costs for training of inspection officer, test equipment or out of service vehicles.
Additional Program The continued use ofvisual observers in the self-certification fleet Observations program is considered questionable

. The continued use of opacity as a surrogate measurement tool to identify high- emitting vehicles is questionable in light ofthe poor correlation between opacity and PM emissions

. At best opacity levels identify some but not all high-emitting engines

. The data reporting and analysis system is considered to be inadequate because the in-use optical mark reader/fill-in-the-bubble paper forms are time consuming, limited, and subject to inaccuracy and error. The computer system where the data is stored and analyzed is obsolete, cannot be updated , and cannot communicate with other interrelated databases (e

.g. the self cert fleet audit database etc
.)

. Migration and registration outside AIR Program area is an issue because a diesel vehicle normally housed and serviced outside the AIR Program area, but normally operated within the AIR Program area is not currently required by statute to be inspected

. The interpretation of "required to be registered or operating from a facility in the AIR Program area" by the APCD is that a vehicle normally housed and serviced in the AIR Program area should either be registered in the program area (and therefore inspected annually) or be inspected annually regardless of location of registration

. Data from a 1998-99 DRCOG study at the borders ofthe metro area indicate approximately 7,000 large diesel vehicles (greater than 7,500 lbs

. GVWR) registered in Colorado, displaying no inspection sticker and starting and ending the day at the owner's lot/terminal enter/leave the metro area on a daily basis. Using the reported 13,000 DOIP inspected vehicles, the 22,000 DFSCP vehicles and the up to 7,000 vehicles noted above, it can be estimated that approximately 17% (7,000/42,000) ofthe Colorado HDDV vehicles operated in the metro area on a week day basis are not currently annually inspected. This does not include out-of-state vehicles

. 

### Diesel 1/M Testing Procedures Colorado Lugdown The Colorado 1/M programs utilize a full load test, which measures stabilized full power operation , similar to "pulling a grade" with a load

. Vehicles are tested at full power load applied on a dynamometer; or using vehicle brakes or transmission. Colorado uses a full power-load applied test on a
IV-4Chapter IV: Diesel Inspection and Maintenance dynamometer for the DOIP

. The DFSCP utilizes a full power-load applied test but allows an option of using a dynamometer, vehicle brakes or transmission. The current federal opacity certification level for a lug test is 15%, which was established in 1974
. Most vehicles today are tested at certification well below 10% opacity

. The lugdown test on a dynamometer is considered a better test for diagnosis of problems in failing vehicles

. It is also a time-consuming and costly test compared to a J1667 snap acceleration test. The current Colorado opacity cut points (20% for turbo charged vehicles) do not fail approximately 10%-15% ofthe heavy-duty fleet that would fail the current J1667 test procedure. Currently, two other states , Arizona and Utah , with mature diesel 1/M programs, utilize a full-load test. At such time that shop grade PM measurement equipment is available (some estimate two years hence) , a loaded test on a dynamometer will most probably return to favor

. Although California's roadside pullover program currently uses the J1667 snap test, California is actively testing a roadside dynamometer

. SAE J1667 The SAE J1667 procedure is a no load test, where the engine throttle is "snapped" wide open from idle speed to governed revolutions per minute (RPM) in a series of three clean out snaps and a series ofthree snap tests averaged together

. The test measures transient acceleration smoke opacity

. The EPA recommended opacity cut points are 55% for MY 1991 and older and 40% for MY 1992 and newer.

Comparison: Colorado Lugdown and SAEJ1667 The test is inexpensive requiring only an opacity meter
. The test is completed very quickly, taking approximately 5 to 10 minutes

. EPA is currently recommending the SAE J1667 test procedure to states considering heavy-duty diesel 1/M programs, until such time that shop grade PM emissions testing technology is available

. At that time, EPA will review its position on the J1667 test and opacity testing in general. California uses the J1667 test procedure for both their Roadside Program and Fleet (Periodic Smoke Inspection) Program

. A study in Colorado Springs, CO in 1997 applied the J1667 test with EPA recommended cut points to a group of approximately 120 HDDV that had just completed the Colorado lugdown test at the current program cut points in the DOIP

. It was found that the approximately 17% ofthe vehicles failed the J1667 test while only 1
.7% ofthe same vehicles failed the Colorado lugdown test. Rather than suggesting that one test is better than the other this study suggests that the cut points are not set appropriately for an equivalent test.

IV-5Chapter IV: Diesel Inspection and Maintenance A study in New York by EEA in 2000 using 37 HDDV, J1667 testing , and the Radian malperformance model demonstrated that lugdown testing and repair with appropriate opacity cut points (15% for pre-1991 vehicles and 10% for post-1991 vehicles) would result in equivalent PM reduction found in a J1667 testing and repair program with EPA-recommended cut points

. 

## Programs in Other States California Programs California operates two vehicle inspection programs that are distinct in that they are codified in different parts of state statute. They were also adopted in different years. However, the Roadside Program is a stand alone program adopted in 1988, while the Periodic Program adopted in 1990 derives its enforcement authority from the legislation that established the Roadside Program. California Heavy-Duty Vehicle Inspection Program (HDVIP) Vehicles & Test- All (570,600 estimated) HDDV traveling California's roads - interstate, intrastate, international - are subject to roadside enforcement based on visual observation followed by an immediate SAE J1667 (snap-accel.) test.The opacity cut point for the J1667 test for pre 1991 HDDV is 55% ; while for 1991+ HDDV it is 40%. Penalties- Pre-1991 HDDV with opacity measurements between 55 and 70% are given a Notice ofViolation ("fix it ticket") requiring repair within 45 days without penalty; failure to repair vehicle results in a citation ($300) plus added penalty of $500

. Citations are issued to all others vehicles (pre-1991 vehicles above 70% and all post-1991 failing the cut points)

. The penalties are $300 to $1800 and possible vehicle impoundment depending on number of citations issued before compliance

. Fail Rate- In California's testing program 64,648 visual Inspections were performed between June 1998-September 2001
. During this time frame 1 ,154 notice ofviolation (NOVs) and 3,384 citations were issued. This established a fail rate of 7% ofvisually inspected vehicles

. Program managers indicate that they currently test approximately 20,000 vehicles annually and continue to expect a 7% fail rate, which equates to approximately 1,400 vehicles failed annually. Cost- Estimates of cost of repairs and fuel saved are approximately equal. The total program costs are estimated at $5

.6 million annually based on vehicle owners cost estimated at $1

.9 million for increased maintenance

IV-6Chapter IV: Diesel Inspection and Maintenance and lost opportunity cost oftime and the State cost of $3

.7 million annually to inspect the vehicles

. Highway Patrol cost in support ofthe inspection program is not included

. The annual program cost is estimated at $280 per vehicle inspected.
California Periodic Smoke Inspection Program (PSIP) Vehicles & Test- All fleets of 2 or more California-registered HDDV, approximately 291 ,600 HDDV, are subject to an annual self-inspection which includes the SAE 

### J1667 (snap-acceleration) test. A 4 model year exemption is allowed , which is estimated at 26% ofthe fleet vehicles

.The opacity cut point for pre-1991 HDDV is 55% and for 1991+ HDDV the cut point is 40%
. Compliance Audit- The California Air Resources Board (CARB) audits fleets for compliance- less than 1% ofthe fleets require formal action

. State cost for auditing the fleets is approximately $0

.5 million annually

. Fail Rate - A 7% failure rate ofthe inspected vehicles is estimated by program managers. Cost- Estimates of cost of repairs and fuel saved are approximately equal. The cost of selftesting is borne solely by the vehicles owners and is estimated at $18

.1 million annually based on costs for labor, test equipment, contract testing and increased maintenance costs
. The annual program cost is estimated at $84 per vehicle inspected. Summary of Currently 17 states and two Canadian provinces have some oftype of Programs in Other diesel 1/M program . Many have a road side testing element while several States and Provinces have fleet self-certification programs. The following table, excerpted from a report prepared by Environment Canada, summarizes the various programs in North America

.

IV-7Chapter IV: Diesel Inspection and Maintenance

SAEJ1667 Test Procedure Lug-Down Test States & Provinces Fleet Self Traditional Fleet Self Traditional Road Side Cert. 1/M Cert. 1/M Arizona X British Columbia X California X X Colorado X X Connecticut X Illinois X X Indiana (vol.) X Maine X Maryland X Massachusetts X X Nevada X NewYork City X X NewYork (outside NYC) X NewHampshire X New Jersey X Ontario X X Rhode Island X X Utah (Davis Co.) X Utah (Utah Co.) X Vermont X Washington X X


## Recommendations Since Colorado's diesel inspection/maintenance (1/M) program was first established nearly 15 years ago, diesel vehicle technology has changed dramatically and emissions from light-duty diesel vehicles and heavy-duty trucks and buses have been reduced significantly

. These technological changes are not reflected in the current program . Taking into account the advances that have occurred in the last 15 years, the Diesel Stakeholder Work Group clearly recognized the current program is not as efficient or as effective as it could be

. There are no quantitative data available to judge how effective the current program is reducing diesel emissions

. However, many program observers believe the program provides undeniable benefits as an incentive for good maintenance and as a deterrent to vehicle tampering. Through in-depth discussions over a period covering six meetings, the Work Group considered changes to make the program both more efficient and more effective

. The recommendations outlined below are intended to reduce the burden ofthe program on vehicle owners, particularly those who have invested in new engine and vehicle technology. Other recommendations will help ensure the program identifies high-emitting vehicles that require repair and maintenance to reduce diesel emissions

.

IV-8Chapter IV: Diesel Inspection and Maintenance It is important to remember that a diesel inspection/maintenance program is a particulate matter (PM) reduction strategy. The program identifies vehicles with high levels of smoke that indicate excessive particulate emissions. An 1/M program cannot be viewed as a NOx reduction strategy since poorly performing diesel vehicles generally lower NOx emissions and repairs and maintenance to make the engine operate properly increase NOx emissions. Studies have shown , however, that NOx emissions after repairs are still within certified limits for the vehicles

. Necessary NOx emission reductions therefore need to be addressed through other types of diesel strategies, such as engine replacement and retrofits, idling strategies, and fuel strategies

. Maintain the basic The Work Group concluded current structure of Colorado's diesel structure ofthe inspection/maintenance program is well-established and accepted by currentprogram diesel vehicle owners. However, there are changes that can be made within the current structure that will make the current program more efficient and effective

. The discussion below presents the recommendations from the Work Group, explains the rationale , and indicates the implementation steps that are need to accomplish the recommendation

. Following the discussion are tables that summarize the net effect ofthe recommendations and summarize what will need to be addressed through statutory changes and what can be handled with current regulatory and administrative authority

. Recommendation #1 Review the Diesel Inspection/Maintenance program within the next two years to determine if further improvements are necessary and feasible. Develop a research protocol and necessary funding to conduct periodic evaluations of program effectiveness. Identify further specific information and data needs and questions that need to be answered. A strong feeling by the Work Group was expressed concerning the lack of a diesel 1/M program review in the past 

### 15 years since the start ofthe program . It is obvious that the current program has not kept pace with changing standards and diesel technology since shortly after program inception. A review in the next two years seemed appropriate to review what has been accomplished and what is needed in the future in light of more stringent standards taking effect in 2004 and 2007. Once the direction ofthe diesel emissions program is reestablished , a means to track progress toward that goal should be included in the program redesign

. This applies regardless ofwhat type of program -

IV-9Chapter IV: Diesel Inspection and Maintenance periodic inspection , roadside enforcement etc; or the goal ofthe program -PM, opacity, citizen complaints , etc
. A pre-changeover baseline measure should be taken ,with periodic evaluation by the same measure to ensure progress is being made. Measurement tools need to be in place before the changeover

. This would provide a tool for assessing program effectiveness

. The discussion of program needs has been open ended

. Often the data are available , but are not easily accessible or need to be looked at in a different way. Specific information and data need to be obtained that can provide answers to questions and issues that have not been addressed

. Implementation- Currently there is no requirement or process for a systematic, regular review ofthe Diesel 1/M program . Existing statute requires the AQCC to review the Diesel 1/M program fail rates annually, but this has not been an in-depth review that would provide a critical analysis ofthe performance and effectiveness ofthe program . Within the next two years, the RAQC and AQCC should undertake another stakeholder process to perform as add itional review of the program , assess implementation of current recommendations , and determine future program needs

. In the meantime, technical staff with the CDPHE Mobile Sources Program ,with assistance from the RAQC , should initiate studies or data analyses to answer some questions remaining after the current stakeholder process. Funding from the General Assembly will be needed to conduct a more rigorous periodic evaluation of program effectiveness

. CDPHE should determine the cost of such an effort and seek an appropriation from the legislature during the next legislative session

. Recommendation #2 Automate data reporting and analysis and develop an internet-based system for information exchange. The in-use optical mark reader/fill-in-the-bubble paper forms are time consuming, limited, and subject to inaccuracy and error. The computer system where the data is stored and analyzed is limited in its capabilities, obsolete , cannot be updated , and cannot communicate with other interrelated databases (e

.g. the self-cert fleet audit database etc
.)

. Data collection , storage , analysis, and reporting need to be redesigned from front to back as an integrated system , fully accessible to program staff. On-line data collection may be an attractive option- Inspector enters inspection data directly into a keyboard , eliminating handling of paper forms

. IV-10Chapter IV: Diesel Inspection and Maintenance No current cost estimate has been developed for an up-to-date system
. Implementation- The APCD Mobile Source Program will have to analyze program data and management needs, reporting needs for fleet and non-fleet vehicle inspectors and develop cost estimates for an up-todate and expandable data management and analysis system that will be useful into the future

. The CDPHE will have to seek legislative appropriation of funds from the AIR account to implement such a system
.
Recommendation 

### #3 Add an on-road enforcement element to the program, either through remote sensing, smoking vehicle hotlines, or limited roadside pullovers (based on probable cause). In California and other states, on-road enforcement has proven to be an effective supplement to the state's fleet inspection program . The threat of on-road enforcement has encouraged proper maintenance on diesel vehicles and improved compliance with the periodic inspection program . On-road enforcement will also identify vehicles with excessive smoke and emissions that have either fallen into disrepair or somehow escaped periodic inspections

. California's on-road enforcement program involves roadside pullovers of heavy-duty diesel vehicles with excessive smoke. State police and trained inspectors identify vehicles on the road and conduct an on-thespot roadside SAE J1667 test. Vehicles thaffail the test are issued a citation and required to bring the vehicle into compliance with necessary repairs

. California's program costs $5.6 million per year and identifies 1 ,400 vehicles per year. An on-road pull over program in Colorado would most likely use the SAE 

### J1667 test procedure

. A confirmatory test would be required at a state licensed inspection station , which uses the Colorado lug down test procedure

. To provide a consistent evaluation ofthe vehicle, the current difference in fail rates due current cut points ofthe two tests, discussed previously in this report, will have to be addressed

. Other methods for on-road vehicle identification exist, including smoking vehicle hotlines, identification by trained personnel, and remote sensing

. Smoking vehicle hotlines use citizen complaints to identify problem vehicles, but owner compliance tends to be voluntary

. The City and County of Denver operates an effective smoking vehicle program whereby trained city staff identify smoking vehicles on the road

. Vehicle owners are issued a citation where they are required to fix vehicle or face legal action

.

IV-11Chapter IV: Diesel Inspection and Maintenance Remote sensing technology (RSD) is under development to identify both heavy-duty and light-duty diesel vehicles

. An improved version of RSD that can take accurate opacity readings for light-duty vehicles is close to commercial application

. However, remote sensing for heavy-duty vehicles is more challenging since their exhaust points vary and are more difficult to measure. It is envisioned by the Work Group that any on-road enforcement program will start out on a small scale and be phased in gradually over time. This will provide the opportunity to implement the program efficiently by working through the pitfalls of such a new approach. Implementation- Statutory authority (42-4-413, C

.R.S

.) for on-road identification and enforcement currently exists, but it proved insufficient to withstand initial challenges in court by owners ofvehicles involved in an enforcement action in the late 1980's

. Since that time law enforcement officers have not given on road enforcement a high priority. Therefore new legislation likely will be necessary to strengthen statutory authority to identify vehicles on the road and provide an effective mechanism for enforcement. Recommendation 

### #4 Define heavy-duty diesel vehicles as those greater than 14,000 pounds gross vehicle weight (GVWR) and eliminate the reference to empty weight or curb weight in Regulation No. 12. The current definition of light-duty vs . heavy-duty vehicles is based on the 7,500 pounds empty weight (curb weight) limit, which means the weight ofthe vehicle at the curb filled with all of its required fluids. Such lightweight vehicles can then be outfitted to do specific work and may in fact have a GVWR up to 16,000 pounds

. This recommendation seeks to separate the transportation vehicles (driven to ajob site or office and left to the end ofthe day, or pulling a boat on the weekend) from the working vehicles (outfitted as a tow truck, for instance)

. Implementation - Since the current definition of light and heavy-duty vehicles is currently in state statute a statutory change will be required

. Since the current Air Quality Regulation also defines and describes the testing of light and heavy-duty vehicles, a regulatory change will also be required

.

IV-12Chapter IV: Diesel Inspection and Maintenance Recommendation #5 Increase model year exemptions to four years for heavy-duty diesel vehicles and decrease test frequency to biennial testing for HDDV 10 model years and newer (beginning with MY 1995) under both programs. The technology for light-duty diesel vehicles has also improved and new Tier 2 standards affecting light-duty vehicles will take effect within two years. However, the Work Group does not recommend increasing the model year exemptions for these vehicles beyond the current two-year exemption

. Anecdotal information provided from actual observations by emissiontesting representatives indicates light-duty diesel vehicles used for personal use may not be as well-maintained continuously like commercial vehicles. Unlike gasoline vehicles, diesel vehicles may experience emission problems while performing acceptably to the owner. In addition , after-market add-on equipment is more prevalent with light-duty vehicles and may change the emission performance ofthese vehicles. Without annual inspections, these vehicles may be emitting high levels of pollution without the owner realiz)ng the condition. Maintaining a two-year model year exemption and an annual inspection cycle for light-duty vehicles will ensure these vehicles continue to operate at their designed low emission levels

. The net effect ofthe increased model year exemptions and biennial testing for newer vehicles is that heavy-duty diesel vehicles will be tested three times during their first 10 years, compared to eight times under the current program . This will save vehicle owners at least $300 per vehicle in testing costs over this time period

. Current statute also requires heavy- and light-duty diesel vehicles to pass an emissions test before they can be registered upon change of ownership. The same requirement applies for the gasoline vehicle emissions testing program . The Work Group does not recommend changing this requirement in current statute
. Requiring an emissions test upon change of ownership is a consumer protection issue and protects vehicle purchasers from hidden emission problems

. The General Assembly has considered this on several occasions for the gasoline program and has resisted attempts to alter the requirement. Implementation- Since current statute specifies a two-year exemption and an annual testing requirement after the initial exemption, legislation will be necessary to increase the model years exemptions and decreasing the testing frequency for newer heavy-duty vehicles

. Legislation can be introduced as early as the 2003 session ofthe General Assembly.

IV-13Chapter IV: Diesel Inspection and Maintenance Recommendation #6 Modify state statute to require testing of all diesel vehicles routinely operated in the program area, not just those registered, required to be registered or housed in the program area as currently required. Current statute (42-4-406, C

.R.S.) requires emissions testing for all diesel vehicles that are registered , required to be registered or are principally operated from a terminal , maintenance facility, branch or division located within the program area. Still , it is believed that many vehicles that routinely and continuously operate in the program area avoid the testing requirement either by ignoring (intentionally or unintentionally) the law or by registering and/or housing the vehicles outside the program area . The Work Group recommends closing the loophole by requiring all vehicles that routinely operate in the program area be subject to emission testing requirements , as similarly required ofvehicles in the gas program , regardless ofwhere they are registered or housed. There will also be a need for greater education on and enforcement ofthis and the current requirement so that vehicle owners comply with the law

. Currently there is no requirement for a windshield inspection sticker, but proof of emissions inspection is required to be carried in the vehicle. An on-road enforcement program will also help identify problem vehicles that are avoiding the requirement. Implementation- Legislation will be necessary to modify current statute (42-4-406 & 414, C.R.S.) to require testing for vehicles that routinely and continuously operate in the program area, regardless ofwhere they are registered or housed

. The APCD will also need to increase its education and compliance efforts so vehicle owners do not avoid the requirement. Recommendation #7 Maintain current testing protocols with the following changes:

- allow SAE J1667 (or other future automated testing protocol) as an option for all HDDV 10 model years and newer in the fleet program;

- require lugdown test for all HDDV older than 10 model years in both programs; and

- eliminate visual testing, during a two-year phase in period, as an option for all HDDV in the fleet program older than 10 model years. The lugdown emissions test is currently required for both the fleet and DOIP programs. The test is generally performed on a dynamometer and is considered an effective test for measuring opacity from diesel vehicles

.

IV-14Chapter IV: Diesel Inspection and Maintenance SAE J1667 is a relatively new test that is being used in many states, including California

. The test is an automated acceleration test that is generally easier and less costly to perform

. However, it measures a different operating condition than the current lugdown test. The Work Group recommends allowing fleet operators the option to use the J1667 test, or some other approved automated testing procedure, on heavy-duty vehicles that are 10 years old and newer. The fleet operator would have to choose J1667 or lugdown for a// its newer vehicles and would not be able to pick and choose

. Again , since these newer vehicles are inherently cleaner, J1667 should be able to identify emission-related problems in these vehicles, especially during acceleration

. The lugdown test, which "exercises" the engine more, is still recommended and considered best for older vehicles

. The lugdown test would also still be required for all vehicles in the DOIP

. The Work Group also recommends eliminating visual observation as an option for the lugdown test for fleet vehicles older than 10 years. Current regulation allows fleet operators to measure opacity either though visual observations or with an opacity meter
. The use of an opacity meter is required in the DOIP and most fleet operators as well already use an opacity meter, which is more accurate and reliable than visual observation

. The mandatory use of opacity meters would be phased in over a two-year period. Visual observations would still be allowed in the fleet program for newer vehicles, which should be smokeless and for which visual observation should be satisfactory

. 

### Implementation- Current statutory language concerning testing methods is fairly specific and does not allow J1667

. Legislation will be necessary to allow J1667 and other automated testing protocols

. The testing provisions should be less specific so the Air Quality Control Commission (AQCC) has authority to modify testing protocols and requirements as new protocols are developed and become more appropriate. Eliminating visual observations for tests of older vehicles does not appear to be constrained by current statute, so the AQCC can make necessary revisions to Regulation No

. 12 to address this issue. However, the AQCC may want direct legislative authority to change this requirement.

IV-15Chapter IV: Diesel Inspection and Maintenance Recommendation #8 Since opacity is not a good measure of emissions for newer technology vehicles, Colorado should work in a joint effort with EPA and other states to conduct research and pilot studies to develop appropriate emissions-based testing methods for future consideration. Opacity testing is currently the measurement of choice for all diesel 1/M programs. Measurement is based on a light extinction opacity meter or visual observation by a trained smoke inspector

. Although high opacity readings will indicate high PM emissions; low opacity does not necessarily indicate low PM

. The current diesel engines are clean , virtually smokeless at certification and durable through their expected life. This has been accomplished through changes in engine design. However, lugdown testing still finds some newer engines that have excessive smoke above the 20% opacity standard. Engines designed for 2006 and beyond will include environmental control equipment such as catalyzed traps, selective catalatic reaction (SCR) systems, oxidation catalysts, and NOx absorbers that potentially will fail without increasing smoke. Emissions based testing will be needed at that time to identify vehicles not operating at near certification levels

. CO and/or CO + HC emissions measurement under peak operating conditions may be a better surrogate for PM emissions than opacity

. Shop grade measurement equipment is currently available

. Direct PM emissions measurement technology is still under development; possibly available within a year or two
. No estimate of required funding has been made. Implementation- Because the current statutes reflect an opacity-based program for the Diesel 1/M programs, a statutory change may be required or desired to fully investigate this issue. In the interim the RAQC/APCD should participate in national diesel conferences , EPA work groups and committees, and activities in California diesel 1/M development to monitor the direction of criteria pollutant diesel emissions based 1/M programs. Identified required research will require funding

. Recommendation #9 Improve audit program by focusing on HDDV fleets with higher than normal out-of-service ratings or fail rates. The APCD staff currently visit every DFSCP terminal or yard at least once per year to audit the testing programs. However, failure rates overall of the DFCSP vehicles are in the range of 0.5 %, while the DOIP vehicles have a 2% fail rate.
IV-16Chapter IV: Diesel Inspection and Maintenance It has been suggested that more effort should be focused on those fleets (large and small) that have a poor safety record

. There is a strong feeling that vehicles that are not meeting safety standards are more than likely those that are also not meeting current opacity standards

. Additionally, an emphasis should be made to address the fleets that have high fail rates regardless of size. It has been suggested that the Federal Motor Carriers Safety Administration Motor Carrier Safety Profiles Out Of Service (OOS) rating , which is internet accessible , be used to help focus audit efforts. The current staffing level can now barely meet the current regulatory requirement for the DFSCP audit. Implementation -This recommendation may be handled administratively by the Mobile Sources Program by directing and focusing resources on problem fleets

. Ifadditional resources are necessary, an additional appropriation from the General Assembly will be necessary. Recommendation Expand repair technician training and technical assistance similar to #10 the efforts for the gasoline vehicle program. The APCD Mobile Source Program currently does not have a Diesel repair training program , although a "tech night" for the diesel repair industry has been held recently wherein diesel repair issues were addressed by APCD staff and repair experts. Original Equipment Manufacturers (OEMs) also provide diesel technician training programs, but these are generally only available to those working for larger fleets

. A diesel repair training program should be similar to the existing APCD Mobile Sources (MS) gasoline 1/M repair industry outreach/training system and should include: Emissions Technical Centers acting as a clearinghouse for specific diesel repair/diagnostic information ; repair information to be made available to involved parties via print, phone, Tech Night', training classes, web site etc
. This repair information is not intended for the general public - liability; and basic electronic/electrical training

. Requires resource commitment by CDPHE as well as a commitment by fleets, repair shops, manufacturers, and inspection stations to share repair/diagnostic information. The effectiveness ofthis project depends on the level of industry participation

.

IV-17Chapter IV: Diesel Inspection and Maintenance Implementation -This recommendation may be handled administratively by the Mobile Sources Program by directing and focusing resources on training and technical assistance

. If additional resources are necessary, an additional appropriation from the General Assembly will be necessary. Recommendation Investigate using remote sensing technology to clean screen light- #11 duty diesel vehicles or identify high-emitting vehicles. Advances in remote sensing technology may soon allow more accurate opacity measurements for light-duty vehicles

. Therefore , the technology may exist to screen out clean (low-opacity) , light-duty diesel vehicles and exempt them from routine emission tests
. This could operate similar to the approach envisioned for the gasoline inspection program. High emitting vehicles could also be identified by the same technology

. Implementation of such an approach would exempt clean vehicles that do not need be tested and would focus efforts on vehicles that are more likely to have emission problems

. It would significantly decrease the burden oftesting on diesel vehicle owners

. Implementation- Given the current state of remote sensing technology, APCD and RAQC should investigate the feasibility of implementing a clean screen and/or high emitter program for diesel vehicles and integrating it with the gasoline vehicle remote sensing clean screen program . If a clean screen or high emitter program is determined to be feasible , legislation will be necessary to authorize implementation of such a program and provide for the mechanism administer the program consistent with the gasoline program . Recommendation Eliminate or increase the current repair cost waiver for failed diesel #12 vehicles. The highest number ofwaivers requested per year in the past two years has been four

. Keeping the waiver limit is unnecessary. Ifthe waiver limit is retained it should be raised to an appropriate level and adjusted to an index annually. There is a strong feeling that failing vehicles need to be repaired

. Repair data indicates that partial repairs do not fix the problem. Implementation- A statutory change is required to eliminate the concept of a waiver rate
. A regulatory change is required to increase the waiver rate.

IV-18Chapter IV: Diesel Inspection and Maintenance 

### Summary of Diesel 1/M Recommendations The following list summarizes the Work Group's recommendations by indicating those that will make the current program more efficient, those that will make the current program more effective, and those that keep current program elements the same. Recommendations - making the program - more efficient

Recommendations - maintaining current elements -

Recommendations - making the program more effective - Define HDDV as those >14,000 pounds GVWR Increase model year (MY) exemption for HDDV to 4 years (both programs) Decrease test frequency to biennially for HDDV 10-MY and newer (both programs) Allow choice ofJ1667 or lugdown test for HDDV 10-MY and newer in fleet program Automate data reporting and analysis Investigate using RSD technology to clean-screen LDDV Expand repair technician training Conduct periodic evaluations of program effectiveness Maintain basic structure of Diesel Opacity Inspection Program (DOIP) and Diesel Fleet Self-Certification Program (DFSCP) Maintain 2 model year (MY) exemption for LDDV Maintain annual testing for all LDDV Maintain annual testing for HDDV older than 10 MY (both programs) Maintain change of ownership testing requirement for all LDDV and HDDV Maintain visual observation testing option for HDDV 10 MY and newer in the fleet program Maintain lugdown tests for HDDV older than 10 MY in the fleet program and for all HDDV in DOIP Require all vehicles operating (not just registered or housed) in the program area to participate in the program Add an on-road enforcement element to the program Eliminate visual testing , over two-year period , for fleet HDDV older than 10 MY in the fleet program Investigate emissions-based testing methods for future consideration Improve audits offleet programs Expand repair technician training Eliminate or increase the current repair ost waiver for failed vehicles Conduct periodic evaluations of program effectiveness

IV-19DFSCP HDDV 

# . . 14,001 & 

# . greater GVWR 

# .

. DOIP HDDV 

# . 14,001 & 

# . greater GVWR



# .



# . DOIP LDDV 

# . . 14,000 & less 

# . GVWR Chapter IV: Diesel Inspection and Maintenance Comparison of Recommendations Affecting Newer and Older Vehicles

(10 Model Y ear Break Poi nt)

Newer Vehicles Older Vehicles (1 0 MY and newer) (> 10 MY) Allow visual test 

# . No visual test allowed after a Alloweither J1667 or the two-year phase in period ; current lug-down test opacity meter required Biennial testing for 10 MY 

# . Req uire the current lug-down and newer (beginning test wl1995 MY) 

# . Annual testing 4 MY exemption No visual test allowed ; opacity 

# . No visual test allowed ; opacity meter requ ired meter requ ired Requ ire the current lug-down 

# . Requ ire the current lug-down test test Biennial testing for 10 MY 

# . Annual testing and newer (beginning wl1995 MY) 4 MY exemption Requ ire current lug-down test 

# . Requ ire current lug-down test Annual test 

# . Ann ual test 2 MY exemption Note: Changes to current progra m are 1n bold

. 

## Opacity Cutpoints The Work Group spent considerable time discussing the opacity cutpoints for the current program and whether lowering cutpoints was feasible or advisable at this time

. The Work Group could not come to consensus on this issues and therefore could not make any specific recommendations

. However, the members agreed cutpoints are an issue and presented the arguments on both sides

. 

### Arguments for - considering lower cutpoints The current opacity cutpoints for the various types and classes of diesel vehicles has remained unchanged since the program began in the late 1980's. Diesel engine technology has improved dramatically since that time, so current cutpoints for newer vehicles are no longer valid

. The current low failure rate in the program , particularly for new vehicles, indicates that current cutpoints are not appropriate

. A 20% opacity standard for newer turbo-charged LDDV would be justified since none ofthese vehicles fail the current 35% standard (which correlates to black smoke) and only 7% would fail a 20% standard

.

IV-20Arguments against - considering lower cutpoints - Chapter IV: Diesel Inspection and Maintenance Very few turbo-charged HDDV fail the current 20% standard and all are certified at levels well below that level. Only 3-5% for 1992 and newer HDDV would fail a 15% opacity limit. Lower cutpoints for naturally-aspirated vehicles are probably not justified because of the technology and the declining number of vehicles in the fleet. Between 30-40% ofthe current naturallyaspirated light- and heavy-duty fleet would fail a 20% standard. Data are not available to quantify the PM emissions reduction that would result from lower cutpoints

. Merely lowering cutpoints does not necessarily make the program more effective

. Because diesel emission data are skewed , lowering cutpoints may not result in a correlating reduction in emissions and there will be diminishing returns with lower cutpoints as a result. Since the Denver region is currently meeting all federal air quality standards and since diesel trends are expected to continue downward with the introduction of new vehicle standards, more stringent program requirements such as lower cutpoints cannot be justified at this time. There are more effective ways, such as on-road enforcement, to identify high-emitting vehicles rather than lowering cutpoints

. 

### Light-duty Diesel Vehicles Fail Rates Light-duty engine technology is separated into naturally aspirated (40% opacity cut point) , which is considered an older technology, and the newer turbo-charged (35% opacity cut point) technology which started in 1990
. The 1992 MY is somewhat arbitrarily established as the year when turbo-charged engine design was well understood and dominant. The results of approximately 19,500 light-duty opacity inspection tests in 2001 are presented in the following table: 2001 LDDV Failure Rate Failures



### ---- --- Technology & Total Valid Percentof Age Tests Fleet #Failed %ofFieet %ofFailed NA.< 92 2,600 13.4% 1ffi 0
.8°/( 68
.9% NA.> 92 338 1.?0/( 30 

### 02% 13.4% TC<92 2,000 10.3% 40 

### 02% 17
.7% TC>92 14,500 74.6% Ne:gigible 0
.0% 0
.0% Totals 19,438 100.0% 226 1.2% 100.0%

IV-21Chapter IV: Diesel Inspection and Maintenance NaturallyAspirated Naturally aspirated vehicles have an exhaust plume that is basically black Vehicles at the 40% opacity (passing) standard

. Naturally aspirated vehicles are 15% ofthe fleet and represent 82% ofthe failed vehicles

. Few naturally aspirated vehicles are being produced and fewer yet are being operated along the Front Range. Review offailures at lower cut points for all naturally aspirated vehicles suggests not much improvement in the technology in newer vehicles. Turbo-charged Turbo-charged vehicles have an exhaust plume that is basically black at Vehicles the 35% opacity (passing) standard

. Turbo-charged vehicles are 85% of the fleet and represent 18% ofthe failed vehicles, mostly from the pre1992 vehicles. 

### Heavy-duty Diesel Vehicles Fail Rates Heavy-duty engine technology is separated into naturally aspirated (35% opacity cut point) , which is considered an older technology, and the newer turbo-charged (20% opacity cut point) technology, which started in 1990
. The 1992 MY is somewhat arbitrarily established as the year when turbo-charged engine design was well understood and dominant. The results of approximately 26,000 light-duty opacity inspection tests in 2001 are presented in the following table: 2001 HDDV Failure Rates Failures Technology & Total Valid Percentof Age Tests Fleet #Failed %ofFleet %ofFailed NA.< 92 900 3
.5% 87 0.3% 27
.8% NA.> 92 225 0.9% 34 0.1% 10
.9% TC<92 7,300 28.4% 110 0.4% 35.1% TC>92 17,300 67.2% 82 0
.3% 26.2% Totals 25,725 100.0% 313 1.2% 100.0% NaturallyAspirated Naturally Aspirated Vehicles have an exhaust plume that is basically Vehicles black at the 35% opacity (passing) standard

. Naturally aspirated vehicles are 5% ofthe Fleet and represent 40% ofthe failed vehicles

. Few naturally aspirated vehicles are being produced and fewer yet are being operated along the Front Range

. Review offailure rates at lower cut points for all naturally aspirated vehicles suggests the technology in newer naturally aspirated vehicles has not improved with time

. The data indicate a significantly higher fail rates for older and newer vehicles in the DOIP compared to the DFSCP, suggesting a need for better maintenance/repair for the DOIP vehicles
IV-22Chapter IV: Diesel Inspection and Maintenance and/or improved testing methods and procedures in the DFSCP. 

### Turbo-charged Turbo-charged vehicles have an exhaust plume that is wispy black at the 

### Vehicles 20% opacity (passing) standard. Turbo-charged vehicles are 95% ofthe fleet and represent 60% ofthe failed vehicles. Based on review ofthe failures at lower cut points, newer vehicles fail at approximately onequarter (DFSCP) to one-third (DOIP) ofthe rate that older vehicles fail, suggesting improvement in turbo-charged technology

. As was the case with naturally-aspirated HDDV, the data indicate a higher fail rate for older and newer vehicles in the DOIP compared to the DFSCP

. 

### Impact ofAdjusting Smoke Opacity Limits The fail rates of diesel vehicles during CY 2001 at different opacity cut points has been analyzed by the APCD staff for the DOIP and DFSCP by vehicle technology and age. The results are presented in the following table. ImpactofAdjusting Smoke Opacity Limits

- 2001 Diesel Opacity Inspection Program FleetDOIP I-Tests 40% 35% 30% 20% 15% 10% Class DOIP LD/NA

<92 2,600 6% 11 % 19% 28% 38% 53% 71 %
.:=: 92 338 9% 14% 18% 23% 28% 43% 66% DOIP LD/TC

<92 2,000 2% 7% 13% 23% 36% 59%
.:=: 92 14,500 0% 2% 4% 7% 14% 30% DOIP HD/NA

<92 600 14% 21 % 27% 37% 50% 70%
.:=: 92 125 26% 31 % 35% 42% 56% 67% DOIP HD/TC

<92 3,700 2% 10% 29%
.:=: 92 8,200 1% 3% 8%

IV-23Chapter IV: Diesel Inspection and Maintenance

Self-Cert Class HD/NA < 92**~** 92 HD/TC < 92**~** 92 Impact of Adjusting Smoke Opacity Limits

- 2001 Diesel Self Certification Fleet -

1-Tests 40% 35% 30% 25% 20% 

### so

300 1% 3% 12% 16% 53% 100 1% 3% 6% 6% 26%
3,600 1% 21 % 9,100 0% 5%

NOTES and EXPLANATION : -This information was requested for comparison and analysis purposes. -These data are applicable to the Colorado full-load lugdown test cycle

. 10%

70% 41 %
42% 11 %

-Opacity limits are the horizontal axis, with vehicle classes on the vertical axis -I-Tests= the number of initial emissions tests deemed valid for the class (representative ofthe size ofthe affected fleet)

-LD = Light-duty Vehicle = < 7,500 #empty weight; HD = Heavy-duty Vehicle = > 7,500 # empty weight -NA = Naturally Aspirated (i

.e. non-turbocharged) ; TC =Turbocharged

-<92 = Model years 1991 and earl ier;**~92** = Model years 1992 and newer -Shaded boxes denote existing opacity limits e.g. HD fTC opacity limit is 20% -Statute currently prohibits opacity lim its less than 20%; any change to less than 20% requires legislation

.

IV-24

# Chapter V. Off-Road Diesel Vehicles Overview As noted in Chapter II , changes in off-road (Tier 1) emissions standards passed in 1994 were phased in between 1996 and 2000
. The standards adopted in 1998 (Tier 2) are being phased in between 2001 and 2005
. The manufacturer's improvements in technology to meet and exceed Tier 1 standards and the continued growth in equipment population and activity has served to slightly reduce PM-1 0 emissions growth and flatten NOx emissions growth through 1999
. Current EPA In 2001 EPA assessed the standards adopted in 1998 for non-road diesel standards engines, in particular to determine ifthe Tier 3 portion (and the Tier 2 emissions standards for engines under 50 hp) were, indeed feasible

. Based on information to date, EPA has affirmed the feasibility ofthese standards. This has been reinforced by the certification data from the Tier 1 engines in the power ranges of interest that demonstrate many of the engines are already meeting Tier 2 standards

. The 1998 rule did not establish a new Tier 3 program for PM emissions reductions because of critical unresolved issues connected with the appropriate test procedure for characterizing transient operating conditions

. Instead the EPA made a commitment in the rule to establish an effective program for controlling PM emissions beyond the limited control achieved under Tier 2 standards, and to consider adopting measures to better ensure in-use emissions control in-use

. The recent regulations that dramatically reduce on-road diesel emissions leaves the non-road diesel engines, already a significant source of PM and NOx, as a dominant source ofthese emissions in the future

. The emissions trend curves for PM and NOx for on-road and off-road engines for the Denver metro area presented in Chapter II ofthis report affirms this observation

.

V-1Chapter

### V :Off-Road Diesel Veh icles Future EPA The EPA is preparing proposed rulemaking in 2002 for further reduction Rulemaking of PM (and NOx ifwarranted) through a "systems" approach that regulates off-road diesel engines and fuel , similar to the recent on-road regulations. This approach continues the pattern of modeling off-road emissions reduction programs after on-road programs, with some additional lead time pro"vided for adaptation of on-road technologies to off-road applications

. Some analysis ofthe fuel required to complement the "system" envisioned above indicates a 15 -30 ppm sulfur content, which is definitely in the range ofthe ultra-low sulfur fuel required for the on-road fleet in 2006
. However, in 2007 a new HDDV will be 15 times cleaner than a off-road engine under the current Tier 3 off-road standards

. The lead time allowed for adaptation of on-road technologies will be important in determining the timing ofthe impact ofthe yet to be proposed new regulations

. The impact at this time could be estimated to be seen in 10- 15 years depending on the rulemaking process and equipment turnover
. Opportunities The turnover of diesel engines can take many years because ofthe exist to reduce durability and long life of diesel engines. However, there are still emissions opportunities to reduce emissions from the in-use engines through proper maintenance, reductions in engine idling , accelerated retirement, add-on equipment retrofits, which are facilitated by the availability of ultra low sulfur fuel, and use of cleaner diesel fuels

. 

## Recommendations The Work Group is cognizant ofthe changes in on-road and off-road standards, the future trends and the related impacts. There does not appear to be any local regulatory action that would be considered appropriate at this time for the off-road sector
. However, there does appear to be opportunities for voluntary activities to encourage the retrofit of equipment as broadly defined in the EPA's Voluntary Diesel Retrofit Program

. Some questions or observations ofthe work group are related to emissions inventory development issues, the amount of low sulfur (500 ppm) currently used in the metro area, incentives for retrofit programs and the need for some recognition for those entities that are doing their part to improve air quality

. To take advantage ofthese opportunities to reduce diesel emissions in innovative ways, the Diesel Stakeholder Work Group recommends the following :

V-2Chapter V: Off
-Road Diesel Vehicles Recommendation #1 Include off-road fleets and engines in the Fleet Outreach and Awareness Program to encourage voluntary initiatives by fleet and engine operators to reduce diesel emissions from the current in-use equipment. As noted above there are currently off-road fleet and engine operators that are planning or implementing voluntary programs that reduce emissions from existing diesel equipment. Public recognition ofthose programs can provide an incentive for others to consider similar programs. Implementation -The fleet special recognition program is outlined in Chapter Ill. All elements offer an opportunity for inclusion of off-road equipment in one way or another

. Recommendation #2 Improve the understanding ofthe current use of low sulfur fuel and the population of off road diesel equipment in the Denver metro area. There is an opinion by Work Group members that there is a significant percentage of low sulfur fuel used in the metro area although there is also a significant amount high sulfur fuel sold

. Also, there is a concern about the emissions inventory when equipment population and activity levels are compared with fuel sales

. Implementation -A survey offuel use/sales and equipment population/activity in the metro area is necessary to resolve the questions

. The Colorado Contractors Association (CCA) has indicated that it could assist in collecting this kind of data

. The APCD/RAQC will investigate additional sources of information and develop inventories

. Recommendation 

### #3 Based on the need, investigate incentives to encourage the use of low sulfur fuel (500 ppm) and other low emitting fuels and investigate the possibilities of early introduction of ultra-low sulfur fuels (15 ppm). Depending on the results ofthe survey discussed above investigate the incentives (economic, recognition , or regulatory) for encouraging the use of low sulfur (500 ppm) and other low emitting diesel fuels, such as biodiesel. Ultra-low sulfur (15 ppm) diesel fuels is necessary to fully realize the benefits of after market emissions control equipment. The availability and lead time for introduction of ultra-low sulfur fuel is an important consideration

. Implementation- The RAQC will lead a cooperative effort including the Colorado Contractors Association , Environmental Defense, local refiners , EPA Voluntary Retrofit Program staff and other interested parties to address these issues

. V-3ChapterV: Off-Road Diesel Vehicles Recommendation 

### #4 Encourage best management practices regarding engine maintenance, idling, and use, similar to the best maintenance practices program developed for on-road fleets. Equipment manufacturer's representatives are very aware ofthe importance of best management practices and often offer training for their clients

. Many operating entities currently follow a variety of enlightened management practices

. Implementation- Using the model program described for on-road vehicles in Chapter Ill , develop an off-road diesel engine best management practices program. The development of a clearinghouse for information and outreach to smaller operators is an additional avenue. Recommendation #5 Encourage low-emitting fuels, retrofits, and other low-emitting technology in large-scale construction projects. Large construction projects offer the opportunity to include in contract specifications the requirement or requirement with incentives of lower sulfur fuels, other low emitting fuels, retrofits, early retirement or replacement of existing equipment, or the use of equipment meeting the latest standards

. Implementation- An outreach program to state and local agencies and large corporate entities in the region concerning the possibilities of improvements to heath and air quality in the region through encouraging these activities

.

V-4

# Appendix AAppendix A 

## National and Local Voluntary Diesel Retrofit Pilot Programs 

## source: www.epa.gov. ota 

# ,. retro 1t. Retrofit Number of State City/State Entity Retrofits Technology Committed AL Birmingha nc am School District Catalyst 35 

# I CA 

# IState of California Agricultural Pumps 

# I Engine**Re-~ower** 430 CA State of California Bay Area, South Coast, Santa Early engine retirement 6901 Barbara, San Diego CA State or BP Fuel Transport Trucks Particulate Filter, Low 29 Sulfur Fuel CA State of California CARS School Bus Retrofit Program Particulate Filter, Low 1900 Sulfur Fuel CA State of California CALTRANS
- California Department 

# I ofTransportation Low Sulfur Fuel 14000 CA State of California Ralph's Grocery Company Particulate Filter, Low 20 Sulfur Fuel CA State of California

# I Urban Transit Agencies 

# IParticulate Filter, Low 4500 Sulfur Fuel CA Los Angeles 

# I City of Los Angeles 

# IParticulate Filter, Low 2300 Sulfur Fuel CA Los Angeles 

# I Hertz Equipment Fleet 

# IParticulate Filter, Low 20 Sulfur Fuel



### ,... Los Angeles Los Angeles City Sanitation Particulate Filter, Low 15 v, Sulfur Fuel '""'Angeles 

# I Los Angeles Count:t 

# II Low Sulfur Fuel 160 CA Los Angeles 

# I Metro Transit Authority 

# IParticulate Filter, Low 20 Sulfur Fuel CA Los Angeles School Districts - Los Angeles, Particulate Filter, Low 39 Anaheim Union, Hemet Unified Sulfur Fuel

....,,... '"'

...... 

# I San Diego School District 

# IParticulate Filter, Low 30 ...,.,, .....rego Sulfur Fuel CA San Diego Various private and transit fleets Particulate Filter, Low 6000 Sulfur Fuel CT State of 

# I CT Transit Agency 

# IParticulate Filter, Low 390 Connecticut Sulfur Fuel 

# [;]I Washington 

# I WMATA- Washington Metropolitan Particulate Filter, Low 1460 Area Transit Authority Sulfur Fuel 

# G Various oxides of Atlanta Hartsfield International Airport nitrogen (NOx) 10 technologies
rn Rnic:.P Arl::. r.n,1ntv Hiahwav Distrir:t

### lr.::~t::~lvst I nw Sttlfttr Fttf>ll :l9 

# I
A-1Appendix A IL Chicago 

# I Locomotive Switch Yard 

# I Auxiliary Power

### ur~il_ 

### J: 7 IN 

# II Hammond I Hammond City School District Catalyst 25 MA Boston Mass Turnpike Authority Catalyst 220 MA Boston 

# I Mass Baz: Area Transit 

# I Low Sulfur Fuel 475 MA Woburn Waste Management Catalyst 40
I**s~**

## ....... uf New NJ Jersey NJ Transit Authority Low Sulfur Fuel 2000 State of New Various oxides of NJ Jersey Department ofTransportation nitrogen (NOx) 30 technologies 

## II NV Las Vegas Construction equipment Catalyst 100 NY New York New York City Transit Authority Particulate filter, Low 4400 Sulfur Fuel NY New York New York City DOS Particulate Filter, Low 260 Sulfur Fuel 

# [;] New York New York City School Bus Fleet Particulate Filter, Low 1000 Sulfur Fuel 

# [;] Westchester Westchester County DOT Particulate Filter, Low 360 County Sulfur Fuel OH Cleveland Community Transit Particulate Filter, Low 10 Sulfur Fuel PA Philadelphia Area School District Particulate Filter, Low 120 Sulfur Fuel PA Philadelphia U

.S

. Naval Base 

# I Unknown 

# I 10 PA Philau"''l-'' ,;a Southeastern Pennsylvania Transit Particulate Filter, Low 1300 Authority Sulfur Fuel**..-~** Houst City of Houston Various NOx 29 technologies Fuel emulsion , selective TX Houston Port of Houston Authority f-atalytic reduction (SCR) , 59 Low Sulfur Fuel Various oxides of TX State ofTexas Various Transit Agencies & nitrogen (NOx) & 10000 Construction Companies particulate matter (PM) technologies WA Seattle Transit, School District &City Particulate Filter Catalyst 

# I 5000 

# I Vehicles Low Sulfur Fuel 

### TOTAL NUMBER OF RETROFITS COMMITTED: 70,229

A-2Appendix A 

## Summary of National and Local Voluntary Diesel Retrofit Pilot Programs

San Diego School Bus Project location: San Diego, Calif

. Retrofit Demonstration Program Project participants: San Diego Unified School District, ARCO Products, Engelhard , Johnson Matthey, Inc. , Navistar, California Air Resources Board , and South Coast Air Quality Management District Project date: Project funding : Retrofitted equipment: Retrofit devices:

Retrofit technology:

Emissions reductions:

Future: January 1999 -June 2000 Federal/State and Industry 30 Navistar Diesel School Buses ARCO's Emission Control Diesel (ECD) fuel California Air Resources Board (CARS) fuel Continuously Regenerating Technology (CRT) Diesel Particulate Filter (DPX) Johnson Matthey CRT System- an emission control system combining oxidation catalyst and filter Engelhard DPX System -a catalytic soot filter for controlling PM emissions (replaces muffler) ARCO ECD fuel- ultra low sulfur diesel fuel (contains only 15 parts per million of sulfur as opposed to 500 parts per million in diesel) CRT System- 90 percent particulate matter (PM) removed along with hydrocarbons (HC) and carbon monoxide (CO) DPX System- 90 percent PM , 80 percent HC, and 80 percent CO emissions reduction Since the program ended in June, the San Diego School District has implemented a plan to discard 375 buses older than 1977
. In addition the district has equipped 10 oftheir buses with the particulate traps and two others with the traps and engines to fully cut emissions. An additional 1 ,875 buses will have filters installed to reduce emissions

. Sources: US EPA web site- www.epa.gov/otaqlretrofitlexsandiego.htm, Diesel Technology Forum web site- www.dieselforum.org, and Education Week web sitewww.edweek.org.

A-3The "Big Dig" or The Boston Central Artery/Tunnel Voluntary Diesel Retrofit Program Project location: Project participants:

Project date: Project funding: Append ix A Boston , Mass

. Massachusetts Turnpike Authority (MTA) , Massachusetts Department of Environmental Protection (DEP) , and the Northeast States for Coordinated Air Use Management (NESCAUM) September 1998 - December 2004 Massachusetts Highway Department has and will continue to provide funding to contractors to purchase emission control devices

. Retrofitted equipment: 70 large, off-road diesel construction machines used for the construction ofthe "Big Dig" project such as front-end loaders, bulldozers, backhoes, cranes, air compressors, and excavators
. Retrofit devices:
Retrofit technology: Catalytic converters Particulate filters Oxidation Catalyst- used to reduce diesel emissions by oxidizing diesel pollutants, such as PM , HC, and CO, to less harmful emissions such as H20 and C02. Diesel Particulate Filters- used to control PM emissions Emissions reductions: Approximately 3 tons per year for PM, 12 tons per year for HC, and 36 tons per year for CO

. Project sponsors estimate that they will reduce 203 tons of pollutants over the six-year project period. Future:

Other: Due to the air quality benefits achieved thus far, the CA/T Project will continue to require that all off-road diesel equipment be equipped with oxidation catalysts until the end ofthe project. In addition to retrofit technology, the project has required all contractors to minimize diesel emissions impacts on people living and working near the construction zones by:**~** turning off diesel combustion engines on construction equipment not in active use and on dump trucks that are idling while waiting to load or unload material for five minutes or more;**~** establishing a staging zone for trucks that are waiting to load or unload material at the work zone in a location where diesel emissions from the trucks will not be noticeable to the public; and**~** locating construction equipment away from sensitive receptors such as fresh air intakes to buildings, air conditioners, and windows. Sources: US EPA web site- www.epa.gov/otaq/retrofitlexbigdig.htm, The Big Dig A-4Appendix A The NewYork City Project location: New York, N

.Y

. Transit (NYCT) Clean Diesel Vehicle Air Project participants: NYC Transit Authority, NYS DEC, Johnson Matthey

. Inc., Corning , Inc., Equilon Enterprises LLC, Environmental Canada, and Emissions Research and Measurement Division Quality Project
Project date: Project funding: Retrofitted equipment: Retrofit devices:
Retrofit technology:

Emissions reductions:
Future: February - November 2000 New York State Environmental Bond Act 50 New York City Transit urban diesel buses Continuously Regenerating Technology (CRT) combined with reduced sulfur diesel fuel Johnson Matthey CRT System- an emission control system combining oxidation catalyst and filter to reduce PM emissions to compressed natural gas (CNG) levels CRT System combined with reduced sulfur diesel fuel- up to 90 percent reduction in PM , HC, and CO The project sponsors concluded that the use ofvery low sulfur diesel was a key component to the outcome
. Due to the success in reductions ofthe three pollutants, the NYCT has continued the program. Sources: US EPA web site - www .epa.gov/otaqlretrofitlexnyproject.htm, Diesel Technology Forum web site- www.dieselforum.org, andDieseiNet web sitewww.dieselnet.com.

A-5Diesel Solutions Project location: Project participants:

Project date: Project funding:

Retrofitted equipment/ devices/technology: Appendix A Seattle, Wash

. The Puget Sound Clean Air Agency, U.S

. Environmental Protection Agency Region 10, King County, City of Seattle, Boeing , Everett Public Schools & Durham Transportation, Pacific Rim Enterprise Center & Emerald City Disposal , Washington State Department ofTransportation , Port of Seattle, Tosco Refining, Washington State Department of Ecology, The Diesel Technology Forum , Manufacturers of Emission Controls Association (MECA), Cummins, Detroit Diesel Corporation, Johnson Matthey, Inc

., and CleanAIR Systems

. Began in Summer/Fall 2001 EPA has leveraged about $1 million in funding to support this program . More grant funding is expected over the next several years. EPA's Diesel Retrofit project is providing substantial grant funding and technical support to help implement the program . Other funding partners include the Puget Sound Clean Air Agency, the Washington State Department of Ecology and Region 10 of EPA

The below equipment is equipped with particulate filter traps and oxidizing catalysts in conjunction with Tosco Refining ultra-low sulfur diesel fuel. King County- 1,100 diesel-powered buses will use ultra-low sulfur diesel between 2001 and 2003; 800 buses will be equipped with retrofit hardware over the next 2 %years; new vehicle and equipment purchases will come equipped with ultra-low sulfur diesel emission hardware City of Seattle -switch to ultra-low sulfur diesel throughout its diesel fleet; switch to ultra-low sulfur diesel in its fueling stations; retrofit heavyduty diesel fleet beginning in 2001 and finishing in 2003 Boeing -fuel 70 heavy-duty diesel fleet vehicles with ultra-low sulfur diesel; equip 70 heavy-duty diesel trucks with retrofit hardware; demonstrate viability of retrofit hardware and fuel to other private sector fleet operators Everett Public Schools and Durham Transportation- equip 25-30 International DTA 360, Cummins B series, and Caterpillar 3126 B school buses with retrofit technology; refuel buses with ultra-low sulfur diesel fuel

A-6Appendix A Emerald City Disposal and the Pacific Rim Enterprise Center- equip 25-30 refuse trucks with retrofit technology; refuel trucks with ultra-low sulfur diesel fuel The Washington State Department ofTransportation -develop pilot project to install retrofit technology on highway maintenance vehicles in Northwest region ; refuel vehicles with ultra-low sulfur diesel fuel Port of Seattle- develop program to install retrofit technology on diesel vehicles associated with its expansion project at Sea-Tac Airport; refuel diesel vehicles using ultra-low sulfur diesel fuel Emissions reductions: The program coordinators expect to see at least a 90 percent reduction in fine particle emissions, more than a 90 percent reduction in toxic emissions, and undetectable levels of HC emissions using the retrofit devices combined with the ultra-low sulfur diesel fuel. Future: The program will continue for the next few years with other private and public partners joining

. Sources: US EPA web site- www.epa.gov/otaqlretrofitlexeverettwa.htm, Puget Sound Clean AirAgency web site - www.pscleanair.org/dieselsolutionslindex.shtml, and Diesel Technology Forum web site - www.dieselforum.org/retrofitlpublicprivate.html.

A-7Ralph's Grocery Company**EC~Diesel** Truck Fleet Start-up Experience Project location: Project participants:

Project date: Project funding: Retrofitted equipment:

Retrofit devices:

Retrofit technology:

Emissions reductions: Appendix A Riverside, Calif. ARCO Products, U

.S

. Department of Energy, National Renewable Energy Laboratory, Detroit Diesel Corporation , Engelhard, Johnson Matthey, California Air Resources Board , South Coast Air Quality Management District, California Energy Commission , and the U

.S

. Environmental Protection Agency March 2000- February 2001 U.S

. Department of Energy 20

- 1999 Sterling Class 8 with Detroit Diesel Series 60 engines ARCO's Emission Control Diesel (ECD) fuel California Air Resources Board (CARB) fuel Continuously Regenerating Technology Diesel Particulate Filter (DPX) Five trucks operating on CARB fuel without a filter Five trucks operating on ECD fuel without a filter Five trucks operating on ECD fuel with Engelhard DPX Five trucks operating on ECD fuel with Johnson Matthey CRT Final results and evaluation for this project is expected before the end ofthe first quarter 2002
. However results from the first five months are as follows: The trucks equipped with the catalyzed particulate filters and ECD fuel emitted 91-99 percent less particulate matter compared to the CARS-fueled trucks with no filter equipment.
Sources: Reportissuedby DOE- www.afdc.doe.gov/pdfs!Ralphs_ECD.pdfand the Diesel Technology Forum web site - www.dieselforum.org.

A-8California Air Project location: Resources Board's (ARB) Lower-Emission Project participants: School Bus Program

Project date: Project funding:

Retrofitted equipment:
Retrofit technology:

Emissions reductions: Append ix A California California Energy Commission , South Coast Air Quality Management District, Bay Area Air Quality Management District, Monterey Bay Unified Air Pollution Control District, San Diego County Air Pollution Control District, Sacramento Metropolitan Air Quality Management District, and the San Joaquin Valley Unified Air Pollution Control District
2001 - 2002 school year $50 million in state funds to California EPA's Air Resources Board , who will distribute grants to school districts 2,000 diesel school buses for retrofit technology and 350 pre-1976 diesel school buses to be replaced Engelhard Diesel Particulate Filter (DPX) and Johnson Matthey CRT System- $12.5 million , new alternative fuel buses (primarily natural gas)- $25 million , new, cleaner diesel buses- $12

.5 million

. All buses equipped with filters are required to use ultralow sulfur fuel. The program began with the 2001 school year in August and will continue through summer of 2002
. Program administrators expect to see at least 85 percent reductions in PM. The ARB staff estimates that this program will reduce PM emissions by approximately 150 tons from the year 2001 - 2010
. This equals about 82 pounds per day

. Sources: California Air Resources Board web site- www.arb.ca.gov.

A-9NewYork State Project location: Thruway Truck Stop Electrification (TSE) Pilot Program Project participants:
Project date: Project funding:

Technology:

Emissions reductions: New York State ThruwayDeWitt and Chittenango Travel Plazas (near Syracuse) Appendix A

New York State Thruway Authority, New York State Energy Research and Development Authority (NYSERDA), and Niagara Mohawk 2001-2003 $500,000 shared by the NYS Thruway Authority , NYSERDA, and Niagara Mohawk Power Corporation

. 44 Truck Stop Electrification (TSE) units manufactured by ldleAir Technologies Corporation in Knoxville, Tenn. These stand-alone electrical power hookups provide drivers with local television, basic cable, telephone service, and basic internet service

. Drivers will have easy access to the above services by swiping a credit card into a module that easily fits into their window

. TSE units will help reduce both air and noise pollution

. The program will continue through 2003
. Emissions reductions have not yet been determined

. However, according to the Argonne National Laboratory, a single truck engine idles an average of six hours a day and 1,830 hours per year. It is estimated that a single truck emits an estimated 220 pounds of nitrogen oxide and 380 pounds ofCO each year. In addition to air quality benefits, installing the TSE units at the two demonstration sites alone could reduce diesel fuel usage by 470,000 gallons per year, according to a NYS Thruway press release

. Sources: New York State Thruway Authority web site -www.thruway.state.ny.us.

A-10International Truck and School bus distribution: Engine CorporationGreen Diesel Distribution dates: Technology School Buses Funding:

Technology:

Emissions reductions: Appendix A Several California school districts December 2001 - March 2002 School districts apply for state grants from the California Low Emission School Bus Program to replace old buses with new Green Diesel Technology buses

. The Green Diesel Technology buses use catalyzed diesel particulate filters and BP's low-sulfur diesel fuel in combination with an engine, built by International , designed to lower diesel emissions

. The Green Diesel Technology buses achieve a 90 percent reduction in PM and HC emissions

. In addition , the odor associated with diesel fuel is eliminated and the buses use 40- 60 percent less fuel per mile

. Sources: International web site- www.internationaldelivers.com, Green Diesel Technology web site- www.greendieseltechnology.com. Regional Project location: Transportation District's (RTD) Emissions inspections: Emissions Inspections and Electric Mall Shuttles

Retrofit:

Other: Seven-county metropolitan Denver area All buses tested annually to insure they meet State and RTD standards,which are twice as strict as State standards

. Supervisors make on-street visual evaluations which may result in immediate removal from service if State standards are exceeded

. Vehicles are scheduled for repair within five days of reported violations

. RTD opts to replace old engines with advanced , clean-burning , low emission , electronically-controlled engines from Detroit Diesel and Cummins

. The engines reduce PM emissions by 70 percent. RTD has replaced 830 buses over the past five years (about 2/3 of its fleet)

. The oldest bus in operation is a 1991 bus

. Hybrid/CNG Mall Shuttles- RTD pioneered transit use of electric vehicles in 1982 on the 161 h Street Mall. There are currently 34 running today

. RTD is researching the use of hybrid-electric buses to replace the existing shuttles in the future

. Hybridelectric buses contain a clean-burning , CNG-fueled engine, which drives an electric generator
. Sources: RTD web site- www.rtd-denver.org.

A-11FedEx Express - Low Project date: Emission Vehicle Purchases Project funding:
Affected equipment:

Technology: Emission reductions:

FedEx Express and the Project participants: Alliance for Environmental Innovation- The Future Vehicle Project Project date: Technology:

Emissions reductions:

Future:

A-12 Appendix A July 1999 to present FedEx Corp

. with assistance from Colorado sales tax waiver 106 diesel-fueled package delivery vehicles in the last 2-1/2 years. About 80 percent of Fed Ex's new vehicle purchases in the Denver-Boulder area have been certified Low Emission Vehicles (LEV). With a fleet of449 vehicles in the area, nearly 25 percent are now Low Emission ehicles

. Modified Cummins engines certified for LEV Up to 25 percent reduction in NOxemissions compared to current non-LEV vehicles

.
FedEx Express, Alliance for Environmental Innovation (an initiative of Environmental Defense) , Allison Transmission Division of General Motors, BAE SYSTEMS Controls, and Eaton Corporation . Prototype testing begins October 2002; new delivery trucks on road by 2004 Three competing teams, headed by the companies listed above, will develop prototype diesel-electric delivery vehicles for the next generation of FedEx Express delivery trucks

. The prototypes will be tested in October against a current baseline 1999 diesel delivery truck

. FedEx Express and Alliance for Environmental Innovation asked companies to submit proposals for a diesel-electric delivery truck that will increase fuel efficiency by 50 percent and reduce PM and NOx emissions by 90 percent. FedEx Express expects to have the new delivery trucks on the road by 2004