Appendix J 

Cost and Economic Analysis Methodology

i 

TABLE OF CONTENTS 

A. Methodology for Estimating Cost and Economic Impact ............................... 1

1. ARB fleet survey ............................................................................................. 1

2. Vehicle Capital Costs ...................................................................................... 3

3. Costs by Fleet Age and Fleet Size .................................................................. 5

4. Scaling to Statewide Costs.............................................................................. 9

5. Annual Costs................................................................................................. 15

6. Total Costs.................................................................................................... 20

7. Vehicle Maintenance and Repair Costs ........................................................ 22

B. Industry Groups................................................................................................ 23

1. The E-DRAM Model...................................................................................... 24

2. Diesel Vehicles by Business Type ................................................................ 29

C. For-Hire Transportation or Warehousing ....................................................... 32

1. Small Fleet Case Study................................................................................. 33

2. Fuel Transport Case Study. .......................................................................... 34

3. General Freight Transport Case Study. ........................................................ 34

4. Motor Coach Case Study. ............................................................................. 34

5. Refrigerated Transport Case Study............................................................... 35

D. Construction ..................................................................................................... 35

E. Agricultural Sector ........................................................................................... 36

1. Almond Farm Case Study. ............................................................................ 39

F. Retail/Wholesale............................................................................................... 40

1. Produce Company Case Study..................................................................... 41

2. Beverage Company Case Study................................................................... 41

G. Other Services .................................................................................................. 42

1. Street Sweeper Case Study.......................................................................... 43

2. Towing Case Study. ...................................................................................... 43

H. References ........................................................................................................ 52
ii 
iii 

LIST OF TABLES 

Table 1: ARB Survey Results Number of Vehicles by Body Type ........................... 2

Table 2: Fleet Size by Average Fleet Age ............................................................... 3

Table 3: Price Data for the Most Commonly Reported Vehicles in the Fleet Survey4

Table 4: Instate Heavy Heavy-Duty Vehicles by Fleet Age for Large Fleets 

(excluding special provisions).................................................................. 14

Table 5: Total Number of Aftermarket and Originally Equipped DPFS .................. 17

Table 6: Cumulative Increased Retrofit Maintenance Costs ($2008)..................... 17

Table 7: Fuel usage rates ...................................................................................... 18

Table 8: Initial Reporting Costs (2010) .................................................................. 19

Table 9: Total Annual Reporting Costs.................................................................. 20

Table 10: Total Reporting Costs .............................................................................. 20

Table 11: Total Statewide Compliance Costs (2008$)............................................. 21

Table 12: Increased Capital Costs as a Percentage of California Gross Domestic 

Product .................................................................................................... 24

Table 13: 2013 Sector Cost Allocations................................................................... 25

Table 14: Allocation of Transportation and Warehousing ........................................ 26

Table 15: Economic Impacts of the Proposed Regulation on the California Economy 

in 2013..................................................................................................... 26

Table 16: Sector Change in Real State Output Billions of 2008 dollars................... 27

Table 17: Sector Change in Employment Millions ................................................... 29

Table 18: Increased Costs by Business Sector ....................................................... 31

Table 19: Type of Vehicle Purchases per 2002 VIUS (National), Diesel Heavy-Duty 

Vehicles ................................................................................................... 31

Table 20: Medium Heavy-Duty Vehicle Price Data.................................................. 45

Table 21: Heavy Heavy-Duty Vehicle Price Data..................................................... 46

Table 22: Sample Individual Company Fleet Costs ................................................. 47
iv 

LIST OF FIGURES

Figure 1: HD Conventional Sleeper Tractor Price Comparison of Truckpaper.com 

and NADA.................................................................................................. 5

Figure 2: Average Increased Cost for Instate Heavy Heavy-Duty Vehicles in Fleets 

with 4 or More Vehicles (excluding special provisions).............................. 6

Figure 3: Average Increased Cost for Instate Medium Heavy-Duty Vehicles in Fleets 

with 4 or More Vehicles (excluding special provisions).............................. 7

Figure 4: Average Increased Cost for Instate Heavy Heavy-Duty Vehicles in Fleets 

with 1 to 3 Vehicles (excluding low use provisions) ................................... 7

Figure 5: Average Increased Cost for Instate Medium Heavy-Duty Vehicles in Fleets 

with 1 to 3 Vehicles (excluding low use provisions) ................................... 8

Figure 6: Average Increased Cost for Instate Heavy Heavy-Duty Vehicles in Fleets 

with Low Mileage (Less than 7500 Miles) .................................................. 8

Figure 7: Average Increased Cost for Instate Medium Heavy-Duty Vehicles in Fleets 

with Low Mileage (Less than 5000 Miles) .................................................. 9

Figure 8: Instate Heavy Heavy-Duty Vehicles by Fleet Age (2006 DMV data) ....... 10

Figure 9: Instate Medium Heavy-Duty Vehicles by Fleet Age (Per 2006 DMV data)11

Figure 10: California International Registration (CA-IRP) Vehicles by Fleet Age (Per 

2006 DMV data)....................................................................................... 12

Figure 11: Heavy Heavy-Duty Vehicle Annual Mileage............................................. 13

Figure 12: HHDDT Vehicle Miles Travelled (VMT) by Vehicle Age........................... 13

Figure 13: Odometer Mileage vs. Maintenance/Repair Cost Per Mile ...................... 23

Figure 14: Percentage of Vehicle Population by Business Sector from National 2002 

VIUS Data................................................................................................ 30

Figure 15: For-Hire Transport or Warehousing Vehicle Ages per 2002 VIUS 

(National), Diesel Heavy-Duty Vehicles ................................................... 32

Figure 16: For-Hire Transport or Warehousing Vehicle Age at Purchase per 2002 

VIUS (National), Diesel Heavy-Duty Vehicles (>15 Years is Unknown)... 33

Figure 17: Construction Vehicle Ages per 2002 VIUS (National), Diesel Heavy-Duty 

Vehicles ................................................................................................... 36

Figure 18: Construction Vehicle Age at Purchase per 2002 VIUS (National), Diesel 

Heavy-Duty Vehicles (>15 Years is Unknown) ........................................ 36

Figure 19: Percentage of Agricultural Employment in California by Selected Major 

Crop/Activity (2007 Annual Average Data) .............................................. 37

Figure 20: California Number of Farms by Size Group (2002 U.S. Census)............. 38

Figure 21: Agriculture, Forestry, Fishing, or Hunting Vehicle Ages per 2002 VIUS 

(National), Diesel Heavy-Duty Vehicles ................................................... 38

Figure 22: Agriculture, Forestry, Fishing, or Hunting Vehicle Age at Purchase per 

2002 VIUS (National), Diesel Heavy-Duty Vehicles (>15 Years is 

Unknown)................................................................................................. 39
v 

Figure 23: Agricultural Production is Shifting to Larger Farms.................................. 39

Figure 24: Retail/Wholesale Trade Vehicle Ages per 2002 VIUS (National), Diesel 

Heavy-Duty Vehicles................................................................................ 40

Figure 25: Retail/Wholesale Trade Vehicle Age at Purchase per 2002 VIUS 

(National), Diesel Heavy-Duty Vehicles (>15 Years is Unknown)............ 41

Figure 26: Other Services Vehicle Ages per 2002 VIUS (National), Diesel HeavyDuty Vehicles........................................................................................... 42

Figure 27: Other Services Vehicle Age at Purchase per 2002 VIUS (National), Diesel 

Heavy-Duty Vehicles (>15 Years is Unknown) ........................................ 43
J-1 

APPENDIX ON COST AND ECONOMIC ANALYSIS METHODOLOGY 

This appendix provides additional details to supplement the chapters on the cost 

methodology and economic impacts on individual sectors. Included are the detailed 

results of the analysis on the impacts on the California economy and individual business 

sectors. Finally, additional case studies are included for a number of companies. 

A. Methodology for Estimating Cost and Economic Impact 

The cost and economic impacts of this regulation are based on the anticipated 

compliance paths of the affected statewide fleets. To perform this analysis, staff 

estimated the cost that fleets are already incurring under their normal vehicle 

replacement practices. Staff then estimated the costs that fleets would incur to meet 

the requirements of the proposed regulation. The difference between these two 

numbers is the regulatory costs of staff’s proposal. These costs have been estimated 

for the years between 2010 and 2025. 

Staff developed the ARB On-Road Compliance Model (cost model) to estimate the 

capital expenditures of normal vehicle replacement during the analysis period compared 

to the capital expenditures required to comply with the proposed regulation over the 

same period. Using actual fleet data reported in the ARB fleet survey on over 13,000 

vehicles, the costs to the statewide fleets were calculated by predicting and evaluating 

the compliance paths for real individual fleets using the cost model. 

Staff used the cost model to analyze over 6,700 vehicles from 688 actual individual 

company fleets for each calendar year from 2009 to 2030, both with the regulation and 

without the regulation. The fleets evaluated varied by fleet age, vehicle type and weight 

class, and provided a representation of in-state and out-of-state fleets operating in 

California. The analysis determined the costs beyond those of estimated normal vehicle 

replacement; all costs calculated are additional costs fleets would incur by complying 

with the regulation. 

In addition to capital costs, various annual operational and maintenance costs are 

attributable to the regulation. Operational and maintenance costs associated with NOx 

and PM controls would include annual PM filter cleaning expenses, changes in fuel 

economy, urea costs for SCR systems, and costs associated with regeneration of active 

PM systems. Potential cost savings include fuel economy improvements with 

replacement of older vehicles with newer vehicles. In addition, companies would incur 

annual reporting costs when required to report to ARB. These annual costs were 

modeled separately and added to the capital cost estimates to arrive at an overall cost 

estimate. 

1. ARB fleet survey 

Staff conducted a detailed fleet information survey with participation by fleet 

organizations and individual stakeholders. The fleet survey collected information from 

fleets throughout the state regarding their company business operations such as the 
J-2 

fleet’s primary business use categories and number of vehicles in each fleet. The 

survey data also includes vehicle specific information for heavy-duty diesel vehicles 

including model year, weight ratings, and annual mileage data. Table 1 lists the reported 

vehicle counts by body type. 

Table 1: ARB Survey Results Number of Vehicles by Body Type 

Vehicle Body Type Count Vehicle Body Type Count 

Beverage HHDDT 166 Service/Utility/Mechanic MHDDT 143 

Beverage MHDDT 579 Stake HHDDT 17 

Bucket/Boom HHDDT 30 Stake MHDDT 16 

Bucket/Boom MHDDT 5 Sweeper MHDDT 197 

Bus - Coach HHDDT 590 Tank Truck: Asphalt HHDDT 1 

Bus - Coach MHDDT 408 Tank Truck: Chemical HHDDT 69

Bus - Shuttle MHDDT 98 Tank Truck: Chemical MHDDT 28 

Cab & Chassis HHDDT single 6 Tank Truck: Gasoline/Fuel HHDDT 68 

Cab & Chassis HHDDT tandem 60 Tank Truck: Gasoline/Fuel MHDDT 7 

Cab & Chassis MHDDT 16 Tank Truck: LPG HHDDT 10 

Car Carrier HHDDT 2 Tank Truck: LPG MHDDT 14 

Cotton Module HHDDT Tandem 23 Tank Truck: Vacuum HHDDT 6 

Crane HHDDT 17 Tank Truck: Water HHDDT single 2 

Crane MHDDT 1 Tank Truck: Water HHDDT tandem 138 

Drill Rig HHDDT 11 Tank Truck: Water MHDDT 48 

Dump HHDDT 260 Tow Truck: Roll-back HHDDT tandem 8 

Dump MHDDT 76 Tow Truck: Roll-back MHDDT 13 

Dump/Transfer HHDDT 92 Tow Truck: Wrecker HHDDT 17 

Expeditor/Hot Shot HHDDT 2 Tow Truck: Wrecker MHDDT 21 

Farm/Grain HHDDT 9 Tractor: Cab-Over HHDDT single 11 

Farm/Grain MHDDT 9 Tractor: Cab-Over HHDDT tandem 126 

Flatbed HHDDT 220 Tractor: Cab-Over MHDDT 5 

Flatbed MHDDT 243 Tractor: Conventional HHDDT single 737 

Flatbed-Dump HHDDT 21 Tractor: Conventional HHDDT tandem 3031 

Flatbed-Dump MHDDT 15 Tractor: Conventional MHDDT 337 

Fuel/Lube HHDDT single 4 Tractor: Sleeper HHDDT 311

Fuel/Lube HHDDT tandem 52 Van: Dry HHDDT single 11 

Fuel/Lube MHDDT 13 Van: Dry HHDDT tandem 394 

Garbage Trucks: Packer HHDDT 17 Van: Dry MHDDT 199 

Garbage Trucks: Roll-Off HHDDT 8 Van: Moving HHDDT 2 

Hooklift HHDDT 2 Van: Moving MHDDT 4 

Logging HHDDT 128 Van: Reefer HHDDT 9 

Mixer/Asphalt/Concrete HHDDT 108 Van: Reefer MHDDT 18 

Other 3741 Winch HHDDT 1 

Service/Utility/Mechanic HHDDT 79 Yard Spotter HHDDT 92 
J-3 

Table 2 summarizes the survey responses by fleet average age and fleet size category. 

A total of 900 trucks are owned by fleets with 3 or fewer vehicles. Most were single 

truck owners. An additional 12,000 vehicles are owned by companies with more than 3 

vehicles. Although not easily evident from the table, the proportion of older trucks in 

small fleets is higher than in the larger fleets consistent with staff analysis of DMV data. 

Table 2: Fleet Size by Average Fleet Age 

Fleet Age Fleet Size (# of Vehicles) 

Group 1 to 3 Vehicles >3 Vehicles Total 

<=3 30 71 101 

>3 & <=6 49 4,093 4,142 

>6 & <=10 152 3,687 3,839 

>10 & <=13 118 1,904 2,022 

>13 & <=16 148 1,496 1,644 

>16 & <=20 132 519 651 

>20 271 552 823 

Totals 900 12,322 13,222 

Staff also met with several individual companies and obtained information about their 

normal business practices, and had meetings with various stakeholder groups (such as 

the agricultural groups, dump truck association and California Trucking Association). 

The meetings and survey responses confirmed trends in vehicle replacement cycles 

that are common for various groups. Normal vehicle replacement practices are 

dependent on a number of factors, but in general are best correlated to annual miles 

traveled and how a vehicle is used. 

2. Vehicle Capital Costs 

To determine truck price inputs into the cost model, for sale vehicle price data was 

downloaded from Truckpaper.com and other online sources. Price curves were 

developed for over 50 truck body types by weight. Table 3 provides price data for the 

top ten types of vehicles that were reported on in the fleet survey. 
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Table 3: Price Data for the Most Commonly Reported Vehicles in the Fleet 

Survey 

Vehicle Type Value 

(new) 

Value 

(10 Years)

Value 

(20 Years) 

Beverage MHDDT $ 55,205 $ 10,315 $6,129 

Bus - Coach MHDDT $ 99,081 $ 15,866 $5,813 

Bus - Coach HHDDT $ 449,954 $ 111,832 $ 18,633 

Dump HHDDT $ 96,685 $ 25,852 $ 10,651 

Dry Van HHDDT (Tandem) $ 98,469 $ 19,519 $8,907 

Flatbed MHDDT $ 48,792 $ 14,482 $8,408 

Tractor Convention MHDDT $ 61,565 $ 14,169 $7,595 

Tractor Convention HHDDT (Single) $ 92,201 $ 17,119 $ 10,644 

Tractor Convention HHDDT (Tandem) $ 105,151 $ 23,216 $ 16,275 

Tractor Sleeper HHDDT $ 131,961 $ 22,166 $ 12,128 

Staff had obtained data from the National Automobile Dealers Association (NADA) 

(http://www.nada.com/b2b/products/commerical_truck_guide.asp) vehicle pricing 

information, but data was only available for a limited number of vehicle types. Staff 

compared the NADA data for a conventional tractor and found that it matched favorably 

with for sale prices downloaded. Here, the Truckpaper.com prices are from February 

29, 2008 and the NADA retail prices are from March 25, 2008. NADA price data was 

available for model year 1999 to 2008 and was limited to heavy-duty tractors, and 

medium-duty tractors or cab and chassis. 

The price of four truck manufacturer of conventional sleeper tractors for each model 

year was averaged to determine the NADA price. The price was based on the following 

manufacturers, models, engine type, and transmission type: 

• Freightliner, Century Class S/T 120” series and CST12064ST Aero body with 13-18 

speed manual transmission and 15L-16L engine with ≥ 500 horsepower 

• International, 9200-9900 series and 9200i Aero body with 13-18 speed manual 

transmission and 15L-16L engine with ≥ 550 horsepower 

• Mack, CHN/CXN series and CHU Aero body with 13-18 speed manual transmission 

• Peterbilt 378/379/385/387 series and 379 body (389 for 2008) with 13-18 speed 

manual transmission and 15L-16L engine ≥ 550 horsepower 

The price for a used 2007 Freightliner conventional sleeper tractor was not available 

from NADA. The price for new 2008 Freightliner conventional sleeper tractor was 

available from NADA at $151,287. This price did not seem realistic since it was even 

higher than a Peterbilt 389 at $138,144. 

The comparison between Truckpaper.com and NADA prices were compared from 

model years 1999 through 2006 since the data was either incomplete or not realistic for 

model years 2007 and 2008. The price difference between the two sources is not 

significantly difference and is shown in Figure 1. 
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Figure 1: HD Conventional Sleeper Tractor Price Comparison of 

Truckpaper.com and NADA 

$0

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

$140,000

0 1 2 3 4 5 6 7 8 9

Years Used

Truck Price

Truck Paper Data

Best Fit Curve

NADA Data

Source: Truckpaper.com. February 9, 2008. http://www.truckpaper.com/ 

NADA. March 25, 2008. http://www.nada.com/

Staff also assessed whether a truck body type could be transferred to a new cab and 

chassis and what the costs of the body transfer would be. If a body transfer is feasible 

and costs less than a replacement vehicle, the estimated transfer costs for the cab and 

chassis is another cost in addition to the cab and chassis price. The vehicle price data 

and body transfer costs used in the cost model are shown in Table 20 through Table 22. 

3. Costs by Fleet Age and Fleet Size 

The cost model must be run for many groups using data specific to the types of 

vehicles, fleet sizes and ages, and with the modeling code aligned with the various 

provisions for vehicle subpopulations. Subpopulations by instate and out-of-state groups 

(see next section for more information) need to be further segregated into groups 

related to specific rule provisions. For example, individual model runs need to be made 

by state inventory populations for large fleets with no special provisions, for small fleets 

with no special provisions, for vehicles with low mileage use provisions or other special 

provisions (such as exemptions related to mileage, specialty vehicles, etc.). 
J-6 

The cost associated with the “regulation run” is compared with the “baseline run” cost to 

determine any increased cost due to the proposed regulation. The increased cost is 

then divided by the number of vehicles in the company fleet to determine the average 

increased cost per vehicle. For the statewide analysis, individual company fleet 

increased costs per vehicle are grouped by fleet age and fleet size. The average 

increased costs by fleet age and fleet size groups reflect that individual companies with 

newer fleets will have no increased costs while companies with older fleets will have 

increased costs due to the regulation. As shown in Figure 2 through Figure 7, the 

average increased cost per vehicle associated with the regulation varies by the average 

age of the fleet and depends upon the value of each vehicle. 

Figure 2: Average Increased Cost for Instate Heavy Heavy-Duty Vehicles in 

Fleets with 4 or More Vehicles (excluding special provisions) 

$0

$10

$20

$30

$40

$50

$60

$70

$80

0 5 10 15 20 25

Average Fleet Age

(Years)

Average Increased Cost (Thousands $/Vehicle)
J-7 

Figure 3: Average Increased Cost for Instate Medium Heavy-Duty Vehicles in 

Fleets with 4 or More Vehicles (excluding special provisions) 

$0

$10

$20

$30

$40

$50

$60

$70

$80

0 5 10 15 20 25

Average Fleet Age

(Years)

Average Increased Cost (Thousands $/Vehicle)

Figure 4: Average Increased Cost for Instate Heavy Heavy-Duty Vehicles in 

Fleets with 1 to 3 Vehicles (excluding low use provisions) 

$0

$10

$20

$30

$40

$50

$60

$70

$80

0 5 10 15 20 25

Average Fleet Age (Years)

Average Increased Cost (Thousands $/Vehicle)
J-8 

Figure 5: Average Increased Cost for Instate Medium Heavy-Duty Vehicles in 

Fleets with 1 to 3 Vehicles (excluding low use provisions) 

$-

$10

$20

$30

$40

$50

$60

$70

$80

- 5 10 15 20 25

Average Fleet Age (Years)

Average Increased Cost (Thousands $/Vehicle)

Figure 6: Average Increased Cost for Instate Heavy Heavy-Duty Vehicles in 

Fleets with Low Mileage (Less than 7500 Miles) 

$0

$5

$10

$15

$20

$25

$30

0 5 10 15 20 25

Average Fleet Age

(Years)

Average Increased Cost (Thousands $/Vehicle)
J-9 

Figure 7: Average Increased Cost for Instate Medium Heavy-Duty Vehicles in 

Fleets with Low Mileage (Less than 5000 Miles) 

$-

$10

$20

$30

$40

$50

$60

$70

$80

0 5 10 15 20 25

Average Fleet Age (Years)

Average Increased Cost (Thousands $/Vehicle)

4. Scaling to Statewide Costs 

The cost model output provides the average increased cost per vehicle by fleet age and 

fleet size for individual company fleets (see Table 22 for sample individual company 

fleet annual costs). For determining the statewide costs, staff matched vehicle types to 

the emission inventory from real fleets who responded to the ARB survey. Staff used 

DMV and IRP data to determine the distribution of medium duty vehicles, heavy duty 

vehicles, fleet size, and fleet age distributions. The vehicle population counts were 

derived from statewide emissions inventory database and include the following 

population categories: 

• Intrastate 

o Heavy Heavy-Duty Vehicles (HHD) – Tractors 

o Heavy Heavy-Duty Vehicles – Non Tractors 

o Medium Heavy Duty (MHD) Vehicles 

o Ag vehicles 

• Interstate 

o California International Registration Plan (CA-IRP) Vehicles 

o Out-of-state neighboring vehicles (AZ, BC, ID, NV, OR, WA) 

o Out of state non-neighboring vehicles 
J-10 

In addition to the statewide vehicle population groups, there are some additional subgroup vehicle counts needed because the regulatory requirements differ, such as for: 

• Low Mileage (<7500 for HHD & <5000 for MHD) Vehicles 

• Small Fleets (1-3 Vehicles) 

• Exempted Vehicles 

The characteristics of the fleet and vehicle information were used to match each vehicle 

to the emissions inventory categories. For example, a company may have some 

vehicles that are registered in the CA-IRP, and also some that are medium and heavy 

heavy-duty vehicles that are registered instate. Based on DMV instate and CA-IRP 

data, weighting percentages were developed by fleet age and size group to apply to the 

statewide emissions inventory populations to get the vehicle counts by fleet age and 

size groups. The statewide cost can be calculated for each fleet age group by 

multiplying the increased average cost per vehicle by the population vehicle counts. 

a) Instate Heavy Heavy-Duty Vehicles 

To put fleet age distributions in perspective, the following figure provides statewide data 

showing the percentage of vehicles, by fleet age, for instate heavy heavy-duty vehicles 

registered in California, per 2006 Department of Motor Vehicle (DMV) data. As can be 

seen in Figure 8, 47 percent of California heavy heavy-duty vehicles reside in individual 

company fleets with an average vehicle age of 6 to 13 years. Only 7 percent of the 

vehicles are in fleets with an average age over 20 years and 9 percent of the vehicles 

are in fleets with an average age of less or equal to 3 years. 

Figure 8: Instate Heavy Heavy-Duty Vehicles by Fleet Age (2006 DMV data) 

>13 & 

<=16 

years

13%

>20 years

7%

>6 & 

<=10 

years

27%

>3 & <=6 

years

14%

<=3 

years

9%

>16 & 

<=20 

years

10%

>10 & 

<=13 

years

20%

b) Instate Medium Heavy-Duty Vehicles 

Similar to the heavy heavy-duty, the following figure provides statewide data showing 

the percentage of vehicles, by fleet age, for instate medium heavy-duty vehicles 

registered in California, per 2006 DMV data. As can be seen in Figure 9, 48 percent of 
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these vehicles reside in individual company fleets with an average vehicle age of over 3 

to 10 years. Only 5 percent of the vehicles are in fleets with an average age over 20 

years while 20 percent of the vehicles are in fleets with an average age of less or equal 

to 3 years. 

Figure 9: Instate Medium Heavy-Duty Vehicles by Fleet Age 

(Per 2006 DMV data) 

>16 & 

<=20 

years

>13 & 7%

<=16 

years

9%

>20 years

5%

<=3 years

20%

>3 & <=6 

years

>6 & <=10 20%

years

27%

>10 & 

<=13 

years

12%

c) Interstate Vehicles 

Interstate vehicle populations include instate registered vehicles, neighboring out-ofstate vehicles (AZ, BC, ID, NV, OR, WA) and non-neighboring out-of-state vehicles. 

Neighboring out-of-state vehicles are expected to have the same vehicle age 

distributions as vehicles in the California International Registration Program (CA-IRP). 

Vehicle age distributions for the CA-IRP vehicles (per 2006 CA-IRP registration data) 

are shown in Figure 10 below. Most or 52 percent of the CA-IRP vehicles reside in 

fleets with an average fleet age of less than or equal to 6 years, and only 12 percent are 

in fleets with an average age greater than 10 years. 
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Figure 10: California International Registration (CA-IRP) Vehicles by Fleet Age 

(Per 2006 DMV data) 

>16 & 

<=20

1% >13 & 

<=16

2%

>20

1%

<=3

17%

>3 & <=6

35%

>6 & <=10

36%

>10 & 

<=13

8%

Interstate vehicles that are based in the mid-west and eastern states are the most likely 

to be newer than any other category. Non-neighboring interstate vehicles have an 

average age of 3.4 years per the emissions inventory database (in comparison to the 6 

year age average of the CA-IRP vehicles), indicating that non-neighboring fleets are 

comprised mostly of very new vehicles that will already exceed the regulation 

requirements. Fleets that have vehicles older than 6 years old would also have the 

ability to route only their cleaner vehicles to California to comply with the regulations 

without any significant increase in costs. 

d) Annual Mileage 

Per the statewide emission inventory database, heavy heavy-duty vehicles travel 

approximately 13.4 billion cumulative miles per year in California and medium heavyduty vehicles travel approximately 4.3 billion cumulative miles in California. Figure 11 

displays the percent of annual mileage travelled by vehicle population categories for 

heavy heavy-duty vehicles. Vehicles that operate only within California comprise 43 

percent of the heavy heavy-duty annual miles and 99 percent of the medium heavy-duty 

annual miles. Interstate and international vehicles comprise 57 percent of the heavy 

heavy-duty annual miles and 1 percent of the medium heavy-duty annual miles. 
J-13 

Figure 11: Heavy Heavy-Duty Vehicle Annual Mileage 

Instate Single

7.93%

Instate Tractor

24.22%

Other Instate

11.05%

CA-IRP

19.26%

Neighboring Out-of-State

9.18%

Non-Neighboring Out-ofState

28.36%

As displayed in Figure 12, the CAIRP vehicles travel the highest percentage of the 

total annual miles travelled by CAIRP vehicles at the age of 3 years and then the 

miles travelled decrease over time as the vehicles are sold into other types of instate 

and out-of-state fleets, or are retired. After the age of 13 years, the annual miles 

travelled by the instate tractor and single (non-tractor) vehicles decreases 

significantly as the population declines and individual vehicle annual miles travel 

decreases. The annual miles travelled for vehicles over the age of 25 years are only 

0.1 percent of the CAIRP miles, 1.2 percent of the non-tractor miles and 1.8 percent 

of the tractor miles. 

Figure 12: HHDDT Vehicle Miles Travelled (VMT) by Vehicle Age 

0.00%

2.00%

4.00%

6.00%

8.00%

10.00%

12.00%

-1 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

Vehicle Age

% of Miles Travelled 

T7 CAIRP

T7 Single

T7 Tractor
J-14 

e) Sample Results 

Table 4 shows sample results for the heavy heavy-duty vehicles subject to the large 

fleet requirements that would not qualify for any of the special provisions. The DMV data 

provides the weighting percentages (similar to the prior pie chart figure with all fleet 

sizes) to apply to the total vehicles from the statewide emissions inventory to get the 

number of vehicles by fleet age groups. 

Table 4: Instate Heavy Heavy-Duty Vehicles by Fleet Age for Large Fleets 

(excluding special provisions) 

Fleet Age 

# Vehicles (Per 

Updated Emissions 

Inventory for 2008)

% (per 2006 DMV 

Data)

$/Vehicle (Per 

Model Output) Statewide $ 

<=3 5,772 12.3% $ - $ -

>3 & <=6 7,933 17.0% $ 7,688 $ 60,989,901 

>6 & <=10 13,567 29.0% $ 13,981 $189,692,574 

>10 & <=13 8,765 18.8% $ 20,274 $177,705,029 

>13 & <=16 6,126 13.1% $ 25,668 $157,242,209 

>16 & <=20 3,003 6.4% $ 31,961 $ 95,972,700 

>20 1,372 2.9% $ 40,052 $ 54,939,191 

Unknown 209 0.4% $ 15,756 $ 3,286,004 

 46,750 100.0% $739,827,609 

 Overall Average $/Vehicle $ 15,827 

The statewide cost estimate for this sub-population can then be estimated by multiplying 

the number of vehicles by the increased $/vehicle for each age group and summing the 

statewide $ per fleet age. In the above example, the highest increased costs due to the 

regulation are found in the >20 fleet age category with an average $/vehicle of $40,052 

and the least cost increases due to the regulation are found in the three or fewer fleet 

age category with no average increased costs. Medium duty vehicles and vehicles 

qualifying for the special provisions including low use vehicles would have separate 

population counts and lower costs. 

Similar analysis is done for all the remaining population categories including: 

• Low mileage vehicles (by MHD and HHD groups) 

• Higher use instate HHD vehicles for small fleets 

• Higher use instate MHD vehicles (by small & non-small fleets) 

• Higher use CA-IRP and neighboring out-of-state vehicles (by small & nonsmall fleets) 

• Bus Fleets (by MHD and HHD) 

• Non-Neighboring out-of-state vehicles 

• Low mileage and specialty agricultural vehicles (special provisions) 

Other populations that have differing requirements and are modeled separately include: 
J-15 

• School Buses (PM only) 

• Ag Fleets 

• Cranes 

• Sweepers 

5. Annual Costs 

In addition to capital costs of the proposed regulation, various annual operational and 

maintenance costs will also be incurred. In determining the total regulatory costs of 

staff’s proposal, these annual costs are added to the total statewide capital cost 

estimates. Operational and maintenance costs associated with PM DECS include 

annual filter cleaning expenses, fuel economy losses and costs associated with 

regeneration of active systems. Other costs or savings include fuel economy 

improvements with replacement of older vehicles with newer vehicles and urea costs for 

SCR. At this time, staff has not included anticipated cost savings associated with lower 

maintenance and less down time by fleets having newer vehicles as compared to 

having older vehicles. 

The operating and maintenance costs associated with the use of PM DECS are 

determined using the anticipated population of vehicles equipped with aftermarket PM 

controls, as well as the population of 2007 and newer engines. The number of PM 

controls in each calendar year was estimated by extrapolating the results of the capital 

cost model to the affected vehicle population. 

Operating and maintenance costs attributable to the proposed regulation were broken 

into four main categories: regeneration cost for active DPFs, changes in fuel economy, 

urea usage, and annual maintenance. Regeneration costs for active filters are incurred 

for electricity or fuel usage for a vehicle to regenerate the filters on a regular basis. 

Annual maintenance costs for vehicles with PM control devices are for the cleaning 

servicing of the filters by external parties. Engines manufactured after 2009 with SCR 

would also have annual costs associated with the use of urea. Also, there is likely to be 

a fuel economy improvement and associated cost savings through the use of 2004-

2006 MY engines utilizing EGR. 

a) Annual Retrofit Costs 

When calculating the statewide costs, additional costs due to retrofits were also 

incorporated. These costs included: 

• Regeneration costs due to active retrofits 

• Maintenance costs due to yearly filter cleanings required 

• Fuel costs associated with the 2 percent fuel penalty per retrofit 

i. Regeneration Costs

Staff expects the majority of diesel emission control systems will use active fuel-based 

systems to regenerate in order to avoid the need to plug in because most vehicles, such 
J-16 

as dump trucks, may not have on the job access to electricity or the extended time for a 

full electricity-based regeneration cycling. Electricity-based regenerating may remain 

commonplace in day-use only applications where the vehicle returns to the same facility 

each night, such as school bus fleets. Diesel emission control systems contain sensors 

that permit operators to anticipate the majority of regenerations. Subsequently, 

regenerations can take place during non business hours with no impact on productivity. 

Given the close comparison of cost between the two technologies, staff used fuel-based 

filters exclusively in its analysis. To estimate the number of in-use active diesel emission 

control systems the retrofit population was scaled by the weighted in-state percentage 

of pre-1994 medium heavy-duty and heavy heavy-duty vehicles, which is 15 percent of 

the population. Based on 2 regenerations per week at a quarter hour of down time per 

regeneration and 0.2 gallon of fuel burned per regeneration the total cost to the 

statewide fleet is $181.7 million at a rate of $3.69 per gallon of diesel. At $4.00 per 

gallon the cost would increase to $182.3 million and at $5.00 per gallon the price would 

be $184.2 million. The cost estimates are insensitive to fuel prices because the down 

time costs represent a vast majority of the total cost estimate. 

ii. Maintenance Costs

In 2010 through 2013, the proposed regulations would require the installation of diesel 

particulate matter filters (DPFs) on existing vehicles. After 2013 all vehicles would have 

PM filters and the total number decreases as vehicles are retired. By 2021, nearly all 

pre-2007 vehicles would be phased out and no aftermarket PM retrofits would remain in 

use. The estimated number of retrofits in the statewide fleet is shown in Table 5. 
J-17 

Table 5: Total Number of Aftermarket and Originally Equipped DPFS 

Calendar Year Number of Aftermarket 

DPFs 

Increased Number of 

Engines with OEM 

equipped DPF 

2010 11,700 7,675

2011 35,152 16,345

2012 136,233 69,090

2013 154,240 81,306

2014 139,120 70,222

2015 113,955 72,013

2016 79,053 87,528

2017 50,929 96,517

2018 48,725 83,895

2019 45,823 82,317

2020 0 93,663

2021 0 87,647

2022 0 80,011

2023 0 67,356

2024 0 57,259

2025 0 53,791

Staff has conservatively estimated that each retrofit will result in maintenance costs of 

about $400 per year for PM filters (ARB 2003; ARB 2006a; ARB 2007). Using this 

estimate, the total statewide costs due to retrofit maintenance was calculated using 

Equation 1 in 2008 equivalent dollars. 

Equation 1: Total Maintenance Costs = Σ [maintenance cost/year per vehicle x # 

of vehicles in the state retrofitted] 

The total increased in maintenance costs for the statewide fleet from 2010 to 2025 is 

estimated at 516 million (in 2008 equivalent dollars), as shown in Table 6. 

Table 6: Cumulative Increased Retrofit Maintenance Costs ($2008) 

Per Filter Costs 

Cumulative Costs 

(millions $) 

OEM equipped DPFs $ 275 

Aftermarket DPFs $ 241 

TOTAL $ 516 

iii. Fuel Costs

The statewide fleet uses over 3 billion gallons of diesel fuel per year for California miles 

traveled at an average cost of approximately $4.00 per gallon (CEC 2008). Fleets 

reported vehicle fuel usage and miles traveled in the fleet survey. Statewide inventory 
J-18 

data (including vehicle miles traveled) was used to compute fuel penalty costs 

associated with particulate matter filters and fuel efficiency offsets from vehicle 

replacements using the fuel usage rates in Table 7.

Table 7: Fuel usage rates 

Model 

Year 

MPG for 

HHD 

MPG for 

MHD 

<1988 5.200 6.916 

1988-1990 5.388 7.165 

1991-1993 5.575 7.415 

1994-1995 5.763 7.664 

1996-1998 5.950 7.914 

1999-2002 5.480 7.288 

2003-2006 5.750 7.648 

2007 5.610 7.461 

2008 5.590 7.435 

2009 5.580 7.421 

2010 5.780 7.687 

2011 5.780 7.687 

>2011 5.800 7.714 

The total statewide costs from 2010 to 2025 due to increased fuel consumption from the 

2 percent fuel penalty in vehicles with aftermarket retrofits installed is a total of 

approximately $113 million in 2008 equivalent dollars. The total statewide offset from 

2010 to 2025 due to decreased fuel consumption from the increased fuel efficiencies 

from vehicle replacements is a total of approximately $126 million in 2008 equivalent 

dollars. Thus there is a net reduction in costs anticipated of approximately $13 million at 

a rate of $4.00 per gallon. At a rate of $3.69 per gallon, the net reduction in costs drop 

to $12.2 million and at a rate of $5.00 per gallon the net reduction in costs increase to 

$16.5 million. 

The proposed regulation will also accelerate the replacement of existing vehicles to 

newer vehicles that utilize SCR technology. The result is an increased number of 

vehicles in the statewide fleet that have SCR relative to what would occur without the 

proposed regulation. SCR technology utilizes urea to reduce NOx emissions, so an 

additional cost will be realized. It is expected that after 2023, the increased number of 

vehicles having SCR because of the accelerated vehicle replacement requirement will 

slowly decrease as the statewide fleet returns to normal vehicle replacement cycles. 

Projecting in 2008 equivalent dollars, and considering urea costs of $4.00 per gallon 

and that urea consumption in SCR is expected to be about 3 percent of the diesel fuel 

used, the estimated cost is approximately $240 million. 
J-19 

iv. Cost for Reporting

For small fleets, initial reporting will cost between $0 and $ 100 (for up to 2 hours 

needed to compile fleet data). This assumes a cost of $50/hr for either work time lost, or 

a hired consultant. For large fleets, the cost will be between $200 and $400 (assuming 

an average of 4 to 8 hours to compile larger fleet data). 

For estimating the total statewide costs, the number of fleets present in the state was 

estimated using 2006 DMV and CA-IRP data with the number of registered vehicles 

grouped by fleet size bins. The number of fleets was calculated by using Equation 2. 

Equation 2: Fleets in State = Σ [Registered Vehicles / Fleet Size] 

Per 2006 DMV data for instate heavy heavy-duty, medium heavy-duty and CAIRP 

vehicle populations, there are approximately 171,500 company fleets. There are 

approximately 156,000 small fleets with less than 4 vehicles and there are 

approximately 15,500 large fleets in California. Excluding single owner fleet trucks that 

would only have a vehicle with a model year of 2007 or greater in 2010, the revised 

estimate for small fleets would be 138,000. Out of state vehicles will be minimally 

impacted as the majority of out-of-state fleets are comprised of newer vehicles and are 

ahead of the proposed requirements. 

Fleets using the BACT compliance schedule would not need to report in the years they 

use this method of compliance. For the reporting costs calculations, it is estimated that 

approximately 75 percent of the fleets would be reporting in any given year as reflected 

in Equation 3. 

Equation 3: Fleet initial reporting costs = # of fleets x 75% x average initial 

reporting costs 

In 2008 dollars, the statewide cost for company fleets initial reporting in 2010 is shown 

in Table 8. 

 

Table 8: Initial Reporting Costs (2010) 

Fleet Type Cost ($2008) 

Millions 

Small fleet $11.4 

Large fleet $ 5.1 

Total cost for initial reporting $16.5 

The annual reporting costs for small fleets will be approximately $50 per fleet per year, 

assuming that on average one hour is needed to update the fleet in the ARB reporting 

system. For a large fleet, the cost is estimated to be $200 per fleet per year, assuming 

that on average, 4 hours is needed to update the fleet in the ARB reporting system. The 

4 hours for large fleets is based on a weighted average using estimating 1.5 hours for 
J-20 

fleets with 4 to 5 vehicles, 2 hours for fleets with 6 to 10 vehicles, 4 hours for fleets with 

11 to 20 vehicles and 20 hours for fleets with over 20 vehicles. The total cost per year 

for small fleet reporting will be 75 percent of the number of fleets multiplied by $50, or 

$5,175,000. For a large fleet, the cost per year will be 75 percent of the number of fleets 

multiplied by $200, or $2,325,000. 

The reporting costs over the life of the regulation were calculated using Equation 4, 

assuming that for all fleets reporting ends in 2022. 

Equation 4: Total annual reporting cost = Σ [Annual reporting cost x NPV (for 

every year of reporting)] 

The total annual reporting cost over the life of the regulation is shown in Table 9. 

Table 9: Total Annual Reporting Costs 

Fleet Type Cost ($2008) 

Millions 

Small fleet $41.6 

Large fleet $18.7 

Total cost for annual reporting $60.3 

The total costs for reporting are the initial and annual reporting costs in 2008 dollars 

(Table 10). 

Table 10: Total Reporting Costs 

Fleet Type Cost ($2008) 

Millions 

Small fleet $53.0 

Large fleet $23.8 

Total cost for reporting $76.8 

6. Total Costs 

Statewide, there are a number of different types of fleet vehicles that will experience 

different costs: 

• Large fleets – all PM and NOx requirements: 

o Medium heavy duty vehicles Instate, 

o Heavy heavy-duty vehicles instate, 

o CAIRP Vehicles, 

o Motor Coach Bus Fleets, 

o Neighboring out of state vehicles, 

o Far out of state vehicles. 

• Small fleets - alternative schedule for requirements per vehicle for fleets with less 

than 4 vehicles. 

• Low Mileage fleet vehicles – PM only requirements until 2020. 
J-21 

• Port Trucks – must replace 2007MY vehicles by end of 2020. 

• School Buses - PM only requirements completing in 2013. 

• Low mileage and specialty agricultural vehicles (special provisions). 

• Utility Fleets 

• Two Engine Cranes 

• Sweepers 

The statewide fleet inventory for 2008 includes approximately 220,000 medium heavyheavy duty vehicles, more than 695,000 heavy heavy-duty vehicles and approximately 

25,000 buses that conduct business in California. This includes vehicles that also 

operate in other states including California. Over 940,000 of the statewide fleet 

inventory vehicles are in fleets that could be subject to provisions in the proposed 

regulations. 

The results of multiplying the number of vehicles for each fleet type by the costs per 

vehicle are shown in Table 11. This table also incorporates reporting costs for company 

fleets to comply with the rule including the initial reporting costs and the total annual 

reporting costs. Retrofit costs for annual maintenance and a 2 percent fuel penalty are 

also included. The reporting and retrofit costs are discussed above in this document. 

Table 11: Total Statewide Compliance Costs (2008$) 

Fleet/Population Type Total Cost 

(Millions) 

# Vehicles 

Instate MHD Fleets - Small $399 77,739 

Instate MHD Fleets - >3 Vehicles $565 88,522 

Instate MHD - Low Mileage $122 32,264 

MHD CAIRP & Out-of-State $46 8,896

Instate HHD Fleets - Small $432 37,097 

Instate HHD Fleets - >3 Vehicles $740 46,754 

HHD - Low Mileage* $142 25,841 

HHD Buses $252 7,211 

MHD Buses $26 2,763 

CA-IRP - Small $156 25,126 

CA-IRP - >3 Vehicles $343 32,273 

Neighboring States - Small $48 7,773 

Neighboring States - >3 Vehicles $339 31,928 

Non-Neighboring $471 225,328 

Non-Neighboring - <1000 Miles $0 225,329 

Agricultural MHD Fleets - Mid Miles $30 1,946 

Agricultural MHD Fleets - High Miles $30 1,750 

Agricultural MHD Fleets - Exempt $0 5,742 

Agricultural HHD Fleets - Mid Miles $30 1,442 

Agricultural HHD Fleets - High Miles $108 4,099 

Agricultural HHD Fleets - Exempt $0 6,459 
J-22 

Port Trucks $106 21,650 

School Buses $69 16,469 

Two Engine Cranes $0 2,113 

Utility Fleets $4 4,154 

Reporting Costs $77 n/a 

Operating Costs $928 n/a 

Grand Total $5,461 940,667 

*Includes CA-IRP, Neighboring States, Instate HHD 

For most fleets, the costs are highest in 2012-2013 and lowest in 2014. In general, 

businesses with newer fleets and lower proportions of equipment subject to other ARB 

rules will have little to no cost impacts to absorb. Businesses with significantly older 

fleets and higher proportions of equipment subject to other ARB rules will have higher 

cost impacts to absorb or pass on. 

7. Vehicle Maintenance and Repair Costs 

In staff’s analysis, the cost estimates are conservative because cost savings for truck 

replacements to newer more reliable trucks with lower operating costs were not 

included. In meeting with individual fleets, and evaluating the impact on cash flow, 

income and total debt load, staff did consider these factors. Cost savings per for newer 

vehicles is dependent on a number of factors including vehicle weight class and use of 

the vehicles. The importance of the cost savings is greater for vehicles that travel more 

miles and less important for those that operate relatively few miles. The following 

discussion shows how significant repair and maintenance costs can be. 

Figure 13 shows maintenance and repair cost of 6 conventional without sleeper tandem 

drive axle class 8 tractors. All tractors were new and 4 were place into service in year 

2000 and 2 in year 2003. The tractors are typically driven by two drivers per day 

normally 5 to 5.5 days per week at a maximum of 1,000 miles per day and averaged 

about 170,000 miles per year. The duty cycle is rated as high in which these trucks 

operate regionally and average 4.95 miles per gallon. A long haul tractor that runs 

between Seattle and San Diego on the Interstate 5 corridor normally average closer 

miles per gallon. The maintenance cost portion included brakes, tires and other 

preventative maintenance repairs. The repair cost portion was the labor cost to perform 

non-routine or preventative maintenance repairs at a shop rate of $100 per hour. 

For example, a new truck driven 100,000 miles (beginning odometer reading = 0) in the 

first year would expect $0.038 per mile maintenance and repair cost of $3,800 for year 

one. If in the fourth year the same truck continues traveling another 100,000 miles 

(ending odometer reading = 400,000 miles) and $0.076 maintenance cost or $15,248 

for year four. 
J-23 

Figure 13: Odometer Mileage vs. Maintenance/Repair Cost Per Mile 

$0.00

$0.05

$0.10

$0.15

$0.20

$0.25

$0.30

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000

Odometer Reading

Maintenance Cost Per Mile ($2007)

B. Industry Groups 

The impact of the proposed regulation on each business sector will depend on the 

number and types of vehicles that are impacted and the fleet ages for each business 

sector. A comparison of the California Gross Domestic Product (GDP) dollars for these 

same time periods provides an indication of the rate increases that would be needed for 

each industry group as a whole. The GDP projections are based on normal historical 

growth patterns. 

As seen in Table 12 below using VIUS 2002 business categories (VIUS 2002), the 

transportation industry would incur the highest costs in relation to their GDP with an 

average increase of 0.07 percent needed in GDP over 2010-2025 to absorb the costs. 

The increased rule costs would be highest for the Transportation industry in 2012. The 

construction industry would need an average increase of 0.03 percent in GDP over 

2010-2025 to absorb costs. Since the construction industry has experienced a 

downturn, primarily in the residential sector, for sensitivity purposes this analysis was 

also examined using no growth projections for GDP, resulting in the need for an 

average increase of 0.06 percent in GDP over 2010-2025 to absorb costs of the 

construction industry. Most industries would experience the highest cost year in 2013. 
J-24 

Table 12: Increased Capital Costs as a Percentage of California Gross 

Domestic Product 

Business Type per 2002 VIUS for Diesel 

Heavy-Duty Vehicles 

Total from 

2010-2025

Maximum 

Year 

Accommodation or Food Services 0.0061% 0.022%

Agriculture, Forestry, Fishing, or Hunting 0.0257% 0.082%

Arts, Entertainment or Recreation Services 0.0027% 0.007%

Construction 0.0503% 0.116%

For-Hire Transportation or Warehousing 0.0958% 0.325%

Manufacturing 0.0013% 0.005%

Mining 0.0450% 0.148%

Other Services 0.0111% 0.021%

Retail & Wholesale Trade 0.0046% 0.013%

Utilities 0.0005% 0.000%

TOTALS 0.0144% 0.044%

1. The E-DRAM Model 

ARB Staff assessed the overall impact that the proposed regulation could potentially 

have on the California economy using the Environmental-Dynamic Revenue Analysis 

Model (E-DRAM). The E-DRAM is a model of the California economy, developed by the 

University of California, Berkeley. The ARB has used the E-DRAM to assess the 

economic impacts of several major regulations and plans. 

The E-DRAM describes the flow of dollars among California producers, California 

households, California governments, and the rest of the world. Data for the 120 

industrial sectors originate from the U.S. Department of Commerce’s Bureau of 

Economic Analysis and are based on the Census of Business—a detailed survey of 

U.S. companies conducted every five years. The survey contains information about 

intermediate purchases, factor (labor, capital, land, and entrepreneurship) payments, 

and taxes. National data are disaggregated to a California level using a combination of 

state-level employment data and estimates from the Department of Finance’s 

econometric modeling. The model is updated as industrial data becomes available and 

the current version of the model is based on the industrial data obtained in 2003. 

Household income data come from the California Franchise Tax Board Personalincome Tax “sanitized” sample. Data on consumption by income class are derived from 

national survey data. Government sector data are culled from published federal, state, 

and local government reports. 

a) Annualized Costs of Compliance 

The annualized cost of the proposed regulatory measure is the basic input to the EDRAM. The Policy Scenario is implemented in the model by increasing the total amount 

spent by the affected sectors in the Vehicle Manufacturing sector by a total of $556 
J-25 

Million. The vehicle manufacturing sector in the E-DRAM model includes the Heavy 

Duty Truck Manufacturing sector (NAICS 33612). The impacts were estimated for the 

year 2013, which represents the year with the greatest increase in spending. Costs to 

the specific sectors are indicated in Table 13. 

. 

Table 13: 2013 Sector Cost Allocations 

Sector NAICS 

2013 

Annualized Cost 

Accommodation and Food Services 72 $15,120,984 

Agriculture, Forestry, Fishing 11 $41,440,107 

Arts, Entertainment or Recreation Services 71 $1,945,808 

Construction 23 $117,081,446 

Transportation and Warehousing 48-49 $182,115,623 

Manufacturing 31-33 $18,899,204 

Mining 21 $17,723,411 

Motor Coach Bus Lines* 485, 5324 $43,223,763 

Other Services Many $9,432,622 

Wholesale and Retail Trade 42,44-45 $55,717,069 

Schools* 4854 $26,044,209 

Utilities 22 - 

Vehicle Leasing or Rental* 5321 $37,073,903 

Total $565,818,151 

* These sectors are treated as part of Transportation and Warehousing in the analysis described below. 

The E-DRAM consists of 120 industrial sectors which means that the costs detailed in 

Table 13 need to be further apportioned among these 120 sectors. This cost 

apportionment was done proportionally, based on each sectors share of spending in the 

Vehicle Manufacturing sector established in the models’ 2003 dataset. The Vehicle 

Manufacturing sector is broad enough that it likely includes vehicle types that would not 

be affected by this regulation. The effect of the proportional apportionment would mean 

that some sectors that would not be affected by this regulation are being affected to 

some extent. 

As indicated in Table 13, the costs to the Transportation and Warehousing sector are a 

substantial share of the total costs of this regulation. The Transportation and 

Warehousing sector is made up of nine individual sectors in E-DRAM, some of which 

may not be affected by this regulation. To get some idea of the effects of misallocating 

costs, two different cost allocation scenarios were analyzed. 

The first assumes that costs are proportional to spending in the Vehicle Manufacturing 

sector, as described above. The second tried to be more explicit about which sector 

would bear the brunt of the costs. These two scenarios are displayed below. 
J-26 

Table 14: Allocation of Transportation and Warehousing 

Transportation and Warehousing NAICS Scenario 1 Scenario 2 

Air Transportation 481, 488 0% 0% 

Other Transportation 486, 488, 5324 13% 0% 

Public Transportation (Motor Coach 

Bus Lines and Schools) 485 2% 15% 

Railroad Transportation 482, 488 2% 0% 

Transportation 49 15% 0% 

Truck Transportation 484 42% 60% 

Vehicle Transportation (Includes 

Vehicle Leasing or Rental) 485, 487, 488, 5321 23% 25% 

Waterway Transportation 483, 488 4% 0% 

b) State Level Economic Impacts 

The proposed plan will require increased spending for vehicle replacements. Increased 

spending by the affected sectors will directly increases the cost of producing goods and 

services and therefore the prices of goods and services in these sectors. Price changes 

will in turn have secondary effects on other sectors of the California economy. Using EDRAM model, it is possible to estimate the net effects of the proposed regulatory plan 

on the aggregate California economy. 

Table 15 summarizes the impacts of the proposed regulation on the California economy 

for the year 2013. Changes are all relative to the Business as Usual case. For Scenario 

1, the results of analysis indicate the state output would be reduced by about $1.3 billion 

(0.04 percent), and personal income would increase by roughly $500 million (0.02 

percent) in 2013. California employment would be reduced by 13,600 (less than 0.08 

percent) in 2013. Therefore, the impacts of the proposed regulation are small compared 

to the growth that is expected to occur in California over the next few years. 

For Scenario 2, the results of analysis indicate the state output would be reduced by 

about $1.3 billion (0.04 percent), and personal income would decrease by roughly $600 

million (0.02 percent) in 2013. California employment would be reduced by 4,600 (less 

than 0.03 percent) in 2013. Therefore, the impacts of the proposed regulation are small 

compared to the growth that is expected to occur in California over the next few years. 

Table 15: Economic Impacts of the Proposed Regulation on the California 

Economy in 2013 

Business as 

Usual Scenario 1 Scenario 2 

Real State Output (billions of 2008 dollars) 3,104 3,103 3,102 

Personal Income (billions of 2008 dollars) 1,800 1,800 1,799 

Income Per Capita (thousands of 2008 dollars) 44.13 44.15 44.13 

Employment (thousands of jobs) 17.63 17.62 17.63 

Total Imports (billions of 2008 dollars) 2,417 2,418 2,417 
J-27 

Total Exports (billions of 2008 dollars) 2,359 2,358 2,358 

Percent Change from Business as Usual 

Real State Output (billions of 2008 dollars) - -0.04% -0.04% 

Personal Income (billions of 2008 dollars) - 0.02% -0.02% 

Income Per Capita (thousands of 2008 dollars) - 0.05% -0.01% 

Employment (thousands of jobs) - -0.08% -0.03% 

Total Imports (billions of 2008 dollars) - 0.04% 0.01% 

Total Exports (billions of 2008 dollars) - -0.02% -0.02% 

A source of uncertainty in the E-DRAM analysis is the industry data that the model is 

dependent upon. The model uses data for 2003 and the data are extrapolated to future 

years based on growth forecasts from the California Department of finance and the 

UCLA Anderson School of Business. These growth rates apply to all E-DRAM sectors. 

If the affected sectors grow faster than the rate used in E-DRAM, this analysis would 

overstate the relative impact of the regulation. Conversely, if sector growth is slower 

than anticipated, this analysis would understate the relative impact of the regulation. 

c) Sector Economic Impacts 

A model such as E-DRAM is most useful for characterizing economic impacts at the 

state level. It can also be informative at the sector level with the understanding that 

some sector details that may be important in characterizing how producers will respond 

to a policy change may not be fully reflected in the model. 

Table 16 and Table 17 reports sector level changes. Again, the overall effects are small 

and largely consistent across both costs allocation scenarios. There is one noticeable 

effect for employment within the Trucking and Warehousing sector. With a general 

apportionment (Scenario 1) Railroad Transportation sees substantial change in 

employment. This effect is not seen in Scenario 2, where the total Trucking and 

Warehousing costs are shared among the Truck Transportation, Public Transportation 

and Vehicle Transportation sectors. In fact, the total employment change for Trucking 

and Warehousing is substantially reduced in Scenario 2. 

Table 16: Sector Change in Real State Output Billions of 2008 dollars 

Sector 

Business as 

Usual Scenario 1 Scenario 2 

Agriculture, Forestry, Fishing 94 94 94 

Mining 28 28 28 

Construction 141 140 140 

Utilities 62 62 62 

Manufacturing 819 818 818 

Transportation and Warehousing 94 93 93 
J-28 

Wholesale and Retail Trade 402 402 402 

Arts, Entertainment or Recreation Services 49 49 49

Accommodation and Food Services 93 93 93 

Other Services 1,323 1,323 1,323 

Grand Total 3,104 3,103 3,102 

 

Agriculture, Forestry, Fishing - -0.10% -0.10% 

Mining - -0.10% -0.11% 

Construction - -0.15% -0.15% 

Utilities - -0.07% 0.02% 

Manufacturing - -0.05% -0.05% 

Transportation and Warehousing - -0.38% -0.22% 

Wholesale and Retail Trade - -0.01% -0.03% 

Arts, Entertainment or Recreation Services - 0.04% 0.01% 

Accommodation and Food Services - -0.02% -0.02% 

Other Services - -0.01% -0.02% 

Grand Total - -0.04% -0.04% 
J-29 

Table 17: Sector Change in Employment Millions 

Sector 

Business as 

Usual Scenario 1 Scenario 2 

Agriculture, Forestry, Fishing 0.43 0.43 0.43 

Mining 0.03 0.03 0.03 

Construction 0.89 0.89 0.89 

Utilities 0.06 0.06 0.06 

Manufacturing 1.96 1.96 1.96 

Transportation and Warehousing 0.48 0.47 0.48 

Wholesale and Retail Trade 2.58 2.58 2.58 

Arts, Entertainment or Recreation Services 0.26 0.26 0.26 

Accommodation and Food Services 1.33 1.33 1.33 

Other Services 6.27 6.27 6.27 

Grand Total 14.29 14.28 14.29 

 

 

Agriculture, Forestry, Fishing - -0.09% -0.10% 

Mining - 0.01% 0.00% 

Construction - -0.14% -0.15% 

Utilities - -0.06% 0.02% 

Manufacturing - -0.06% -0.05% 

Transportation and Warehousing - -2.51% -0.18% 

Wholesale and Retail Trade - -0.01% -0.03% 

Arts, Entertainment or Recreation Services - 0.09% 0.03% 

Accommodation and Food Services - -0.01% -0.02% 

Other Services - 0.00% -0.01% 

Grand Total - -0.11% -0.04% 

2. Diesel Vehicles by Business Type 

The impact of the proposed regulation on each business sector will depend on the 

number and types of vehicles that are impacted and the fleet ages for each business 

sector. Figure 14 summarizes the National 2002 VIUS data by the percent of the 

vehicle population to business type for heavy heavy-duty and medium heavy-duty diesel 

trucks. 
J-30 

Figure 14: Percentage of Vehicle Population by Business Sector from National 

2002 VIUS Data 

 Heavy Duty Vehicles Medium-Duty Vehicles

Vehicle 

Leasing or 

Rental

5%

Manufacturing 

& Mining

8%

Agriculture, 

Forestry, 

Fishing, or 

Hunting

16%

Other 

Services

12%

Construction

22%

Retail & 

Wholesale 

Trade

10%

For-Hire 

Transportation 

or 

Warehousing

27%

Vehicle 

Leasing or 

Rental

9%

For-Hire 

Transportation 

or 

Warehousing

19%

Retail & 

Wholesale 

Trade

19%

Construction

18%

Other Services

19%

Agriculture, 

Forestry, 

Fishing, or 

Hunting

10%

Manufacturing 

& Mining

6%

The total in-state heavy heavy-duty and medium heavy-duty inventory vehicle 

population’s were multiplied by the appropriate National 2002 VIUS vehicle percentages 

for each industry sector type to get the total number of vehicles allocated to each 

industry by weight class. The in-state annual operating and reporting costs were 

apportioned to each industry sector based on the annual miles travelled for each 

industry sector, as per the 2002 VIUS national data. The increased costs by sector are 

summarized below in Table 18. 
J-31 

Table 18: Increased Costs by Business Sector 

Business Sector 

Increased 

Capital Costs 

(in millions of 

$2008) 

Annual Costs 

(in millions of 

$2008) 

Total Increased 

Costs (in 

millions of 

$2008) 

Accommodation or Food Services $ 83.5 $ 14.7 $ 98 

Agriculture, Forestry, Fishing, or Hunting $ 197.7 $ 68.0 $ 266 

Arts, Entertainment or Recreation 

Services $ 14.0 $ 0.9 $ 15 

Construction $ 960.1 $ 100.4 $1,061 

For-Hire Transportation or Warehousing $1,359.0 $ 486.2 $1,845 

Manufacturing $ 124.9 $ 43.3 $ 168 

Mining $ 117.1 $ 20.1 $ 137 

Other Services $ 84.6 $ 48.5 $ 133 

Retail & Wholesale Trade $ 401.3 $ 105.5 $ 507 

Utilities $ 3.9 $ 10.2 $ 14 

Vehicle Leasing or Rental $ 207.9 $ 71.1 $ 279 

TOTALS $3,554.0 $ 968.9 $4,523 

This industry sector cost analysis computes the increased capital costs for vehicles 

registered in-state and does not include costs to out-of-state fleets. However, staff 

expects the majority of costs to out-of-state fleets to be borne by the transportation and 

warehousing sector. 

Table 19: Type of Vehicle Purchases per 2002 VIUS (National), Diesel HeavyDuty Vehicles 

HHDDT Purchases MHDDT Purchases 

Business Group 

New 

Vehicles 

Used 

Vehicles 

New 

Vehicles 

Used 

Vehicles 

Accommodation or Food Services 65.3% 34.7% 83.2% 16.8%

Agriculture, Forestry, Fishing, or Hunting 16.6% 83.4% 21.1% 78.9%

Arts, Entertainment or Recreation Services 26.1% 73.9% 24.0% 76.0%

Construction 32.8% 67.2% 38.0% 62.0%

For-Hire Transportation or Warehousing 56.2% 43.8% 67.1% 32.9%

Information Services 56.3% 43.8% 90.1% 9.9%

Manufacturing 61.2% 38.8% 56.9% 43.1%

Mining 37.1% 62.9% 42.8% 57.2%

Other Services 52.5% 47.5% 54.2% 45.8%

Retail Trade 61.1% 38.9% 63.0% 37.0%

Utilities 49.5% 50.5% 70.0% 30.0%

Vehicle Leasing or Rental 86.9% 13.1% 87.8% 12.2%

Waste Mgmt, Landscaping or Admin/Support 

Services 56.7% 43.3% 47.4% 52.6%

Wholesale Trade 65.7% 34.3% 70.6% 29.4%
J-32 

C. For-Hire Transportation or Warehousing 

ARB fleet survey data submitted by 179 companies with a total of 1,712 vehicles 

included 6.0% low mileage vehicles that would have delayed replacement requirements 

and almost no very low mileage vehicles that would be exempt from the cleanup 

requirements. These fleets had a median fleet age of 11.0 years. 

As displayed in Figure 15 and Figure 16, the vast majority of vehicles in this industry 

sector are purchased new; approximately 62% of the vehicles are less than 7 years old 

and only 38% of these vehicles remain after the age of 10 years. The average U.S. 

tractor travels 65,000 miles each year and typically accrues more than 500,000 miles 

before being replaced. 

Figure 15: For-Hire Transport or Warehousing Vehicle Ages per 2002 VIUS 

(National), Diesel Heavy-Duty Vehicles 

0 to 3 Years

41%

3 to 6 Years

21%

7 to 10 Years

20%

11 to 13 Years

8%

14 to 15 Years

4%

>15 Years

6%
J-33 

Figure 16: For-Hire Transport or Warehousing Vehicle Age at Purchase per 2002 

VIUS (National), Diesel Heavy-Duty Vehicles (>15 Years is Unknown) 

<3 Years

86.8%

3 to 6 Years

7.8%

7 to 10 

Years

3.9%

11 to 15 

Years

1.6%

1. Small Fleet Case Study 

A California company has 3 flatbed tractor and trailer combinations for hauling various 

goods. The oldest vehicle is a 1995 model year which travels about 15,000 miles per 

year. A 2001 and a 2000 model year vehicle both travel about 95,000 miles per year, 

and over half of these miles are in California. The company has 1 employee, annual 

revenue of between $250,000 to $500,000 and assets valued at about $2 million. On 

average, this company would replace a vehicle every 6 years with a new to 3 year old 

vehicle. Staff modeled that replacement would be with a 1 year old vehicle. 

The proposed regulation would require replacing two of the vehicles earlier than normal. 

The 1995 model year vehicle would get replaced as normal with a 2010 model year 

vehicle in the year 2011. The 2000 model year vehicle would get replaced 4 years 

earlier than normal in 2013 instead of 2017. And the 2001 model year vehicle would be 

replaced 8 years earlier than normal in 2015 instead of 2023. 

For this company, staff estimates the increased costs to comply with the proposed 

regulation would be about $28,000 above what would normally be spent for vehicle 

replacements from 2010 to 2025 ($2008). This compares to about $157,000 that would 

normally be spent for capital upgrades over this time period. Annual revenues for this 

company estimated at $375,000 are cumulatively projected to be $4.6 million in 2008 

equivalent dollars over the same time period. To offset the increased capital costs of 

these regulations, this fleet would need to increase revenue by about 0.6 percent. To 

substantially lower the upfront capital investment, the fleet could have purchased a used 

3 to 5 year old vehicle in 2015 instead of a new vehicle. This would lower the capital 

investment considerably. In this example the fleet owner would have fully met the 2023 

goals of the regulation 8 years early and would have no additional requirements. 
J-34 

2. Fuel Transport Case Study 

A fuel company owns 12 vehicles with an average fleet age of 4.6 years and annual 

revenue of approximately $15,000,000. There are 2 heavy heavy-duty Tank Trucks, 6 

heavy heavy-duty Tractors, and 4 medium heavy-duty Tank Trucks with 73,000 average 

miles per truck. The company reported a total of 26 trucks and the remaining 14 

vehicles are outside of the scope of the proposed regulation. 

Because this fleet typically replaces its vehicles within 10 years, it would likely 

accelerate their vehicle replacements by a few years to avoid filter retrofits. For this 

fleet, they would replace most vehicles as normal, but would replace the vehicles that 

would normally be replaced in 2014 to 2016 2 to 3 years early. There would then be no 

replacements required until 2021; however, starting in 2017, the oldest vehicle in the 

fleet would be 10 years old and the company would return to a normal replacement 

cycle of replacing 10 year old vehicles. The fleet would be able to continue business as 

usual because it would have all 2010 engines in its fleet before the regulation would 

require it. Staff estimates the increased costs to comply with the proposed regulation 

would be about $26,400 in 2008 equivalent dollars over the calendar years of 2010-

2025. To offset the increased capital costs, this fleet would need to increase revenue by 

about 0.014 percent. 

3. General Freight Transport Case Study 

A general freight trucking company owns 60 vehicles with an average fleet age of 13.4 

years. All the vehicles are heavy heavy-duty Tractors with an average of 85,000 miles 

per vehicle. Three of the vehicles have low mileage of less than 7500 and thus have 

delayed replacement requirements. 

For this company, staff estimates the increased costs to comply with the proposed 

regulation would be about $1.52 million in 2008 equivalent dollars over the calendar 

years of 2010-2025.The annual revenues of this company were not provided; however, 

gross revenues of $1.50 per mile is not unusual for a general freight company. To offset 

the increased capital costs of these regulations, this fleet would need to increase 

revenue by about $0.014 per mile or about 0.1 percent, during 2010 to 2025. 

4. Motor Coach Case Study 

A California bus company comprised of 138 diesel buses with an average fleet age of 

6.4 years. This company operates a range of bus types including small shuttle buses 

and motor coaches with an average of 31,000 miles per bus. The shuttle buses are 

primarily operated locally and the motor coaches are used for both local trips and longer 

trips. On average, this company would spend about $1.7 million annually for normal 

replacements of 11 to 12 vehicles. 

For this analysis, staff estimated that shuttle vehicles cost about $70,000 when new, 

and that new motor coaches cost about $400,000 when new. This large disparity in cost 

is important in considering compliance options. For this company, staff estimates the 

increased costs to comply with the proposed regulation would be about $0.9 million in 
J-35 

2008 equivalent dollars over the calendar years of 2010-2025.Annual revenue for this 

company is approximately $9.8 million which is cumulatively projected to be about $119 

million in 2008 equivalent dollars over the same time period. To offset the increased 

capital costs of these regulations, this fleet would need to increase revenue by about 

0.8 percent during 2010 to 2025. 

5. Refrigerated Transport Case Study 

As a case study, staff analyzed the economic impact of the proposed regulations and 

the existing transportation refrigeration unit regulation for a refrigerated transport 

company that owns 228 tractors and 270 refrigerated trailers used in long haul 

operations. The average tractor age was 7 years and the average trailer age was about 

6 years old. This particular company normally purchases refrigerated trailers new and 

purchases a range of new-to-3 year old trucks. 

For this company, staff estimates the increased costs to comply with the In-Use HeavyDuty Vehicle proposed regulation would be about $1.5 million in 2008 equivalent dollars 

over the calendar years of 2010-2025. Annual revenues for this company are 

approximately $47.8 million, which are cumulatively projected to be $583 million in 2008 

equivalent dollars over the same time period. To offset the increased capital costs of the 

proposed regulations, this fleet would need to increase revenue by about 0.25 percent, 

or $0.0031 per mile, during 2010 to 2025. 

This company would also be subject to the transport refrigeration unit (TRU) regulation. 

Staff estimate increased TRU costs of $2.1 million in 2008 equivalent dollars would be 

incurred over 2008-2018 to meet the TRU requirements. Thus, the increased costs of 

both rules would be approximately $3.6 million in 2008 equivalent dollars over the 

calendar years of 2010-2025. To offset the increased capital costs of these combined 

regulations, this fleet would need to increase revenue by about 0.61 percent, or $0.0074 

per mile, during 2010 to 2025. 

D. Construction 

ARB fleet survey data submitted by 50 companies with a total of 1,116 vehicles included 

21.6% below the mileage thresholds that would not be subject to replacement prior to 

2020 requirements and 9.5% very low mileage vehicles that would be exempt from the 

performance requirements. These fleets had an average fleet age of 16 years, and the 

median vehicle age was 13.0 years. 

As seen in Figure 17 and Figure 18, while the majority (52.6%) of these vehicles are 

purchased new, only 29% of the vehicles are less than 7 years and 30% are over 15 

years indicating many of these vehicles are kept in fleets for many years. 
J-36 

Figure 17: Construction Vehicle Ages per 2002 VIUS (National), Diesel HeavyDuty Vehicles 

0 to 3 Years

16%

3 to 6 Years

13%

7 to 10 Years

18% 11 to 13 

Years

13%

14 to 15 

Years

10%

>15 Years

30%

Figure 18: Construction Vehicle Age at Purchase per 2002 VIUS (National), 

Diesel Heavy-Duty Vehicles (>15 Years is Unknown) 

<3 Years

52.6%

3 to 6 

Years

23.0%

7 to 10 

Years

15.6%

11 to 15 

Years

8.8%

E. Agricultural Sector 

California is home to the biggest agricultural economy in the United States. California's 

farmers and ranchers have made this state the leader in agricultural production for more 

than 50 years. The agriculture sector includes agriculture production crops, agriculture 

production livestock and animal specialties, agricultural services, forestry, fishing, 

hunting and trapping. Figure 19 shows the agricultural employment percentages in 

California by major crop/activity based on 2007 annual averages. 
J-37 

Figure 19: Percentage of Agricultural Employment in California by Selected 

Major Crop/Activity (2007 Annual Average Data) 

Per the 2002 U.S. Census, California farm land covers 28 million acres with a harvested 

cropland of 8.5 million acres. The average size of a California farm is 346 acres. As 

seen in Figure 20, about 61 percent of California farms have less than 50 acres. In 

2000, California farms made up 4% of the nations farm total. California has some of the 

most agriculturally productive counties in the nation. Eight of the nation’s top 10 

producing counties are in California. Fresno is the leading agricultural county in the 

nation. As reported August 28, 2008 by the USDA’s National Agricultural Statistics 

Service and Economic Research Service, California agriculture saw a 15 percent gain in 

the sales value of its products in 2007. The state’s 75,000 farms and ranches received a 

record $36.6 billion for their output in 2007, a 15 percent gain from 2006. 
J-38 

Figure 20: California Number of Farms by Size Group (2002 U.S. Census) 

 Under 10 acres

27%

 10-49 acres

34%

 50-179 acres

18%

 180-499 acres

10%

 500-999 acres

5%

 1,000 to 1,999 acres

3%

 2,000 acres or more

3%

Per the statewide emission inventory database, there are about 22,000 agricultural 

trucks statewide, of which about 55% are heavy-heavy duty trucks (>33,000 pounds) 

and 45% are medium-heavy duty trucks (14,000-33,000 pounds). As seen in Figure 21 

and Figure 22, while approximately one-third of these vehicles are purchased new, only 

17 percent of the vehicles are less than 7 years and 41% are over 15 years indicating 

many of these vehicles are kept in fleets for the life of the vehicle. 

Figure 21: Agriculture, Forestry, Fishing, or Hunting Vehicle Ages per 2002 

VIUS (National), Diesel Heavy-Duty Vehicles 

0 to 3 Years

8%

3 to 6 Years

9%

7 to 10 Years

18%

11 to 13 

Years

14%

14 to 15 

Years

10%

>15 Years

41%
J-39 

Figure 22: Agriculture, Forestry, Fishing, or Hunting Vehicle Age at Purchase 

per 2002 VIUS (National), Diesel Heavy-Duty Vehicles (>15 Years is Unknown) 

<3 Years

32.5%

3 to 6 Years

28.1%

7 to 10 

Years

26.5%

11 to 15 

Years

12.8%

Agricultural production and farmland trends over time are displayed in Figure 23. Per 

the USDA, between 1989 and 2003 the national trend demonstrates a shift in 

agricultural production to larger farms. 

Figure 23: Agricultural Production is Shifting to Larger Farms 

1. Almond Farm Case Study 

Staff did not receive financial information from any farms or ranches. Therefore, to 

evaluate specific costs, staff used an economic study from the University of California 

(UC), Davis of a typical almond orchard (UC, 2008). The example almond orchard had 

typical gross returns of $4,200 per acre, with net revenues (excluding tractor costs) of 

$213 per acre. The study indicates that a single truck tractor would be needed for an 

orchard of approximately 125 acres. 
J-40 

Survey data from an Almond Board survey suggests that a typical farm truck would be 

16 years old (a 1992 model year) truck and would be driven about 13,000 miles. If this 

truck would be normally replaced when it was 25 years old it would need to be replaced 

in 2017. Under the agricultural provisions of the proposed regulation, this vehicle would 

be required to be replaced by January 1, 2017. The ARB cost model would reflect that 

this type of fleet would normally replace the vehicle with a 10 year old vehicle. 

Therefore, if the farmer chose to purchase a truck with a 2010 model year engine, staff 

estimates that the farmer would need to pay about $12,000 more than normal to replace 

this vehicle. 

For a farm of this size, the total amount of almonds harvested from 2010 to 2025 would 

be about 7,350,000 pounds, valued at $6,400,000 in $2008, yielding a net income of 

$325,000. The increased capital costs to comply with the proposed regulation 

represents about 0.025 percent of the gross revenue received. To offset the increased 

capital costs, of replacing this vehicle, the farmer would need to increase prices by 

$0.001 per pound of almonds. If the farmer operated the truck less than 10,000 miles, 

the truck would not be required to be replaced until 2022. 

F. Retail/Wholesale 

As seen in Figure 24 and Figure 25, approximately three quarters of the vehicles used 

in the retail or wholesale markets are purchased new and only a 9 percent are over 15 

years old. 

Figure 24: Retail/Wholesale Trade Vehicle Ages per 2002 VIUS (National), Diesel 

Heavy-Duty Vehicles 

0 to 3 Years

32%

3 to 6 Years

18%

7 to 10 

Years

24%

11 to 13 

Years

12%

14 to 15 

Years

5%

>15 Years

9%
J-41 

Figure 25: Retail/Wholesale Trade Vehicle Age at Purchase per 2002 VIUS 

(National), Diesel Heavy-Duty Vehicles (>15 Years is Unknown) 

<3 Years

74.5%

11 to 15 

Years

2.6%

7 to 10 

Years

7.1%

3 to 6 Years

15.8%

1. Produce Company Case Study 

A produce company owns 7 vehicles with an average fleet age of 4.4 years. There are 3 

heavy heavy-duty vehicles with annual mileage of 15,000 each and 4 medium heavyduty vehicles with annual mileage of 25,000 each. The company reported a total of 10 

vehicles for their fleet with 3 vehicles not subject to the rule requirement. 

If this company were to install PM retrofits and do the minimum replacements required. 

For this fleet, the proposed regulation would require the installation of PM filters on five 

of the fleet vehicles. Staff estimates the increased costs to comply with the proposed 

regulation would be about $44,900 in 2008 equivalent dollars from 2010 to 2025. 

Annual revenues for this company are approximately $15 million which are cumulatively 

projected to be $183 million in 2008 equivalent dollars over the same time period. To 

offset the increased capital costs of these regulations, this fleet would need to increase 

revenue by about 0.025 percent from 2010 to 2025. 

Alternatively, the company could also choose to make early vehicle replacements to 

avoid these filter retrofits. This would result in increased investments of about $158,000 

($2008) in the years 2010-2013 but no additional replacement would be required until 

2021. Because of the early replacements, the fleet would not make any replacements 

until 2018 when the oldest vehicle would be of an age that would normally be replaced. 

Starting in 2018, the company would return to a normal replacement cycle. The 

increased costs to comply using this option would be approximately $18,000 in 2008 

equivalent dollars over the calendar years of 2010-2025 compared to normal capital 

expenditures. 

2. Beverage Company Case Stud 

A company that distributes beverage products has 687 vehicles with an average fleet 

age of 5.8 years. The fleet includes 213 heavy heavy-duty tractors, 8 medium heavy-
J-42 

duty dry vans and 466 medium heavy-duty beverage trucks with approximately half of 

the vehicles in California. The fleet includes 41 vehicles with less than 1000 annual 

miles which would be exempt from the Truck and Bus rule requirements. 

For this company, staff estimates the increased costs to comply with the proposed 

regulation would be about $2.1 million in 2008 equivalent dollars over the calendar 

years of 2010-2025. This compares to about $52 million that would normally be spent 

for capital upgrades on diesel heavy-duty vehicles over this time period. The annual 

revenues of this company were not provided. To offset the increased capital costs of 

these regulations, this fleet would need to increase revenue by about $0.0028 per mile, 

during 2010 to 2025. 

G. Other Services 

The Other Services (except Public Administration) sector comprises establishments 

engaged in providing services not specifically provided for elsewhere in the 

classification system. Establishments in this sector are primarily engaged in activities 

such as equipment and machinery repairing, promoting or administering religious 

activities, grant making, advocacy, and providing dry-cleaning and laundry services, 

personal care services, death care services, pet care services, photofinishing services, 

temporary parking services, and dating services. 

As seen in Figure 26 and Figure 27, the majority (65%) of Other Service vehicles are 

purchased new and only 10% of the vehicles are over 15 years. 

Figure 26: Other Services Vehicle Ages per 2002 VIUS (National), Diesel HeavyDuty Vehicles 

0 to 3 

Years

32%

3 to 6 

Years

18%

7 to 10 

Years

23%

11 to 13 

Years

11%

14 to 15 

Years

6%

>15 Years

10%
J-43 

Figure 27: Other Services Vehicle Age at Purchase per 2002 VIUS (National), 

Diesel Heavy-Duty Vehicles (>15 Years is Unknown) 

<3 Years

65.2%

3 to 6 Years

19.3%

7 to 10 

Years

11.1%

11 to 15 

Years

4.4%

1. Street Sweeper Case Study 

A sweeper company has 22 vehicles with an average age of 14 years and has revenue 

of $1.6 million per year with a 3 percent growth rate. The fleet includes 15 active 

mainline medium heavy-duty street sweepers and 7 vehicles either for low use or 

awaiting sale. The fleet’s active mainline vehicles average annual mileage is 10,000 

with all miles instate. The increased capital costs would be approximately $994,000 in 

2008 equivalent dollars and the revenue received would be approximately $25,700,000 

in 2008 equivalent dollars. The increased capital costs represent 3.8% of the revenue 

received over this time period absent existing regulations. However, because this 

sweeper fleet has several sweepers with uncontrolled auxiliary engines they would not 

be able to operate in 2010 and could only be replaced with new ones because they are 

currently subject to the portable engine BACT requirements. Staff’s proposal to remove 

the auxiliary engine from the scope of the portable equipment ATCM and to treat the 

auxiliary engines at the same time as the main drive engine in the current proposal, the 

net cost of the current proposal would be lower than the status quo. 

2. Towing Case Study 

A towing company has 5 vehicles with an average fleet age of 18.2 years and receives 

annual revenue of approximately $1,000,000. The fleet includes 1 heavy heavy-duty 

tractor, 3 heavy heavy-duty tow trucks and 1 medium heavy-duty tow trucks. The fleet’s 

total annual mileage is 175,000 with 155,000 miles specific to California. The fleet has 1 

low mileage vehicle which would have delayed rule requirements. On average, this 

company would replace a vehicle every 5 to 6 years with a used vehicle of 6 to 10 

years. Staff modeled that replacement would be with an 8 year old vehicle. 
J-44 

For this company, staff estimates the increased costs to comply with the proposed 

regulation would be about $429,000 in 2008 equivalent dollars over the calendar years 

of 2010-2025. This compares to about $135,500 that would normally be spent for capital 

upgrades over this time period. Annual revenues for this company are approximately $1 

million which are cumulatively projected to be $12.2 million in 2008 equivalent dollars 

over the same time period. To offset the increased capital costs of these regulations, 

this fleet would need to increase revenue by about 3.5 percent during 2010 to 2025. 
J-45 

Table 20: Medium Heavy-Duty Vehicle Price Data 

0 1 2 3 4 5 6 7 8 9 10 15 20 

Beverage Single $55,205 $46,492 $39,040 $32,712 $27,380 $22,926 $19,241 $16,226 $13,787 $11,842 $10,315 $6,781 $6,129 

Bucket/Boom Single $52,071 $48,687 $45,518 $42,553 $39,785 $37,207 $34,809 $32,583 $30,521 $28,615 $26,856 $19,985 $15,560 

Bus/Shuttle Single $71,850 $54,703 $40,872 $29,945 $21,534 $15,274 $10,821 $8,141 $7,293 $6,618 $6,068 $4,344 $3,427 

Bus (Motor Coach) Single $99,081 $83,136 $69,485 $57,870 $48,052 $39,814 $32,953 $27,287 $22,649 $18,887 $15,866 $8,085 $5,813 

Cab & Chassis (Cabover) Single $40,972 $35,101 $30,075 $25,804 $22,206 $19,197 $16,701 $14,645 $12,962 $11,590 $10,470 $7,127 $5,534 

Cab & Chassis Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Car Carrier Single $66,424 $57,786 $50,344 $43,959 $38,508 $33,874 $29,951 $26,643 $23,862 $21,530 $19,575 $13,487 $10,112 

Chipper Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Crane Single $95,284 $86,348 $77,713 $69,498 $61,800 $54,689 $48,216 $42,413 $37,293 $32,852 $29,074 $18,741 $15,902 

Dump Single $55,561 $49,636 $44,323 $39,584 $35,383 $31,683 $28,445 $25,633 $23,210 $21,138 $19,381 $14,116 $11,919 

Expeditor/Hot Shot Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Farm/Grain Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Flatbed Single $48,792 $42,264 $36,681 $31,933 $27,917 $24,539 $21,713 $19,362 $17,415 $15,807 $14,482 $10,535 $8,408 Flatbed: Dump Single $53,143 $47,313 $42,108 $37,473 $33,357 $29,712 $26,491 $23,654 $21,160 $18,973 $17,061 $10,613 $7,399 Fuel/Lube Single $84,104 $75,392 $67,746 $61,038 $55,155 $49,992 $45,455 $41,461 $37,933 $34,805 $32,019 $21,652 $14,762 

Garbage: Packer Same $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Garbage: Roll-off $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Grapple $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Hooklift Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Landscape Single $50,056 $43,888 $38,641 $34,205 $30,476 $27,361 $24,773 $22,634 $20,872 $19,422 $18,227 $14,483 $11,748 

Logging Tandem $200,744 $162,704 $132,920 $109,845 $92,155 $78,722 $68,598 $60,997 $55,272 $50,902 $47,474 $35,827 $25,964 

Mixer/Concrete Same $160,796 $145,511 $130,973 $117,235 $104,339 $92,314 $81,179 $70,941 $61,598 $53,140 $45,548 $19,439 $8,792 

Service/Utility Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Stake Single $39,214 $35,236 $31,640 $28,405 $25,511 $22,938 $20,666 $18,673 $16,939 $15,445 $14,170 $10,358 $8,954 Tank: General Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Tank: Asphalt Single $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: Chemical Single $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: Liq. Fuel Same $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: LPG Same $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: Milk Single $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: Vacuum Single $95,088 $80,568 $68,202 $57,740 $48,951 $41,623 $35,562 $30,590 $26,548 $23,291 $20,689 $13,907 $11,272 

Tank: Water Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Tow: Roll-back Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Tow: Wrecker Single $62,830 $56,319 $50,345 $44,884 $39,911 $35,402 $31,332 $27,676 $24,409 $21,507 $18,945 $9,335 $6,372 

Tractor: Conventional w/o Tractor: Cabover w/o Sleeper Single $45,893 $40,029 $34,923 $30,501 $26,692 $23,429 $20,651 $18,301 $16,326 $14,677 $13,310 $9,376 $7,693 Sleeper Single $61,565 $53,654 $46,531 $40,174 $34,559 $29,650 $25,408 $21,790 $18,745 $16,223 $14,169 $8,983 $7,595 

Van: Dry Single $52,868 $45,055 $38,506 $33,051 $28,532 $24,806 $21,743 $19,223 $17,143 $15,409 $13,944 $8,755 $5,672 

Van: Moving Single $60,621 $51,703 $43,969 $37,314 $31,636 $26,838 $22,828 $19,518 $16,824 $14,666 $12,971 $9,116 $8,135 

Van: Reefer Single $74,028 $58,819 $47,295 $38,667 $32,267 $27,537 $24,021 $21,355 $19,257 $17,521 $16,003 $9,985 $7,698 

Winch Single $90,712 $82,206 $74,232 $66,787 $59,863 $53,450 $47,537 $42,109 $37,151 $32,644 $28,570 $13,938 $6,715 Yard Spotter (Goat) Single $58,484 $52,833 $48,465 $44,869 $41,678 $38,650 $35,651 $32,633 $29,613 $26,661 $23,873 $15,473 $13,378 

Tractor: Cabover w/o Sleeper Single $45,893 $40,029 $34,923 $30,501 $26,692 $23,429 $20,651 $18,301 $16,326 $14,677 $13,310 $9,376 $7,693 

Tractor: Conv w/o Sleeper Single $61,565 $53,654 $46,531 $40,174 $34,559 $29,650 $25,408 $21,790 $18,745 $16,223 $14,169 $8,983 $7,595 

Tank: LPG Same $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: Milk Single $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,717 

Tank: Vacuum Single $95,088 $80,568 $68,202 $57,740 $48,951 $41,623 $35,562 $30,590 $26,548 $23,291 $20,689 $13,907 $11,272 

Tank: Water Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Tow: Roll-back Single $52,409 $43,888 $36,822 $31,026 $26,326 $22,564 $19,591 $17,270 $15,477 $14,102 $13,045 $9,896 $6,781 

Tow: Wrecker Single $62,830 $56,319 $50,345 $44,884 $39,911 $35,402 $31,332 $27,676 $24,409 $21,507 $18,945 $9,335 $6,372 

Tractor: Conventional w/o Tractor: Cabover w/o Sleeper Single $45,893 $40,029 $34,923 $30,501 $26,692 $23,429 $20,651 $18,301 $16,326 $14,677 $13,310 $9,376 $7,693 Sleeper Single $61,565 $53,654 $46,531 $40,174 $34,559 $29,650 $25,408 $21,790 $18,745 $16,223 $14,169 $8,983 $7,595 

Van: Dry Single $52,868 $45,055 $38,506 $33,051 $28,532 $24,806 $21,743 $19,223 $17,143 $15,409 $13,944 $8,755 $5,672 

Van: Moving Single $60,621 $51,703 $43,969 $37,314 $31,636 $26,838 $22,828 $19,518 $16,824 $14,666 $12,971 $9,116 $8,135 

Van: Reefer Single $74,028 $58,819 $47,295 $38,667 $32,267 $27,537 $24,021 $21,355 $19,257 $17,521 $16,003 $9,985 $7,698 

Winch Single $90,712 $82,206 $74,232 $66,787 $59,863 $53,450 $47,537 $42,109 $37,151 $32,644 $28,570 $13,938 $6,715 Yard Spotter (Goat) Single $58,484 $52,833 $48,465 $44,869 $41,678 $38,650 $35,651 $32,633 $29,613 $26,661 $23,873 $15,473 $13,378 

Transfer Body 

($)

$9,500$9,500

$18,000

$8,500$9,500$9,500$9,500$9,500$9,500

Age in 2008 Rear Axle

$9,500

$10,500

$6,000$8,500

$24,000$11,500

$9,000$9,500

MHD Vehicle Type

$9,500$9,500$9,500
J-46 

Table 21: Heavy Heavy-Duty Vehicle Price Data 

0 1 2 3 4 5 6 7 8 9 10 15 20 

Beverage Single $75,611 $61,861 $50,456 $41,113 $33,565 $27,565 $22,881 $19,301 $16,628 $14,683 $13,307 $10,539 $7,8

Bucket/Boom Tandem $25,000 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Bus (Motor Coach) Tandem $449,954 $404,277 $360,925 $320,078 $281,879 $246,436 $213,822 $184,072 $157,187 $133,131 $111,832 $41,687 $18,

Cab & Chassis Single $59,836 $51,269 $43,898 $37,589 $32,218 $27,670 $23,840 $20,634 $17,963 $15,750 $13,923 $8,621 $6,2

Cab & Chassis Tandem $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Cab & Chassis Dual Frame Tandem $105,738 $90,581 $77,693 $66,800 $57,649 $50,010 $43,674 $38,451 $34,171 $30,679 $27,841 $19,764 $15,Car Carrier Tandem $261,761 $228,860 $199,472 $173,394 $150,421 $130,351 $112,980 $98,103 $85,517 $75,018 $66,403 $44,448 $38,Chipper Single $10,500 $59,836 $51,269 $43,898 $37,589 $32,218 $27,670 $23,840 $20,634 $17,963 $15,750 $13,923 $8,621 $6,2Cotton Module Tandem $10,500 $105,738 $90,581 $77,693 $66,800 $57,649 $50,010 $43,674 $38,451 $34,171 $30,679 $27,841 $19,764 $15,Crane (Boom) Same $152,706 $129,256 $109,978 $94,253 $81,524 $71,294 $63,121 $56,616 $51,440 $47,303 $43,956 $33,087 $24,

Drill Rig Tandem $756,478 $652,807 $565,406 $492,256 $431,507 $381,463 $340,583 $307,469 $280,861 $259,631 $242,777 $196,921 $170

Dump Tandem $9,250 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Dump: Transfer Single $208,875 $180,973 $157,445 $137,712 $121,248 $107,578 $96,272 $86,948 $79,265 $72,923 $67,661 $50,749 $39,

Expeditor/Hot Shot Tandem $114,960 $88,866 $72,526 $61,322 $52,460 $44,494 $36,917 $29,803 $23,518 $18,478 $14,980 $11,473 $9,6

Farm/Grain Same $113,235 $97,606 $84,512 $73,630 $64,662 $57,339 $51,415 $46,669 $42,903 $39,939 $37,622 $31,543 $27,

Flatbed Tandem $79,035 $69,876 $61,783 $54,662 $48,426 $42,989 $38,271 $34,195 $30,689 $27,684 $25,118 $16,904 $12,

Flatbed: Dump Tandem $80,422 $70,173 $61,191 $53,369 $46,602 $40,790 $35,838 $31,656 $28,158 $25,262 $22,892 $16,568 $14,

Fuel/Lube Single $25,500 $59,836 $51,269 $43,898 $37,589 $32,218 $27,670 $23,840 $20,634 $17,963 $15,750 $13,923 $8,621 $6,2Fuel/Lube Tandem $25,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Garbage: Packer Tandem $24,000 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Garbage: Roll-off Tandem $11,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,Grapple Tandem $18,000 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Hooklift Tandem $8,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Logging Tandem $200,744 $162,704 $132,920 $109,845 $92,155 $78,722 $68,598 $60,997 $55,272 $50,902 $47,474 $35,827 $25,Mixer/Concrete Tandem $160,796 $145,511 $130,973 $117,235 $104,339 $92,314 $81,179 $70,941 $61,598 $53,140 $45,548 $19,439 $8,7

Service/Utility Single $9,000 $59,836 $51,269 $43,898 $37,589 $32,218 $27,670 $23,840 $20,634 $17,963 $15,750 $13,923 $8,621 $6,2Stake Single $106,567 $85,350 $67,970 $53,902 $42,672 $33,849 $27,045 $21,913 $18,146 $15,472 $13,654 $11,046 $9,8

Sweeper Single $207,024 $180,509 $157,184 $136,727 $118,842 $103,254 $89,707 $77,969 $67,827 $59,085 $51,567 $27,283 $15,

Tank: General Tandem $9,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Tank: Asphalt Same $108,330 $96,090 $85,561 $76,531 $68,806 $62,210 $56,582 $51,778 $47,668 $44,137 $41,085 $30,293 $22,Tank: Chemical Same $108,330 $96,090 $85,561 $76,531 $68,806 $62,210 $56,582 $51,778 $47,668 $44,137 $41,085 $30,293 $22,

Tank: Liq. Fuel Same $108,330 $96,090 $85,561 $76,531 $68,806 $62,210 $56,582 $51,778 $47,668 $44,137 $41,085 $30,293 $22,

Tank: LPG Same $108,330 $96,090 $85,561 $76,531 $68,806 $62,210 $56,582 $51,778 $47,668 $44,137 $41,085 $30,293 $22,Tank: Milk Tandem $108,330 $96,090 $85,561 $76,531 $68,806 $62,210 $56,582 $51,778 $47,668 $44,137 $41,085 $30,293 $22,Tank: Vacuum Same $162,565 $137,737 $117,636 $101,496 $88,633 $78,442 $70,393 $64,027 $58,949 $54,827 $51,385 $38,161 $25,Tank: Water Single $9,500 $59,836 $51,269 $43,898 $37,589 $32,218 $27,670 $23,840 $20,634 $17,963 $15,750 $13,923 $8,621 $6,2

Tank: Water Tandem $9,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Toter Same $140,987 $118,185 $98,844 $82,549 $68,917 $57,599 $48,276 $40,658 $34,486 $29,524 $25,565 $15,122 $10,

Tow: Roll-back Single $9,500 $59,836 $51,269 $43,898 $37,589 $32,218 $27,670 $23,840 $20,634 $17,963 $15,750 $13,923 $8,621 $6,2

Tow: Roll-back Tandem $9,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Tow: Wrecker Tandem $300,478 $270,655 $243,293 $218,257 $195,415 $174,638 $155,799 $138,776 $123,449 $109,703 $97,424 $54,347 $33,

Tractor: Cabover w/o Sleeper Single $92,201 $77,615 $65,065 $54,362 $45,327 $37,789 $31,582 $26,554 $22,558 $19,456 $17,119 $12,965 $10,Tractor: Cabover w/o Sleeper Tandem $105,151 $88,278 $73,997 $62,035 $52,132 $44,044 $37,539 $32,401 $28,425 $25,422 $23,216 $18,968 $16,

Tractor: Cabover w/ Sleeper Tandem $131,961 $101,674 $78,671 $61,516 $48,967 $39,964 $33,617 $29,193 $26,099 $23,873 $22,166 $15,628 $12,

Tractor: Conventional w/ Sleeper Tandem $131,961 $101,674 $78,671 $61,516 $48,967 $39,964 $33,617 $29,193 $26,099 $23,873 $22,166 $15,628 $12,

Tractor: Conventional w/o Sleeper Single $92,201 $77,615 $65,065 $54,362 $45,327 $37,789 $31,582 $26,554 $22,558 $19,456 $17,119 $12,965 $10,

Tractor: Conventional w/o Sleeper Tandem $105,151 $88,278 $73,997 $62,035 $52,132 $44,044 $37,539 $32,401 $28,425 $25,422 $23,216 $18,968 $16,Van: Dry Single $54,910 $47,717 $41,364 $35,794 $30,950 $26,774 $23,211 $20,203 $17,692 $15,623 $13,937 $9,273 $7,3Van: Dry Tandem $98,469 $85,185 $73,317 $62,783 $53,502 $45,391 $38,368 $32,351 $27,259 $23,009 $19,519 $10,599 $8,9Van: Moving Single $75,179 $60,443 $48,520 $39,009 $31,538 $25,766 $21,384 $18,115 $15,711 $13,957 $12,668 $8,920 $7,2Van: Reefer Same $78,491 $64,827 $53,746 $44,836 $37,726 $32,090 $27,640 $24,126 $21,335 $19,084 $17,227 $10,562 $5,8Winch Tandem $8,500 $96,685 $82,337 $70,285 $60,228 $51,895 $45,038 $39,433 $34,881 $31,202 $28,238 $25,852 $18,928 $14,

Yard Spotter (Goat) Single $79,950 $66,817 $56,304 $47,958 $41,382 $36,229 $32,200 $29,038 $26,528 $24,495 $22,796 $16,334 $11,

0 1 2 4 6 8 10 15 20 25 30 35 40 45 

$2,909/hp $2,690/hp $2,488/hp $2,129/hp $1,821/hp $1,557/hp $1,332/hp $902/hp $610/hp $413/hp $279/hp $189/hp $128/hp $98/

Tandem Two-Engine Crane ($/HP by Yr) (Lattice Boom/All- Terrain/Mounted Hydraulic)

HHD Vehicle Type Age in 2008 Rear Axle Transfer Body ($)
J-47 

Table 22: Sample Individual Company Fleet Costs 
J-48 

SAMPLE INDIVIDUAL COMPANY FLEET COSTS 
J-49 

SAMPLE INDIVIDUAL COMPANY FLEET COSTS
J-50 

SAMPLE INDIVIDUAL COMPANY FLEET COSTS
J-51 

SAMPLE INDIVIDUAL COMPANY FLEET COSTS
J-52 

H. References 

ARB 2003. Air Resources Board. Supplemental Staff Report: Proposed Diesel 

Particulate Matter Control Measure For On-Road Heavy-Duty Residential and 

Commercial Solid Waste Collection Vehicles. Appendix F – Revised Cost Effectiveness 

Methodology. August 11, 2003. 

http://www.arb.ca.gov/regact/dieselswcv/appf2.pdf

ARB 2006a. Air Resources Board. December 2006 In-Use Off-road Diesel Vehicle 

Workshops. Quotes from diesel emissions control manufacturers at workshops. 

December 2006. 

ARB, 2007. Air Resources Board. Technical Support Document, Regulations to 

Control Emissions From In-Use On-Road Diesel-Fueled Heavy Duty Drayage Trucks. 

Appendix D: Methodologies for Economic Impact Assessment. October 2007. 

http://www.arb.ca.gov/regact/2007/drayage07/appbf.pdf 

CEC 2008. California Energy Commission, California Gasoline Statistics & Data, Price 

of California No 2 Diesel in September 2008. 

http://energyalmanac.ca.gov/gasoline/

VIUS 2002. U.S. Census Bureau, Vehicle Inventory and Use Survey, 2002 Data 

Releases. 

http://www.census.gov/svsd/www/vius/2002.html