Appendix F 

Evaluation of the Use of Alternative Fuels in 

Cargo Handling Equipment
F - 1 

Evaluation of the Use of Alternative Fuels in Cargo Handling Equipment 

Alternative fuels can be used in engines subject to the proposed cargo handling 

equipment regulation – as long as the engines meet the requirements, which are based 

on best available control technology (BACT), outlined in the proposed regulation. Inuse yard trucks would be required to meet the 2007 or later certified on-road diesel 

engine standards, the final Tier 4 certified off-road diesel engine standards, or install a 

verified diesel emission control strategy (VDECS) that will result in the engine meeting 

equivalent diesel PM and NOx emissions of the final Tier 4 certified off-road diesel 

engine standards. In-use non-yard truck cargo handling equipment also have several 

compliance options, which include, but are not limited to, meeting certified on-road or 

off-road diesel engine standards and/or applying VDECS. A detailed discussion of the 

requirements is available in Chapter 4 of this Staff Report. These requirements do not 

specify that diesel fuel be used in cargo handling equipment engines. In fact, they were 

established for both diesel-fueled diesel engines and diesel engines that use alternative 

fuels. As such, an engine that meets the requirements of the proposed regulation would 

be considered BACT if it used diesel or an alternative fuel. 

 

A. Alternative Fuel Types

Liquefied Natural Gas: (LNG) is an odorless, colorless, non-corrosive and non-toxic. 

When extracted from underground reserves, natural gas is composed of approximately 

90 percent methane. During the liquefaction process, oxygen, carbon dioxide, sulfur 

compounds, and water are removed, purifying the fuel and increasing its methane 

content to almost 100 percent. As a result, LNG-fueled vehicles can offer significant 

emissions benefits compared with older diesel-powered vehicles and can significantly 

reduce carbon monoxide and particulate emissions as well as nitrogen oxide emissions. 

(EPA, 2002) 

Compressed Natural Gas: (CNG) is odorless, colorless, and tasteless. It consists 

mostly of methane and is drawn from gas wells or in conjunction with crude oil 

production. CNG vehicles store natural gas in high-pressure fuel cylinders at 3,000 to 

3,600 psi. An odorant is normally added to CNG for safety reasons. (EPA, 2002a) 

Liquefied Petroleum Gas: (Propane or LPG) is a byproduct of natural gas processing 

and petroleum refining. In its natural state, propane is a colorless, nontoxic gas -- at 

least 90 percent propane, 2.5 percent butane and higher hydrocarbons, and the balance 

ethane and propylene. Under moderate pressure, propane gas turns into a liquid 

mixture, making it easier to transport and store in vehicle fuel tanks. Compared with 

gasoline, propane can lower carbon dioxide, carbon monoxide, and other toxic 

emissions. (EPA, 2002b) 
F - 2 

B. Alternative Fuels Specifications (Regulations Concerning Fuel Quality) 

The Air Resources Board (ARB) adopted specifications for all alternative motor vehicle 

fuels can be found in the California Code of Regulations, Title 13, Division 3, Chapter 5, 

Article 3, Sections 2290-2292.6. When the Board adopted specifications for vehicular 

alternative fuels1

, it set essentially identical standards for the motor vehicle fuel sold 

commercially in California and the fuel used for emission standard certification testing of 

new motor vehicles. The purpose for the commercial fuel specifications is to ensure 

that motor vehicles certified on alternative fuel will receive in-use fuel having a quality 

similar to that of a certification fuel, so that vehicles will achieve their emission 

standards in use. 

C. Standards For and Availability of Alternative Fueled Engines 

The ARB must certify new motor vehicles and engines for emission compliance before 

they are legal for sale, use, or registration in California. Certification is granted annually 

to individual engine families and is good for one model year. Table F-1 lists the on-road 

heavy-duty engines that are CARB certified using alternative fuels. 

Table F-1 

2005 CARB Certified Alternative Fueled On-Road Engines 

Engine 

Manufacturer Fuel Type Engine Size (L) Hp Class CARB 

Executive Order #

CNG/LNG 5.9 195 - 230 MHDD A-021-0377 

CNG/LNG 8.3 250 - 280 MHDD A-021-0381 

CNG/LNG 8.3 250 - 280 UB A-021-0382 

CNG/LNG 8.9 320 MHDD A-021-0372 

CNG/LNG 8.9 320 MHDD A-021-0372-1 

Cummins 

CNG/LNG 8.9 320 UB A-021-0373 

CNG 8.1 275 - 280 HHDD A-108-0035 

John Deere CNG 8.1 250 MHDD A-108-0037 

CNG 8.1 250 - 280 UB A-108-0036 

CNG/LNG 8.5 275 UB A-290-0116 DDC* CNG/LNG 11.9 275 UB A-290-0117 

Mack Truck CNG/LNG 8.1 325 - 425 HHDD A-027-0118 

Bi-Phase LPG 8.1 325 HDO A-360-0003 

Technology LPG 8.1 325 HDO A-360-0004 

 MHDD= Medium Heavy Duty Diesel 

 UB= Urban Bus 

 HDO= Heavy Duty Off-Road 

* DDC no longer offers an alternative fuel engine for sale in California. (ARB 2005d) 

 

1

 Alternative fuels are defined as any fuel which is commonly or commercially known as one of the 

following: M-100 fuel methanol, M-85 fuel methanol, E-100 fuel ethanol, M-85 fuel ethanol, CNG, LPG, or 

hydrogen. 
F - 3 

The ARB also certifies off-road engines prior to their legal sale, use, or registration in 

California. Table F-2 lists two certified alternative fueled engines for off-road use in 

2005. Both of these engines are also certified for on-road use. The Executive Order 

(E.O.) # U-R-002-0302 is on-road E.O. # A-021-0377 and E.O.# U-R-002-0303 is onroad E.O. # A-021-0378. 

Table F-2 

2005 CARB Certified Alternative Fueled Off-Road Engines

Engine 

Manufacturer 

Fuel Type Engine Size 

(L) 

Hp Class CARB 

Executive 

Order #

Cummins CNG/LNG 5.9 195 - 230 MHDD U-R-002-0302 

Cummins LPG 5.9 185 MHDD U-R-002-0303 

. 

Table F-3 below lists the on-road emission standards for heavy duty diesel engines 

along with certification information for an 2005 alternative fueled engine. 

Table F-3 

Compare 2005 Alternative Fuel Engine Certification and 

Heavy-Duty On-Road Engines FTP Transient Test Standard (g/bhp-hr)

Model Year Fuel NOx CO PM 

2005 Certification* CNG/LNG 1.4 (+HC) 1.0 0.004 

Stardard 

1990 Diesel 6.0 15.5 0.6 

1991 - 1993 Diesel 5.0 15.5 0.25 

1994 - 1998 Diesel 5.0 15.5 0.1 

2004 Diesel 2.4 (+nmoc) 15.5 0.1 

2007 Diesel 0.2** 15.5 0.01 

*Certification for family 5CEXH0359BBG, ARB Executive Order A-021-0377 

**phase in schedule, 50% from 2007 to 2009, 100% in 2010. (Diesel, 2002) 

Tables F-4 compares two 2005 alternative fuel engine certification levels to the 

certification standards for off-road engines in the 175 to 300 horsepower range. Diesel 

emission certification limits are the standard that alternative fuel off-road engines must 

meet. 
F - 4 

Table F-4 

Comparison of 2005 Alternative Fuel Engine Certifications and 

Off-Road Compression Ignition (diesel) Certification Standards (g/bhp-hr)

Year Type Horse

power 

Fuel NMOC+

NOx PM CO 

2005 *Off-Road 

Certification 185 LPG 2.1 0.01 0.8 

2005 **Off-Road 

Certification

195 - 

230 

CNG/

LNG 1.4 0.004 1.0 

1996 

Tier 1 

Off-Road 

C.I. Std. 

(Diesel) 

175 to 

<300 Diesel 7.9 0.4 8.5 

2001 

Tier 2 

Off-Road 

C.I. Std. 

(Diesel) 

175 to 

<300 Diesel 4.9 0.15 2.6 

2006 

Tier 3 

Off-Road 

C.I. Std. 

(Diesel) 

175 to 

<300 Diesel 2.9 0.15 2.6 

2011 

Tier 4 

Off-Road 

C.I. Std. 

(Diesel) 

175 to 

<300 Diesel 1.6 0.01 2.6 

*Certification for family 5CEXH0359BBG, ARB Executive Order # A-021-037 

** Certification for family 5BPTELPGEFVAP, ARB Executive Order # A-360-004 

D. Current Use of Alternative Fuels in Cargo Handling Equipment 

Currently, LPG powered forklifts are being used at the Ports of Long Beach and 

Los Angeles container and dry and break bulk terminals. Container terminals at the 

POLB had 77 forklifts, 31 (43%) of the forklifts use LPG fuel; the remaining forklifts are 

diesel powered. Likewise, at the Port of Los Angeles, the container terminals totaled 

46 forklifts, 4 (9%) of the forklifts use LPG fuel. Total forklifts at POLB dry and break 

bulk terminals was 153 forklifts. LPG fuel was used in 37 (24%) forklifts, instead of 

diesel fuel. At the POLA, a majority (78%) of the forklifts are using LPG instead of 

diesel or gasoline. (Starcrest, 2004a) (Starcrest, 2004b) 

Raley’s has been successfully using LNG yard tractors for 8 years. According to a 

Raley’s representative, the LNG yard tractors work fine compared to the diesel tractors. 

The drivers have commented the engine produces less soot and smell. Because of the 

higher cost of running LNG engines and the current and future cleaner emitting diesels, 

the future of the LNG fleet at Raley’s does not look promising. Higher cost fuel, for 

example, is costing about $2.25 for diesel and about $4.00 for LNG equivalent. Another 

high cost is spark plug replacement, costing each engine $28 per cylinder every 

25,000 to 35,000 miles. (ARB, 2005a) 
F - 5 

Von’s grocery, responding to a NRDC lawsuit, is using LNG yard tractors at their 

distribution center. A Von’s representative stated the drivers do not seem to notice 

between the LNG and the diesel trucks, other than refueling the LNG more often. One 

point is the higher cost of the fuel, about 20% higher for LNG than diesel fuel. 

(ARB 2005b) 

Port of Virginia is currently using new “hybrid” straddle carriers. The hybrid technology 

is new to straddle carriers. Common straddle carriers are powered by diesel engines 

powering hydraulics for motion and lifts. New hybrid technology straddle carriers enlist 

the use of a diesel-electric drive, the same technology that has been used by rubber 

tired gentry cranes in use in California. According to a supervisor at the Port of Virginia, 

the new “hybrid” straddle carriers are working just fine. (ARB, 2005e) 

The Port of Long Beach (POLB) will be conducting a pilot project to evaluate LNG 

feasibility on some cargo handling equipment. The LNG equipment will be compared to 

the standard diesel equipment to meet the port needs and future emission standards. 

Currently, the POLB has ordered LNG yard trucks and is awaiting delivery. 

(POLB, 2005) 

E. Fuel Cost 

Table F-5 compares standard fuel prices to alternate fuel prices. Gasoline and diesel 

prices shown are retail prices. The prices include federal, state, and local taxes. The 

prices are listed as gasoline gallon equivalent. 

Table F-5 

Alternative Fuel Price / Gallon Comparison 

Fuel Week of 11/15/04 Week of 3/21/05 

Gasoline 2.22 2.56 

Diesel 2.27 2.47 

CNG* 1.82 1.56 

Propane* 2.33 1.63 

*Price gasoline gallon equivalent (All West Coast Prices) 

(Clean Cities, 2005) 
F - 6 

Table F-6 below outlines various fuels and its energy content relative to gasoline. 

 

Table F-6 

Gasoline Gallon Equivalency Table 

Fuel Unit BTU's Gal. 

Equivalent 

Gasoline Gallon 114,100 1.00 

Gasoline 

(RFG) Gallon 112,000 1.02 

Diesel Gallon 129,800 0.88 

LNG Gallon 75,000 1.52 

CNG Cubic Foot 900 126.67 cu. ft. 

LPG Gallon 84,300 1.35 

 Soy Power, 2005 

Although at present natural gas is less expensive than diesel, it is impossible to be 

certain about fossil fuel market conditions between now and 2020. In recent years, 

CNG has been 15 – 20 percent more expensive (on a $/mile basis) compared to diesel. 

However, key parameters of the natural gas market appear to be changing. Canadian 

imports, which have met domestic demand growth in the past 10 – 15 years, are 

becoming insufficient. In addition, environmental concerns continue to favor natural gas 

combustion over oil and coal, and demand for cleaner fuels may well push natural gas 

prices higher. (ARB, 2005g) 

F. Fueling Infrastructure Cost 

Gasoline and diesel fuel terminals are commonly located at or very near ports. Thus, 

the fueling infrastructure already exists. The same is not true for alternative fuels. As a 

result, using an alternative fuel will result in infrastructure costs not associated with 

diesel or gasoline. 

The recent analysis, prepared by ARB regarding the South Coast transit bus rule, 

identified the cost of construction of an L/CNG (gasification) station at about $25,000 

per bus and for a CNG (compression) station at about $36,000 per bus. 

In 1998, Raley’s constructed a permanent 13,000 gallon LNG fueling station at an 

estimated cost of $350,000. This station fueled eight heavy-duty on-road trucks and 

two yard tractors. A current completed LNG terminal, dispensing about 16,000 gallons 

from a single point will cost about $700,000. This terminal would refuel about 30-35 

vehicles. Costs for a permanent alternative fueling site can vary widely. (ARB, 2005a) 

(Raley's, 2000) (Clean Car Maps, 2005) (ARB, 2005f) (ARB, 2005g) 
F - 7 

G. Equipment Cost 

Alternative fuel engines are more expensive to purchase than their diesel counterparts. 

ARB staff estimated that the costs of a LNG yard truck is currently about $40,000 per 

truck more than its diesel counterpart. In collection vehicle application, ARB staff 

estimated that the incremental cost of a collection vehicle is $50,000 more than a diesel 

equipped vehicle. 

Another source of information on the cost of alternative fuel equipment is the Carl Moyer 

Program. Since 1998 there have been 23 projects for yard hustlers operating in 

California, most in port areas. All of the projects replaced diesel engines with liquefied 

natural gas engines. The engines were 195 or 200 horsepower engines. The chart 

below lists the incremental cost increase of a LNG engine compared to a similar diesel 

engine. (Carl Moyer) 

Table F-7 

LNG Compared to Diesel 

Incremental Cost per Unit 

Year Quantity Incremental Cost 

1998 - 1999 12 $9,630 - $20,000 

2001 - 2002 1 $19,499 

2002 - 2003 10 $29,128 

H. Maintenance and Repair Costs 

Based on current experiences with natural gas buses and collection vehicles, ARB staff 

believes that maintenance costs for alternative fueled equipment will be somewhat 

higher than for diesel equipment. For example, staff estimated the extra maintenance 

cost for natural gas buses to be $4,300 per year and $2,000 per year for collection 

vehicles. Additional costs would also occur due to maintenance of the fueling facility. 

I. Other Technologies 

Dual Fuel: Dual fuel engines are compression ignition engines that use diesel fuel and 

a supplementary fuel. The supplementary fuel is usually natural gas, but propane and 

even methanol can be used. They operate very similarly to diesel engines and they 

may operate on a wide percentage of diesel fuel, ranging from 100% diesel to as little 

as 1%. Many older dual fuel engines obtained about 5% of their energy from diesel 

fuel, but newer pre-chamber dual fuel engines may use as little as 1%. An advantage of 

dual fuel engines is that they can attain higher efficiencies than spark ignition engines 

(CI engines are more efficient than SI engines), but they have lower emissions than 

diesel engines. 
F - 8 

A diesel engine cannot be used if alternative fuel is only being used. An alternative 

fueled engine needs a spark ignition to ignite the fuel. Manufacturers use diesel 

engines as a base to burn alternative fuel. The diesel engines have been modified to 

accomplish a spark ignition instead of a compression ignition, lower compression ratio, 

and air and fuel mixture combined prior to entering the combustion chamber, 

comparable to an Otto cycle engine. 

 J. Conclusions

Alternative fuel use in cargo handling equipment has been successful on limited 

equipment applications. However, high fuel and infrastructure cost, new cleaner 

emitting diesel engines, and small number of engines available make alternative fuel a 

limited option. Yard trucks and forklifts have been successfully using alternative fuel. 

However, the use of 2007 on-road engines in yard trucks greatly narrows the emissions 

reduction advantage of alternative fuels compared to diesel for this application. 

Additional alternative fuel projects involving other cargo handling equipment (i.e., top 

handlers, RTG cranes, etc.) will need to take place before a full port or rail yard can use 

alternative fuel for all applications. The possible higher cost of the alternative fuel and 

alternative fuel infrastructure, along with cleaner diesel engines which are near to the 

emissions of alternative fuel engines, favors selection of alternative fuels on a case-bycase basis instead of a general mandate. 
F - 9 

REFERENCES:

(ARB, 2005a) California Air Resources Board. 5/27/05. Telephone conversation with 

Mr. Stan Sasaki of Raley's. May 27, 2005 

(ARB, 2005b) California Air Resources Board. 5/27/05. Telephone conversation with 

Mr. Tom Nartker of Von’s/Safeway. May 31, 2005 

(ARB, 2005c) California Air Resources Board. 6/13/05, Telephone conversation with 

Mr. Robert Oldum, of NorthStar Inc. June 13, 2005 

(ARB, 2005d) California Air Resources Board. 6/27/05, Telephone conversation with 

Mr. Ralph Mendez, Valley Power Systems 

(ARB, 2005e) California Air Resources Board. 6/28/05, Telephone conversation with 

Mr. Dan Demers, Supervisor Port of Virginia. 

(ARB, 2005f) California Air Resources Board Staff Report: Proposed Amendments to 

the Exhaust Emission Standards for 2007-2009 Model – Year Heavy Duty Urban Bus 

Engines and the Fleet Rule for Transit Agencies. July 29, 2005. 

(ARB, 2005g) California Air Resources Board Staff Report: Proposed Amendments to 

the Diesel Particulate Control Measure for On-Road Heavy Duty Residential and 

Commercial Solid Waste Collection Vehicles: Fleet Rules for the South Coast Air 

Quality Management District. July 29, 2005. 

(Clean Car Maps, 2005) Clean Car Maps, June, 2005 www.cleancarmaps.com 

(Clean Cities, 2005) Clean Cities, The Alternative Fuel Price Report. March 28, 2005 

(Diesel, 2002) Diesel Progress, North American Edition, 23rd Annual Engine Yearbook. 

“Emission Standards Reference Guide, for New Heavy-Duty and Off-Road Diesel 

Engines” June 2002. 

(EPA, 2002) U.S. Environmental Protection Agency. Clean Alternative Fuels: Liquefied 

Natural Gas. (EPA420-F-00-038) March 2002 

(EPA, 2002a) U.S. Environmental Protection Agency. Clean Alternative Fuels: 

Compressed Natural Gas. (EPA420-F-00-033) March 2002 

(EPA, 2002b) U.S. Environmental Protection Agency. Clean Alternative Fuels: 

Propane. (EPA420-F-00-039) March 2002 

(Raley's, 2000) U.S. Department of Energy, Raley's LNG Truck Fleet, Final Results, 

Alternative Fuel Truck Evaluation Project, March 2000 
F - 10 

(POLB, 2005) Port of Long Beach – Alternative fuel web page. 

http://www.polb.com/environment/air_quality/alternative_fuels.asp

(Soy Power, 2005) Soy Power, 2005. www.soypower.net/energyequivalents.asp 

(Starcrest, 2004a) Starcrest Consulting Group, LLC 2002 Baseline Emissions 

Inventory, Cargo Handling Equipment, Rail Locomotives, and Heavy-Duty Vehicles. p. 

28 March 2004 

(Starcrest, 2004b) Starcrest Consulting Group, LLC. The Port of Los Angeles, Final 

Draft, Port-Wide Baseline Air Emission Inventory June 2004,