STAFF REPORT: INITIAL STATEMENT OF REASONS FOR 

PROPOSED RULEMAKING

REGULATION FOR MOBILE CARGO HANDLING EQUIPMENT AT

PORTS AND INTERMODAL RAIL YARDS

Stationary Source Division 

Emissions Assessment Branch 

October 2005
i 

State of California 

AIR RESOURCES BOARD 

STAFF REPORT: INITIAL STATEMENT OF REASONS 

FOR PROPOSED RULEMAKING 

Public Hearing to Consider 

ADOPTION OF THE PROPOSED REGULATION FOR MOBILE 

CARGO HANDLING EQUIPMENT AT PORTS AND INTERMODAL RAIL YARDS 

To be considered by the Air Resources Board on December 8-9, 2005, at: 

California Environmental Protection Agency 

Headquarters Building 

1001 “I” Street 

Byron Sher Auditorium 

Sacramento, California 

Stationary Source Division: 

Robert D. Fletcher, Chief 

Daniel E. Donohoue, Chief, 

Emissions Assessment Branch 

Peggy Taricco, Manager, 

Technical Analysis Section 

This report has been prepared by the staff of the Air Resources Board. Publication 

does not signify that the contents reflect the views and policies of the Air Resources 

Board, nor does mention of trade names or commercial products constitute 

endorsement or recommendation for use. 
ii 

State of California 

AIR RESOURCES BOARD 

PROPOSED REGULATION FOR MOBILE CARGO HANDLING EQUIPMENT 

AT PORTS AND INTERMODAL RAIL YARDS 

Contributing Authors

Lisa Williams 

Pingkuan Di 

John Lee 

Kirk Rosenkranz 

Bonnie Soriano 

Todd Sterling 

Legal Counsel

Michael Terris, Office of Legal Affairs 

Supporting Divisions

PTSD, RD, MSCD 

Acknowledgements

This report was prepared with the assistance and support from the other divisions and 

offices of the Air Resources Board. In addition, we would like to acknowledge the 

assistance and cooperation that we have received from many individuals and 

organizations. 
iii 

TABLE OF CONTENTS

Contents Page

Executive Summary .................................................................................................. ES-1 

 I. Introduction......................................................................................................... I-1 

 A. Overview.................................................................................................. I-1 

B. Purpose ................................................................................................... I-1 

C. Regulatory Authority ................................................................................ I-2 

D. Need for Control of Diesel Particulate Matter........................................... I-3 

E. Physical and Chemical Characteristics of Diesel PM............................... I-3 

F. Health Impacts of Exposure to Diesel PM, Ambient Particulate Matter, 

 and Ozone ............................................................................................... I-4 

G. Health and Environmental Benefits from the Proposed Regulation ......... I-6 

H. Public Outreach and Environmental Justice ............................................ I-8 

 

 II. Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards ........... II-1 

 A. Definitions and Uses............................................................................... II-1 

B. Ports and Intermodal Rail Yards ............................................................. II-7 

C. Regulatory Status ................................................................................... II-8 

 

III. Emissions, Potential Exposures, and Risk ....................................................... III-1 

A. Estimated Emissions from Cargo Handling Equipment ......................... III-1 

B. Potential Exposures and Risk from Diesel PM Emissions from 

 Cargo Handling Equipment Engines...................................................... III-5 

C. Non-Cancer PM Health Effects.............................................................. III-9 

 IV. The Proposed Regulation and Alternatives ......................................................IV-1 

A. Summary of the Proposed Regulation ...................................................IV-1 

B. Discussion of the Proposed Regulation .................................................IV-3 

C. Alternatives Considered.......................................................................IV-18

 

 V. Technological Feasibility of the Proposed Regulation .......................................V-1 

A. New Engine Standards ...........................................................................V-1 

B. Diesel Exhaust Aftertreatment Emission Controls ..................................V-4 

C. Cleaner Diesel Fuels, Alternative Diesel Fuels, and Alternative Fuels ...V-7 

D. Verification of Diesel Emission Control Devices .....................................V-9 

 
iv 

TABLE OF CONTENTS (cont.) 

Contents Page

VI. Environmental Impacts .....................................................................................VI-1 

A. Legal Requirements...............................................................................VI-1 

B. Effects on Air Quality .............................................................................VI-2 

C. Health Benefits Analysis ........................................................................VI-4 

D. Reasonably Foreseeable Environmental Impacts as a Result of 

 Potential Compliance Methods ..............................................................VI-7 

E. Reasonably Foreseeable Mitigation Measures ....................................VI-11 

F. Reasonably Foreseeable Alternative Means of Compliance with the 

 Proposed Regulation ...........................................................................VI-11 

VII. Economic Impacts ...........................................................................................VII-1 

A. Summary of the Economic Impacts ......................................................VII-1 

B. Legal Requirements..............................................................................VII-2 

C. Methodology for Estimating Costs Associated with Implementation .....VII-3 

D. Estimated Costs to Businesses ..........................................................VII-12 

E. Potential Costs to Local, State, and Federal Agencies .......................VII-17 

F. Cost-Effectiveness..............................................................................VII-17 

G. Analysis of Alternatives.......................................................................VII-23 

 

APPENDICES 

Appendix A: Proposed Regulation for Mobile Cargo Handling Equipment at Ports and 

Intermodal Rail Yards 

Appendix B: Emissions Inventory Methodology 

Appendix C: Ports of Los Angeles and Long Beach Health Risk Assessment 

Appendix D: Cost Analysis - Basis for Calculations 

Appendix E: Cargo Handling Equipment Yard Truck Off-Road Emissions Testing 

Appendix F: Evaluation of the Use of Alternative Fuels in Cargo Handling Equipment 

Appendix G: Verified Diesel Emission Control Strategies for Off-Road Applications 

Appendix H: Demonstration Program for High-Efficiency Emission Controls for 

Rubber-Tired Gantry Cranes, Top Picks, and Side Picks 

Appendix I: NOx to PM Conversion Factor Methodology

Appendix J: Data Inputs for Health Impacts Analysis

Appendix K: List of Acronyms and Abbreviations 
v 

TABLE OF CONTENTS (cont.) 

TABLES AND FIGURES 

Contents Page

Tables 

Table ES-1: Estimated Statewide 2004 Cargo Handling Equipment 

 Population and Associated Emissions ................................................. ES-4 

Table I-1: State and National PM Standards............................................................ I-7 

Table I-2: State and National Ozone Standards ...................................................... I-7

Table I-3: Workshop/Workgroup and Public Outreach Meetings ............................. I-9 

Table II-1: Average New Equipment Costs.............................................................. II-6 

Table II-2: Off-Road Compression-Ignition (Diesel) Engine Standards.................... II-9 

Table II-3: 2004 and Subsequent On-Road Heavy-Duty Diesel Engine 

 Standards ............................................................................................. II-10 

Table III-1: Estimated Statewide 2004 Cargo Handling Equipment Emissions........ III-2 

Table III-2: Estimated 2004 Cargo Handling Equipment Emissions by 

 District.................................................................................................... III-3 

Table III-3: Cargo Handling Equipment Engines Projected Year 2010 

 and 2020 Emission Estimates................................................................ III-4 

Table III-4: Summary of Area Impacted and Population Affected by Risk Levels 

 from Cargo Handling Equipment............................................................ III-8 

Table IV-1: Compliance Schedule for In-Use Yard Truck Fleets of 

 Three or Less.........................................................................................IV-8 

Table IV-2: Compliance Schedule for In-Use Yard Truck Fleets of 

 Four or More..........................................................................................IV-9 

Table IV-3: Compliance Schedule for In-Use Non-Yard Truck Mobile 

 Cargo Handling Equipment..................................................................IV-14 

Table V-1: Exhaust Emission Standards for 2007 and Later Model Year 

 On-Road Heavy-Duty Diesel Engines/Vehicles ......................................V-3 

Table V-2: Verification Classifications for Diesel Emission Control Strategies .......V-10 

Table VI-1: Projected Annual Emissions for Cargo Handling Equipment Used in 

 Ports and Intermodal Rail Yard Applications with Implementation of 

 the Proposed Regulation .......................................................................VI-2 

Table VI-2: Emission Benefits from Implementation of the Proposed Cargo 

 Handling Equipment Regulation ............................................................VI-3 

Table VII-1: Capital Costs Assumptions for VDECS.................................................VII-4

Table VII-2: Estimated Value of New and Used Equipment .....................................VII-5 

Table VII-3: Compliance Assumptions for New Equipment......................................VII-7 

Table VII-4: Compliance Assumptions for In-Use Equipment...................................VII-8 

Table VII-5: Population of Yard Trucks Having Compliance Costs Associated with 

 the Proposed Regulation ......................................................................VII-9 
vi 

TABLE OF CONTENTS (cont.) 

Contents Page

Tables (cont.) 

Table VII-6: Population of Non-Yard Truck Equipment Having Compliance 

 Costs Associated with the Proposed Regulation ................................VII-10 

Table VII-7: Estimated Statewide Annual Costs for Businesses ............................VII-11 

Table VII-8: Estimated Statewide Average Costs per Equipment Types................VII-13 

Table VII-9: Estimated Costs for Typical Businesses.............................................VII-14

Table VII-10: Representative Affected Businesses ..................................................VII-18 

Table VII-11: Estimated Statewide Diesel PM Annual Emission Reductions ...........VII-18 

Table VII-12: Estimated Statewide Cargo Handling Equipment NOx Annual 

 Emission Reductions ..........................................................................VII-19 

Table VII-13: Summary of Annual Diesel PM Cost-Effectiveness for the Cargo 

 Handling Equipment Regulation .........................................................VII-21 

Table VII-14: Summary of Average Cost-Effectiveness for the Period 2007-2020...VII-22 

Table VII-15: Diesel PM Cost-Effectiveness of the Proposal and Other 

 Regulations/Measures ........................................................................VII-23 

Figures 

Figure ES-1: Projected Diesel PM Emissions with and without the Regulation ........ ES-7 

Figure ES-2: Projected NOx Emissions with and without the Regulation.................. ES-7 

Figure II-1: Engine Manufacturers and Equipment Types......................................... II-5 

Figure II-2: 2004 Statewide Population Distribution of Cargo Handling 

 Equipment at Ports and Intermodal Rail Yards....................................... II-6 

Figure II-3: California’s Ports..................................................................................... II-7 

Figure II-4: California’s Intermodal Rail Yards........................................................... II-8 

Figure III-1: 2004 NOx and Diesel PM Emission Distributions at California 

 Ports and Intermodal Rail Yards ............................................................ III-2 

Figure III-2: Baseline vs. Voluntary Programs Diesel PM Cargo Handling 

 Equipment Emissions ............................................................................ III-5 

Figure III-3: Estimated Diesel PM Cancer Risk from Cargo Handling Equipment 

 Activity at the POLA and POLB ............................................................. III-9 

Figure IV-1: Diesel PM Emission Rates for Yard Trucks with Off-Road and 

 On-Road Engines with and without VDECS ..........................................IV-6 

Figure IV-2: NOx Emission Rates for Yard Trucks with Off-Road and 

 On-Road Engines ..................................................................................IV-7

Figure IV-3: Basic Container Handling Equipment Compliance Options .................IV-11 

Figure IV-4: Bulk Cargo Handling Equipment Compliance Options.........................IV-12 

Figure IV-5: RTG Crane Compliance Options .........................................................IV-13 
vii 

TABLE OF CONTENTS (cont.) 

Contents Page

Figures (cont.) 

Figure VI-1: Projected Diesel PM Emissions with and without the Regulation ..........VI-3 

Figure VI-2: Projected NOx Emissions with and without the Regulation....................VI-4 

Figure VI-3: Residential Areas Impacted by the Proposed Regulation for Baseline 

 Year (2002) and Predicted 2010 and 2020 at the POLA and POLB......VI-5 

Figure VI-4: Population Affected by the Proposed Regulation for Baseline Year 

 (2002) and Predicted 2010 and 2020 at the POLA and POLB...............VI-6 
ES - 1 

EXECUTIVE SUMMARY 

This executive summary presents the Air Resources Board (ARB or Board) staff’s 

Proposed Regulation for Mobile Cargo Handling Equipment at Ports and Intermodal Rail 

Yards. The proposed regulation is designed to reduce diesel particulate matter (PM) 

and oxides of nitrogen (NOx) emissions from mobile cargo handling equipment that 

operate at ports and intermodal rail yards in California. 

Because of its geographical location and major ports and railways, California is a global 

gateway for goods movement. Some of the largest ports in the world are located in 

California, and with increases in trade and general goods movement, both the ports and 

intermodal rail yards stand to experience major growth over the next two decades. 

Cargo handling equipment at ports and intermodal rail yards is a significant source of 

emissions of diesel PM, as well as NOx, in California. In addition, these facilities are 

often located in or near densely populated areas and neighborhoods, exposing 

residents to unhealthy levels of pollutants. 

In 1998, following the ARB’s identification of diesel PM as a toxic air contaminant (TAC), 

California embarked on an ambitious strategy to reduce emissions from diesel-fueled 

engines. The Risk Reduction Plan to Reduce Particulate Matter Emissions from DieselFueled Engines and Vehicles (Diesel Risk Reduction Plan), adopted by the Board in 

October 2000, outlined steps to reduce diesel emissions and associated potential 

cancer risks by 75 percent in 2010 and by 85 percent by 2020. Because of the potency 

and the large amount of emissions to California’s air, diesel PM is the primary 

contributor to adverse health impacts, including an estimated 70 percent of all cancer 

risks, from TACs. Diesel exhaust is a major source of fine particulate pollution as well, 

and numerous studies have linked elevated particle levels in the air to increased 

hospital admissions, emergency room visit, asthma attacks and premature deaths. 

(ARB, 2000) 

As part of the effort to reduce diesel PM, ARB staff is proposing this regulation, which 

would result in diesel PM and NOx emission reductions beginning in 2007. Additional 

reductions are phased in over the next eight years. Staff estimates that in 2015, diesel 

PM emissions from cargo handling equipment at ports and intermodal rail yards would 

be reduced by approximately 66 percent and NOx emissions by approximately 47 

percent relative to the projected baseline, which includes the benefits of the new engine 

standards adopted by the U.S. EPA and ARB. These reductions are significant 

considering the growth in trade that is expected to occur over the same timeframe. 

In recent years, the Board has adopted many regulations to reduce diesel PM 

emissions from other sources. These include stationary engines, portable equipment, 

transport refrigeration units, and solid waste collection vehicles. Additional regulations 

are being developed to address oceangoing ship auxiliary engines, commercial harbor 

craft, and general off-road equipment. 
ES - 2 

Presented below is an overview which briefly discusses the emissions from new and 

existing mobile cargo handling equipment, the proposed regulation, and the potential 

impacts from implementation as well as what our plans are for future activities. For 

simplicity, the discussion is presented in question-and-answer format using commonly 

asked questions about the regulation. It should be noted that this summary provides 

only brief discussion on these topics. The reader is directed to subsequent chapters in 

the main body of the report for more detailed information. 

1. What is ARB staff proposing? 

ARB staff is proposing a regulation that would reduce emissions of diesel PM and NOx 

from new and existing (in-use) mobile cargo handling equipment at ports and intermodal 

rail yards. Unlike mobile diesel-fueled compression ignition (CI) engines used in onroad applications, diesel-fueled engines used in off-road mobile cargo handling 

applications are currently required to meet much less stringent engine certification 

standards. The Federal Clean Air Act, Section 209(e), allows California to request and 

receive authority from the U.S. EPA to establish requirements for off-road mobile 

engines. (EPA, 1990) 

The proposed regulation would establish requirements that affect the sellers, renters, 

lessors, owners, and operators of mobile cargo handling equipment that are used at 

California’s ports or intermodal rail yards. Staff’s approach in developing the 

performance standards was to establish requirements that are based on the application 

of the best available control technology (BACT). 

For newly purchased, leased, or rented equipment, certified on-road engines would be 

required if available for the specific equipment type and application. Otherwise, the 

highest level certified off-road engine would be required, along with installation of the 

highest level verified diesel emission control strategy (VDECS) within one year of 

purchase, lease, or rent, or within six months of becoming available if after a year. 

The proposed regulation would require in-use yard trucks to meet BACT performance 

standards primarily through accelerated turnover of older yard trucks to those equipped 

with cleaner, on-road engines (2007 model year or later). Owners or operators who 

have installed VDECS prior to the end of 2006, or who are already using certified onroad engines, are given additional time to comply. In addition, compliance is phased in 

for owners or operators who have more than three yard trucks in their fleet. 

Non-yard truck equipment would also be required to meet BACT, which, for them, is a 

menu of options that includes replacement to cleaner on-road or off-road engines and/or 

the use of retrofits. For owners or operators that elect to use retrofits, a second 

compliance step, which would require replacement to Tier 4 off-road engines or 

installation of a Level 3 (85 percent diesel PM reduction) VDECS, may be required, 

depending on the equipment category and level of VDECS applied. 
ES - 3 

Owners and operators would also be required to meet recordkeeping and reporting 

requirements. A discussion of the proposed regulation and its requirements are in 

Chapter IV of this Staff Report. 

2. What is mobile cargo handling equipment? 

Mobile cargo handling equipment is any motorized vehicle used to handle cargo, or in 

some cases, may be used for other activities, such as maintenance. The type of 

equipment used usually depends on the type of cargo handled or the type of activity. 

Equipment that handles cargo containers includes, but is not limited to, yard trucks, top 

handlers, side handlers, reach stackers, forklifts, and rubber-tired gantry cranes. 

Equipment that is used to handle bulk cargo includes, but is not limited to, dozers, 

excavators, loaders, mobile cranes, railcar movers, and sweepers. While forklifts can 

be used in either container or bulk cargo operations, for the purposes of this regulation, 

they are considered to be container handling equipment. Forklifts, aerial lifts, mobile 

cranes, and sweepers may also be used in maintenance operations at ports and 

intermodal rail yards. There are approximately 3,700 cargo handling equipment 

vehicles at California’s ports and intermodal rail yards. 

3. Where is mobile cargo handling equipment used? 

Mobile cargo handling equipment is used throughout California in almost all industries 

involved with the movement of goods. The most common use of cargo handling 

equipment occurs at intermodal facilities, including ports and rail yards, and distribution 

centers and warehouses. This proposed regulation will address mobile cargo handling 

equipment only at ports and intermodal rail yards. The ARB is in the process of 

developing another regulation to address other diesel-fueled off-road equipment, 

including those used at other intermodal facilities. More information on this effort is 

available at http://www.arb.ca.gov/msprog/ordiesel/ordiesel.htm. 

There are several ports in California that would be affected by the proposal, including 

Antioch, Benicia, Crockett, Humboldt Bay, Hueneme, Long Beach, Los Angeles, 

Oakland, Pittsburg, Port Chicago, Redwood City, Richmond, Sacramento, San Diego, 

San Francisco, and Stockton. Most of the ports are controlled by port authorities, but 

several are independently operated. Two major railroad companies, BNSF Railway and 

Union Pacific Railroad, operate several intermodal rail yards in the state, located in 

cities such as Barstow, City of Industry, Commerce, Fresno, Lathrop, Long Beach, Los 

Angeles, Oakland, Richmond, San Bernardino, and Stockton. It is expected that, as the 

growth in trade continues, additional intermodal rail yards may be developed. 

4. What are the emissions, exposures, and health risks from mobile cargo 

handling equipment? 

ARB staff estimates mobile cargo handling equipment at ports and intermodal rail yards 

emit approximately 0.65 tons per day (237 tons per year) of diesel PM and 19.04 tons 

per day (6,950 tons per year) of NOx in 2004. Based on an average statewide NOx to 
ES - 4 

PM conversion factor, we estimate the secondary formation of PM10 nitrate from NOx 

emissions from mobile cargo handling equipment engines to be about 6 to 10 tons per 

day. Table ES-1 shows the distribution of cargo handling equipment by equipment type 

and the estimated emissions in 2004. 

Table ES-1: Estimated Statewide 2004 Cargo Handling Equipment Population and 

Associated Emissions 

2004 Pollutant Emissions (tons per day) 

Equipment Types 

Numbers of 

Equipment NOx HC CO PM 

Cranes 321 1.93 0.15 0.58 0.07 

Excavators 28 0.24 0.02 0.06 0.01 

Forklifts 464 0.54 0.06 0.20 0.03 

Container Handling Equipment 487 3.25 0.22 0.84 0.11 

Other Equipment 40 0.08 0.01 0.02 0.00 

Sweepers/Scrubbers 28 0.04 0.00 0.02 0.00 

Tractors/Loaders/Backhoes 93 0.18 0.02 0.05 0.01 

Yard Trucks 2277 12.78 1.14 8.98 0.42 

Totals 3738 19.04 1.61 10.76 0.65 

Yard trucks account for the majority of the diesel PM and NOx emissions, about 

66 percent and 67 percent, respectively, from cargo handling equipment at ports and 

intermodal rail yards. Because ambient air monitoring techniques for diesel PM are still 

under development, it is difficult to measure the actual exposures to persons from the 

emissions of cargo handling equipment. However, because the equipment is distributed 

throughout the ports and intermodal rail yards in California, and because most of the 

facilities are located in urban centers near residential communities, we believe that 

several million Californians are impacted by diesel PM emissions from the operation of 

cargo handling equipment. 

Exposure to these emissions results in increased cancer risk and other serious noncancer health impacts, including premature death, irritation to the eyes and lungs, 

allergic reactions in the lungs, asthma exacerbation, blood toxicity, immune system 

dysfunction, and developmental disorders. Estimates of the level of cancer risk can be 

made using emission estimates and modeling techniques to predict ambient 

concentrations of diesel PM. 

A health risk assessment was conducted for cargo handling equipment operated at the 

Ports of Long Beach and Los Angeles, which showed significant near-source risks. For 

example, nearby residents living within a 4,100-acre perimeter of the ports are 

estimated to have a potential cancer risk of over 100 in a million due to emissions from 

cargo handling equipment. Nearly 75 percent of the two million people living in the area 

around the ports have an estimated predicted risk of greater than 10 in a million. These 

risk values assume exposure duration of 70 years for a nearby individual. 
ES - 5 

ARB staff also estimated the potential non-cancer impacts associated with exposure to 

diesel PM from cargo handling equipment. The non-cancer health effects evaluated 

include premature death, asthma attacks, work loss days, and minor restricted activity 

days. Based on the analysis, staff estimates that the average number of cases 

statewide per year that would be expected from exposure to the 2004 cargo handling 

equipment diesel PM emission levels are as follows:

• 9 premature deaths (4 to 13, 95% confidence interval (CI)) 

• 219 asthma attacks (53 to 383, 95% CI) 

• 1,907 work loss days (1,614 to 2,200, 95% CI) 

• 10,127 minor restricted activity days (8,254 to 12,000, 95% CI) 

5. Are the requirements proposed for cargo handling equipment 

technologically feasible? 

Yes. Based upon extensive analysis and discussions with numerous stakeholders, staff 

has determined that the proposed requirements and performance standards are 

technologically feasible. 

The proposal requires owners and operators of in-use yard trucks to accelerate the 

turnover to cleaner on-road or off-road engines. Yard trucks with on-road engines 

meeting the 2007 certified standards will be commercially available throughout the 

country beginning in 2007 when the proposed regulation takes effect. As the on-road 

engine standards become more stringent in 2010, yard truck manufacturers will 

continue to offer their equipment with certified on-road engines that meet the new 

standards. (ARB, 2005c) The option to select a comparable off-road engine is 

expected to be available beginning in 2011. 

The in-use performance standards for non-yard truck equipment can be met through the 

application of retrofits, or verified diesel emission control strategies (VDECS), and/or 

replacement to cleaner on-road or off-road engines. The ARB has currently verified 

several VDECS that range from Level 1 to Level 3 for applicable cargo handling 

equipment, and more are expected in the future. Many of these technologies have 

been successfully used in mobile cargo handling equipment, particularly at California 

ports, and include diesel oxidation catalysts (DOCs), emulsified diesel fuel, and diesel 

particulate filters (DPFs). In addition, flow-through filters, sometimes referred to as 

enhanced DOCs, are relatively new to the market but also show promise in reducing 

diesel PM from these engines. 

While several VDECS are currently available for non-yard truck cargo handling 

equipment, the verification extends only to select model years and engine families. As 

a result, the proposed regulation has several provisions to provide flexibility and to 

encourage the development of other emission control strategies. The proposal would 

allow owners and operators to apply for a compliance extension for the use of 

experimental diesel emission control technologies, which in turn, is expected to result in 

additional verifications. The proposal also includes an alternative compliance plan 
ES - 6 

(ACP) option for owners or operators of non-yard truck equipment. In order to receive 

approval for the ACP, owners or operators would be required to demonstrate that 

equivalent emission reductions can be achieved through the use of alternative 

strategies, which can include early engine or equipment replacement, alternative fuels 

or fuel additives, exhaust treatment controls, or equipment engine modifications. 

As part of the implementation efforts for the proposed regulation, staff plan to create a 

technology workgroup, whose goal will be to monitor the available control strategies, 

address concerns regarding the use of the technologies in non-yard truck cargo 

handling equipment, and encourage manufacturers to apply for ARB verification. 

6. What businesses will be affected by the proposed regulation? 

The proposed regulation will affect any businesses operating mobile cargo handling 

equipment at ports and intermodal rail yards in California. Examples of businesses that 

potentially will be affected include terminal operators and owners at ports, railroad 

companies that operate intermodal rail yards, and renting or leasing companies that 

provide cargo handling equipment to these facilities. In general, public agencies will not 

be affected by this regulation. However, military installations that have cargo handling 

activities at military ports may be affected. 

7. How will the regulation be enforced? 

The proposal requires that owners or operators of cargo handling equipment at ports 

and intermodal rail yards provide access to the equipment to ARB employees or agents 

for the purposes of inspection. This includes access to records necessary to establish 

compliance with the requirements of the proposal. 

8. What are the environmental impacts of the proposed regulation? 

The proposed regulation will significantly reduce diesel PM emissions and the resulting 

exposures from mobile cargo handling equipment at ports and intermodal rail yards in 

California. ARB staff estimates that, with implementation of the regulation, diesel PM 

emissions will be reduced by approximately 40 percent or 75 tons per year in 2010 and 

66 percent or 86 tons per year in 2015 relative to the projected 2010 and 2015 

emissions, which includes an annual growth rate of six percent and estimated 

reductions from normal equipment turnover and voluntary programs. Figure ES-1 

shows the projected diesel PM emissions with and without the regulation. 
ES - 7 

Figure ES-1: Projected Diesel PM Emissions with and without the Regulation 

Note: Baseline includes estimated reductions from voluntary programs and the benefits from the new 

engine standards adopted by the U.S. EPA and ARB. 

California’s air quality will also benefit from reduced NOx emissions. As a result of the 

regulation, ARB staff estimates that NOx emissions will be reduced by 24 percent or 

1,425 tons per year in 2010 and 47 percent or 1,991 tons per year in 2015, relative to 

the projected 2010 and 2015 emissions, which includes a growth rate of six percent 

each year and estimated reductions from voluntary programs. Figure ES-2 shows the 

projected NOx emissions with and without the regulation. 

Figure ES-2: Projected NOx Emissions with and without the Regulation 

Note: Baseline includes estimated reductions from voluntary programs and benefits from new engine 

standards adopted by the U.S. EPA and ARB. 

We anticipate significant health benefits due to reduced mortality, incidences of cancer, 

PM related cardiovascular effects, chronic bronchitis, asthma, and hospital admissions 

for pneumonia and asthma-related conditions. These directly emitted diesel PM 

reductions are expected to reduce the number of premature deaths and other 

0

50

100

150

200

250

300

20042007201020152020

Year

TPY

PM Baseline

PM Reg Influence

0

1000

2000

3000

4000

5000

6000

7000

8000

20042007201020152020

Year

TPY

NOx Baseline 

NOx Reg Influence
ES - 8 

noncancer health effects from air pollution in California. Staff estimates that the 

implementation of this regulation will avoid between 2007 and 2020 approximately: 

• 32 premature deaths (16 to 48, 95% CI); 

• 820 asthma attacks (200 to 1,400, 95% CI); 

• 7,100 work loss days (6,020 to 8,200, 95% CI); and

• 38,000 minor restricted activity days (31,000 to 45,000, 95% CI). 

 

With respect to potential cancer risk, ARB staff believes there will be significant 

reductions in exposures and potential cancer risks to residents that live near ports and 

intermodal rail yards in California. For example, based on an analysis of the predicted 

2010 and 2020 ambient diesel PM levels near the POLA and POLB, we estimate that in 

2010 there will be a 56 percent reduction in the population-weighted average risk 

relative to the risk levels in 2002 from cargo handling equipment emissions and a 

82 percent reduction in 2020. 

9. What are the economic impacts of the proposed regulation? 

ARB staff estimates the cost for compliance with the regulation to be approximately 

71 million dollars for the total capital and recurring costs. This corresponds to about 

5.1 million dollars annually on average for the years 2007 through 2020. This cost, 

which is based on 2004 dollars, represents the capital cost of equipment, maintenance 

and replacement, and reporting costs from 2007 through to 2020. 

The cost for a business to comply with this regulation will vary depending on the number 

and type of cargo handling equipment and whether the equipment is equipped with a 

verified diesel exhaust control system (VDECS) and/or later replaced with a new Tier 4 

engine in 2015. For example, the costs for a typical crane engine (rated at 210 hp 

operated 1370 hours per year) with a diesel particulate filter (DPF) is about $17,500 for 

equipment and installation. The estimated annual ongoing costs are based on a 

reporting cost of about $500 per terminal with the cost spread over many pieces of 

equipment. To determine the cost a typical business may incur, we used the ARB 

Survey data on the average number and type of equipment operated by a port container 

terminal, a port bulk handling terminal, and an intermodal rail yard and applied the 

annual average costs for the various equipment types. Based on our analysis, we 

estimate that the total 2007 to 2020 costs to a typical business will be in the range of 

$343,000 to $1,373,000. 

Staff does not have access to financial records for most of the companies that 

responded to the survey. However, approximately 10 percent of the respondents 

identified themselves as small businesses (annual gross receipts of $1,500,000 or less 

for transportation and warehousing per California Government Code 

Section 11342.610). 

Cost-effectiveness is expressed in terms of control costs (dollars) per unit of air 

emissions reduced (pounds). The cost-effectiveness for the proposed regulation is 
ES - 9 

determined by dividing the total capital costs plus the annual operation and 

maintenance and reporting costs by the total pounds of diesel PM reduced during the 

years 2007 to 2020. All costs are in 2004 equivalent expenditure dollars. With a total 

cost of 71 million dollars reducing approximately 1.73 million pounds of diesel PM, staff 

estimates the overall cost-effectiveness of the proposed regulation to be about 

41 dollars per pound of diesel PM reduced, considering only the benefits of reducing 

diesel PM. Because the proposed regulation will also reduce NOx emissions, we could 

allocate half of the costs of compliance against these benefits, resulting in costeffectiveness values of approximately 21 dollars per pound of diesel PM and 1 dollar 

per pound of NOx reduced. 

10. Will Carl Moyer Program funds be available for cargo handling equipment if 

the regulation is adopted? 

Yes. Although the bulk of the emission reductions from cargo handling equipment 

would be obtained through the regulatory requirements, Carl Moyer Program funds may 

be available for owners or operators that can comply early. The incremental cost of 

new purchase, repower, and retrofit projects would be eligible for funding. In order to 

qualify for Carl Moyer Program funding, the project would have to start at least three 

years before the required implementation date in the regulation, all of the owner or 

operator’s cargo handling equipment for the specific model year or model year group 

would have to be brought into early compliance at the same time, and the project would 

have to meet a cost-effectiveness cap. The percent of the owner or operator’s fleet 

eligible for Carl Moyer Program funding would be based on how early the fleet is 

brought into compliance. 

11. How does the proposed regulation fulfill the goals of the Diesel Risk 

Reduction Plan and the State Implementation Plan as they pertain to these 

engines? 

The proposed regulation is consistent with the goals of the Diesel Risk Reduction Plan. 

The requirements and standards in the regulation are based on the application of BACT 

for diesel PM. ARB staff estimates that with implementation of the regulation, diesel PM 

emissions will be reduced by approximately 53 percent in 2010 and 81 percent in 2020 

relative to the 2004 baseline, with a cumulative reduction of 1.73 million pounds by 

2020. 

The proposed regulation is also consistent with the goals of the State Implementation 

Plan (SIP) as it relates to the in-use fleet of off-road heavy-duty compression ignition 

engines and equipment. The requirements and standards in the regulation utilize the 

strategies suggested in the SIP by reducing emissions through the application of 

verified diesel emission control strategies and replacing older, dirtier engines with new, 

lower-emission models. In addition to the reductions in diesel PM stated above, NOx 

emissions will also be reduced by approximately 35 percent in 2010 and 77 percent in 

2020 relative to the 2004 baseline, with a cumulative reduction of 37.3 million pounds by 

2020. 
ES - 10 

12. How does the proposed regulation relate to ARB’s goals for Environmental 

Justice? 

Environmental Justice is defined as the fair treatment of people of all races, cultures, 

and incomes with respect to the development, adoption, implementation, and 

enforcement of environmental laws, regulations, and policies. ARB’s Environmental 

Justice Policies are intended to promote the fair treatment of all Californians and cover 

the full spectrum of the ARB's activities. 

The proposed regulation is consistent with the environmental justice policy to reduce 

health risks from toxic air contaminants in all communities, including those with lowincome and minority populations, regardless of location. The regulation will reduce 

diesel PM emissions from mobile cargo handling equipment at ports and intermodal rail 

yards by requiring the use of the best available control technologies. The proposed 

regulation will provide air quality benefits for all Californians, particularly those residing 

in communities located near these facilities. 

13. What future activities are planned? 

After Board consideration and approval of the proposed regulation, ARB staff will work 

on a number of projects related to implementation, the collection and processing of 

engine-related data, and the improvement of the cargo handling equipment category of 

the off-road engine emission inventory. Specifically, resources will be devoted to the 

following: 

• Seeking a Title I section 209(e) waiver from U.S. EPA 

Upon Office of Administrative Law approval of the proposed regulation, staff 

will submit a Title I section 209(e) waiver request to the U.S. EPA. Staff 

expect the U.S. EPA will act expeditiously to approve the waiver prior to the 

implementation dates of the regulation. 

• Implementing the requirements of the regulation 

ARB staff will develop implementation guidance as appropriate and will work 

with industry groups and affected businesses to ensure owners and operators 

are aware of the regulatory requirements and compliance options. Staff will 

prepare fact sheets, a question and answer document regarding 

implementation, and work to provide electronic forms. 

• Technology review 

A technology working group will be formed to monitor the feasibility of retrofit 

emission controls, encourage manufacturers to apply for ARB verification, 

and address concerns regarding the use of VDECS in non-yard truck cargo 
ES - 11 

handling equipment. In addition, the workgroup will share information on 

successful applications of experimental emission control strategies. 

 

• Monitoring implementation 

ARB staff will monitor implementation of the proposed regulation. This will 

include monitoring advancements in emission control technologies and 

evaluating BACT. In the event implementation reveals amendments to the 

regulation are warranted or that BACT has changed, ARB staff will propose 

amendments for the Board’s consideration. 

• Updating inventory with the reporting data 

A key requirement of the regulation is the initial reporting of information on the 

number of engines and their operating characteristics and compliance 

reporting. This information will be used to update the ARB’s emission 

inventory for off-road equipment. 

14. What is staff’s recommendation? 

We recommend the Board approve the proposed regulation presented in this report 

(Appendix A). The regulation will reduce diesel PM and NOx emissions from mobile 

cargo handling equipment at ports and intermodal rail yards by requiring the use of the 

best available control technologies, including accelerated turnover and/or retrofits. The 

proposed regulation will provide air quality benefits for all Californians, particularly those 

living in communities near ports and intermodal rail yards. ARB staff believes the 

proposed regulation is technologically feasible and necessary to carry out the Board’s 

responsibilities under State law. 
ES - 12 

REFERENCES: 

(ARB, 2000) California Air Resources Board. Risk Reduction Plan to Reduce 

Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles; October 2000. 

(EPA, 1990) United States Environmental Protection Agency. Federal Clean Air Act, 

Title II, Part A, Sec. 209(e); 1990. 

(ARB, 2005c) California Air Resources Board. Phone call with Mr. Don Lawrence, 

Ottawa (Kalmar Industries); September 22, 2005. 
I - 1 

I. INTRODUCTION 

A. Overview 

The California Air Resources Board's (ARB or Board) mission is to protect public health, 

welfare, and ecological resources through the effective and efficient reduction of air 

pollutants, while recognizing and considering the effects on the economy of the State. 

ARB’s vision is that all individuals in California, especially children and the elderly, can 

live, work, and play in a healthful environment – free from harmful exposure to air 

pollution. Diesel engine exhaust is a source of unhealthful air pollutants including 

gaseous- and particulate-phase toxic air contaminants (TAC), particulate matter, carbon 

monoxide, hydrocarbons, and oxides of nitrogen. Emissions from diesel-fueled mobile 

cargo handling equipment (cargo handling equipment) are a significant concern in 

communities near ports and intermodal rail yards. ARB staff are proposing a control 

measure to reduce emissions from cargo handling equipment used at ports and 

intermodal rail yards. These emissions contribute to ambient levels of particulate 

matter, result in community exposures to diesel PM, and contribute to oxides of nitrogen 

(NOx) levels and reactive organic compounds (ROG) levels, which are precursors to the 

formation of ozone. 

This Staff Report for the proposed regulation includes: 

• background regulatory information, discussion of the need for control of diesel 

particulate matter, and a summary of public outreach (Chapter I); 

• discussion of cargo handling equipment at ports and intermodal rail yards 

(Chapter II); 

• potential emissions, exposure, and risk from cargo handling equipment (Chapter III); 

• summary and discussion of the proposed regulation, including alternative 

requirements considered (Chapter IV); 

• availability and technological feasibility of potential control measures (Chapter V); 

• environmental impact of the proposed control measure (Chapter VI); 

• economic impacts of the proposed control measure (Chapter VII); and 

• proposed text of the measure and other supplementary information (Appendices). 

B. Purpose 

The proposed regulation is designed to reduce levels of ambient particulate matter, the 

general public's exposure to diesel PM, and ozone precursor emissions from cargo 

handling equipment at ports and intermodal rail yards. The proposed regulation 

establishes best available control technology (BACT) for cargo handling equipment. 

The proposed regulation requires yard trucks that operate at a port or intermodal rail 

yard in California to meet in-use performance standards through accelerated turnover of 

older yard trucks to ones equipped with cleaner, on-road engines. Non-yard truck 

equipment would also be required to meet BACT, which, for them, could include retrofits 

and/or replacement to cleaner on-road or off-road engines. Owners or operators would 

be required to maintain records of their equipment, compliance method, and compliance 
I - 2 

dates, as well as report to the ARB compliance plans and a demonstration of 

compliance. Chapter IV of this Staff Report contains a discussion of the proposed 

regulation. Appendix A contains the full text of the proposed regulation. 

C. Regulatory Authority 

Under federal Clean Air Act (CAA) section 209(e)(2), California may adopt emission 

standards for off-road1

 engines that are not otherwise expressly preempted under 

section 209(e)(1). Section 209(e)(1) provides that no state, including California, or any 

political subdivision thereof may adopt or enforce emission standards or other 

requirements relating to the control of emissions for nonroad engines under 

175 horsepower that are used in farm or construction equipment or used in locomotives 

or locomotive engines. CAA section 209(e)(2) provides California with sole authority 

among the states to adopt emission standards and requirements related to emission 

control for new and in-use nonroad engines that are not specifically preempted under 

section 209(e)(1). Section 209(e)(2) requires that California must obtain authorization 

from the Administrator of the United States Environmental Protection Agency 

(U.S. EPA) prior to the regulation becoming effective. As part of the authorization 

process, ARB must establish that the adopted regulations “will be, in the aggregate, at 

least as protective of public health and welfare as the applicable Federal standards.” 

U.S. EPA is authorized by CAA section 213 to adopt emission standards and other 

regulations for only new non-road engines. In Engine Manufacturers Association v. 

U.S. EPA (D.C. Cir.1996) 88 F.3d 1075, the Court concluded that California is the only 

government body with authority to adopt emission standards and other regulations for 

in-use engines. (Id., at 1089-1091.) 

ARB has been granted both general and specific authority under the Health and Safety 

Code (HSC) to adopt the proposed regulation. HSC sections 39600 (General Powers) 

and 39601 (Standards, Definitions, Rules, and Measures) confer to the ARB, the 

general authority and obligation to adopt rules and measures necessary to execute the 

Board's powers and duties imposed by State law. HSC sections 43013(b) and 43018(a) 

provide broad authority to achieve the maximum feasible and cost effective emission 

reductions from all mobile source categories, including off-road diesel engines and 

equipment. 

With respect to toxic air contaminants (TAC), California's Air Toxics Program, 

established under California law by AB 1807 (Stats. 1983, Ch. 1047) and set forth in 

HSC sections 39650 through 39675, mandates that ARB identify and control air toxics 

emissions in California. The identification phase of the Air Toxics Program requires the 

ARB, with participation of other state agencies, such as the Office of Environmental 

Health Hazard Assessment (OEHHA), to evaluate the health impacts of, and exposure 

to, substances and to identify those substances that pose the greatest health threat as 

TACs. ARB's evaluation is then made available to the public and is formally reviewed 

by the Scientific Review Panel (SRP) established under HSC section 39670. Following 

 

1

 The CAA refers to “nonroad engines” and California has historically referred to these same engines as

“off-road engines.” For purposes of this regulation the two terms are interchangeable. 
I - 3 

the ARB's evaluation and the SRP's review, the Board may formally identify a TAC at a 

public hearing. Following the identification of a substance as a TAC, HSC sections 

39658, 39665, 39666, and 39667 require ARB, with the participation of the air pollution 

control and air quality management districts (districts), and in consultation with affected 

sources and interested parties, to prepare a report on the need and appropriate degree 

of regulation for that substance. The mobile cargo handling equipment subject to this 

regulation are vehicular sources. As such, the proposed regulation would be adopted 

under the authority provided in HSC section 39667. The ARB is responsible for 

implementation and enforcement of the proposed regulation. Districts are not 

authorized to adopt requirements for equipment subject to the proposed regulation. 

D. Need for Control of Diesel Particulate Matter

In 1998, the Board identified diesel PM as a TAC. Diesel PM is by far the most 

important TAC and contributes over 70 percent of the estimated risk from air toxics 

today. In September 2000, the ARB approved the “Risk Reduction Plan to Reduce 

Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles” (Diesel Risk 

Reduction Plan). The goal of the Diesel Risk Reduction Plan is to reduce diesel PM 

emissions and the associated cancer risk by 85 percent in 2020. (ARB, 2000) In 

addition, in 2001, OEHHA identified diesel PM as one of the TACs that may cause 

children or infants to be more susceptible to illness pursuant to the requirements of 

Senate Bill 25 (Stats. 1999, ch. 731). Senate Bill 25 also requires the ARB to adopt 

control measures, as appropriate, to reduce the public’s exposure to these special 

TACs (H&SC section 39669.5). In the following sections, we describe the physical and 

chemical characteristics of diesel PM and discuss the adverse health and environmental 

impacts from the suite of pollutants emitted by diesel-fueled engines. 

E. Physical and Chemical Characteristics of Diesel PM 

Diesel engines emit a complex mixture of inorganic and organic compounds that exist in 

gaseous, liquid, and solid phases. The composition of this mixture will vary depending 

on engine type, engine age and horsepower, operating conditions, fuel, lubricating oil, 

and whether or not an emission control system is present. The primary gas or vapor 

phase components include typical combustion gases and vapors such as carbon 

monoxide (CO), carbon dioxide (CO2), sulfur dioxide (CO2), oxides of nitrogen (NOx), 

reactive organic gases (ROG), water vapor, and excess air (nitrogen and oxygen). 

Many of the diesel particles exist in the atmosphere as a carbon core with a coating of 

organic carbon compounds, or as sulfuric acid and ash, sulfuric acid aerosols, or sulfate 

particles associated with organic carbon. (Beeson, 1998) The organic fraction of the 

diesel particle contains compounds such as aldehydes, alkanes and alkenes, and highmolecular weight PAH and PAH-derivatives. Many of these PAHs and PAH-derivatives, 

especially nitro-PAHs, have been found to be potent mutagens and carcinogens. 

Nitro-PAH compounds can also be formed during transport through the atmosphere by 

reactions of adsorbed PAH with nitric acid and by gas-phase radical-initiated reactions 

in the presence of oxides of nitrogen. Fine particles may also be formed secondarily 
I - 4 

from gaseous precursors such as SO2, NOx, or organic compounds. Fine particles can 

remain in the atmosphere for days to weeks and travel through the atmosphere for 

hundreds to thousands of kilometers, while coarse particles deposit to the earth within 

minutes to hours and within tens of kilometers from the emission source. 

Almost all of the diesel particle mass is in the fine particle range of 10 microns or less in 

diameter (PM10). Approximately 94 percent of the mass of these particles are less than 

2.5 microns (PM2.5) in diameter. Diesel PM can be distinguished from noncombustion 

sources of PM2.5 by the high content of elemental carbon with the adsorbed organic 

compounds and the high number of ultrafine particles (organic carbon and sulfate). 

The soluble organic fraction (SOF) consists of unburned organic compounds in the 

small fraction of the fuel and atomized and evaporated lube oil that escape oxidation. 

These compounds condense into liquid droplets or are adsorbed onto the surfaces of 

the elemental carbon particles. Several components of the SOF have been identified as 

individual TACs. 

F. Health Impacts of Exposure to Diesel PM, Ambient Particulate Matter, and 

Ozone 

The proposed regulation will reduce the public’s exposure to diesel PM as well as 

reduce ambient particulate matter. In addition, the proposed regulation is expected to 

result in reductions in emissions of NOx and ROG, which are precursors to the 

formation of PM2.5 and ozone in the lower atmosphere. The primary health impacts of 

these air pollutants are discussed below. 

 Diesel Particulate Matter

Diesel PM is of specific concern because it poses a lung cancer hazard for humans as 

well as a hazard from noncancer respiratory effects such as pulmonary inflammation. 

(ARB, 1998a) Because of their small size, the particles are readily respirable and can 

effectively reach the lowest airways of the lung along with the adsorbed compounds, 

many of which are known or suspected mutagens and carcinogens. (ARB, 2002) More 

than 30 human epidemiological studies have investigated the potential carcinogenicity 

of diesel PM. On average, these studies found that long-term occupational exposures 

to diesel exhaust were associated with a 40 percent increase in the relative risk of lung 

cancer. (ARB, 1998b) However, there is limited specific information that addresses the 

variable susceptibilities to the carcinogenicity of diesel exhaust within the general 

human population and vulnerable subgroups, such as infants and children and people 

with preexisting health conditions. The carcinogenic potential of diesel exhaust was 

also demonstrated in numerous genotoxic and mutagenic studies on some of the 

organic compounds typically detected in diesel exhaust. (ARB, 1998b) 

Diesel PM was listed as a TAC by ARB in 1998 after an extensive review and 

evaluation of the scientific literature by OEHHA. (ARB 1998c) Using the cancer unit 

risk factor developed by OEHHA for the TAC program, it was estimated that for the year 
I - 5 

2000, exposure to statewide, average population-weighted, ambient concentrations of 

diesel (1.8 μg/m3

) could be associated with a health risk of 540 potential cancer cases 

per million people exposed over a 70-year lifetime. 

Another highly significant health effect of diesel exhaust exposure is its apparent ability 

to act as an adjuvant in allergic responses and possibly asthma. (Dab, 2000) 

(Diaz-Sanchez, 1996) (Kittelson, 1999) However, additional research is needed at 

diesel exhaust concentrations that more closely approximate current ambient levels 

before the role of diesel PM exposure in the increasing allergy and asthma rates is 

established. 

 Ambient Particulate Matter

The key health effects categories associated with ambient particulate matter, of which 

diesel PM is an important component, include premature mortality; aggravation of 

respiratory and cardiovascular disease (as indicated by increased hospital admissions 

and emergency room visits, school absences, work loss days, and restricted activity 

days); aggravated asthma; acute respiratory symptoms, including aggravated coughing 

and difficult or painful breathing, chronic bronchitis, and decreased lung function that 

can be experienced as shortness of breath. (U.S. EPA 2000, U.S. EPA 2003) 

Health impacts from exposure to the fine particulate matter (PM2.5) component of diesel 

exhaust have been calculated for California, using concentration-response equations 

from several epidemiological studies. Both mortality and morbidity effects could be 

associated with exposure to either direct diesel PM2.5 or indirect diesel PM2.5, the latter 

of which arises from the conversion of diesel NOx emissions to PM2.5 nitrates. It was 

estimated that 2000 and 900 premature deaths resulted from long-term exposure to 

either 1.8 μg/m3 of direct PM2.5 or 0.81 μg/m3 of indirect PM2.5, respectively, for the year 

2000. (Lloyd, 2001) The mortality estimates are likely to exclude cancer cases, but 

may include some premature deaths due to cancer, because the epidemiological 

studies did not identify the cause of death. Exposure to fine particulate matter, including 

diesel PM2.5 can also be linked to a number of heart and lung diseases. 

 Ozone

Diesel exhaust consists of hundreds of gas-phase, particle-phase, and semi-volatile 

organic compounds, including typical combustion products, such as CO2, hydrogen, 

oxygen, and water vapor, as well as CO, ROG, carbonyls, alkenes, aromatic 

hydrocarbons, PAHs, PAH derivatives, and sulfur oxides (SOx) - compounds resulting 

from incomplete combustion. Ozone is formed by the reaction of ROG and NOx in the 

atmosphere in the presence of heat and sunlight. The highest levels of ozone are 

produced when both ROG and NOx emissions are present in significant quantities on 

hot, clear summer days. This pollutant is a powerful oxidant that can damage the 

respiratory tract, causing inflammation and irritation, which can result in breathing 

difficulties. 
I - 6 

Studies have shown that there are impacts on public health and welfare from ozone at 

moderate levels. Short-term exposure to high ambient ozone concentrations have been 

linked to increased hospital admissions and emergency visits for respiratory problems. 

(Peters, 2001) Repeated exposure to ozone can make people more susceptible to 

respiratory infection and lung inflammation and can aggravate preexisting respiratory 

diseases, such as asthma. Prolonged (six to eight hours), repeated exposure to ozone 

can cause inflammation of the lung, impairment of lung defense mechanisms, and 

possibly irreversible changes in lung structure, which over time could lead to premature 

aging of the lungs and/or chronic respiratory illnesses such as emphysema and chronic 

bronchitis. 

The subgroups most susceptible to ozone health effects include individuals exercising 

outdoors, children and people with preexisting lung disease such as asthma, and 

chronic pulmonary lung disease. Children are more at risk from ozone exposure 

because they typically are active outside, during the summer when ozone levels are 

highest. Also, children are more at risk than adults from ozone exposure because their 

respiratory systems are still developing. Adults who are outdoors and moderately active 

during the summer months, such as construction workers and other outdoor workers, 

also are among those most at risk. These individuals, as well as people with respiratory 

illnesses such as asthma, especially asthmatic children, can experience reduced lung 

function and increased respiratory symptoms, such as chest pain and cough, when 

exposed to relatively low ozone levels during prolonged periods of moderate exertion. 

G. Health and Environmental Benefits from the Proposed Regulation 

Reducing diesel PM emissions from cargo handling equipment at ports and intermodal 

rail yards will have both public health and environmental benefits. The proposed 

regulation will reduce localized potential cancer risks associated with emissions from 

cargo handling equipment and will contribute to the reduction of the general exposure to 

diesel PM that occurs on a region-wide basis due to collective emissions from dieselfueled engines. Additional benefits associated with the proposed regulation include 

further progress in meeting the ambient air quality standards for PM10, PM 2.5, and 

ozone, and enhancing visibility. 

 Reduced Diesel PM Emissions

The estimated reductions in diesel PM emissions and the associated benefits from 

reduced exposure and risk are discussed in detail in Chapter VI. 

 Reduced Ambient Particulate Matter Levels

Reducing diesel PM will also help efforts to achieve the ambient air quality standards for 

particulate matter. Both the State of California and the U.S. EPA have established 

standards for the amount of PM10 in the ambient air. These standards define the 

maximum amount of PM that can be present in outdoor air. California's PM10 standards 
I - 7 

were first established in 1982 and updated June 20, 2002. It is more protective of 

human health than the corresponding national standard. Additional California and 

federal standards were established for PM2.5 to further protect public health (Table I-1). 

Table I-1: State and National PM Standards 

California Standard National Standard

PM10

Annual Arithmetic Mean 20 μg/m3 Annual Arithmetic Mean 50 μg/m3

24-Hour Average 50 μg/m3 24-Hour Average 150 μg/m3

PM2.5

Annual Arithmetic Mean 12 μg/m3 Annual Arithmetic Mean 15 μg/m3

24-Hour Average No separate 

State standard

24-Hour Average 65 μg/m3

Particulate matter levels in most areas of California exceed one or more of current state 

PM standards. The majority of California is designated as non-attainment for the State 

PM10 standard (ARB 2002). Diesel PM emission reductions from diesel-fueled engines 

will help protect public health and assist in furthering progress in meeting the ambient 

air quality standards for both PM10 and PM2.5. 

The emission reductions obtained from the use of lower emission diesel engines will 

result in lower ambient particulate matter levels and significant reductions of exposure 

to primary and secondary diesel PM. Lower ambient particulate matter levels and 

reduced exposure mean reduction of the prevalence of the diseases attributed to diesel 

PM, reduced incidences of hospitalizations and prevention of premature deaths. 

 Reduced Ambient Ozone Levels

Emissions of NOx and ROG, precursors to the formation of ozone in the lower 

atmosphere, will also be reduced by the proposed regulation. In California, most major 

urban areas and many rural areas continue to be non-attainment for the State and 

federal 1-hour ambient air quality standard for ozone. Controlling emissions of ozone 

precursors would reduce the prevalence of the types of respiratory problems associated 

with ozone exposure and would reduce hospital admissions and emergency visits for 

respiratory problems. Ozone can also have adverse health impacts at concentrations 

that do not exceed the 8-hour NAAQS. 

Table I-2: State and National Ozone Standards 

California Standard National Standard

1 hour 0.09 ppm (180 μg/m3

) - 

8 hour 0.070 ppm (137 μg/m3

) 0.08 ppm (157 μg/m3) 

 Note: The 8 hour California standard is expected to become effective in early 2006.
I - 8 

Improved Visibility

In addition to the public health effects of fine particulate pollution, inhalable particulates 

including sulfates, nitrates, organics, soot, and soil dust contribute to regional haze that 

impairs visibility. 

In 1999, the U.S. EPA promulgated a regional haze regulation that calls for states to 

establish goals and emission reduction strategies for improving visibility in 

156 mandatory Class I national parks and wilderness. California has 29 of these 

national parks and wilderness areas, including Yosemite, Redwood, and Joshua Tree 

National Parks. Reducing diesel PM from cargo handling equipment will help improve 

visibility in these Class I areas. 

H. Public Outreach and Environmental Justice 

Environmental Justice

The ARB is committed to integrating environmental justice in all of its activities. On 

December 13, 2001, the Board approved "Policies and Actions for Environmental 

Justice," which formally established a framework for incorporating Environmental 

Justice into the ARB's programs, consistent with the directive of California state law. 

(ARB, 2001) Environmental Justice is defined as the fair treatment of people of all 

races, cultures, and incomes with respect to the development, adoption, 

implementation, and enforcement of environmental laws, regulations, and policies. 

These policies apply to all communities in California, but recognize that environmental 

justice issues have been raised more in the context of low-income and minority 

communities. 

The Environmental Justice Policies are intended to promote the fair treatment of all 

Californians and cover the full spectrum of the ARB's activities. Underlying these 

Policies is a recognition that the agency needs to engage community members in a 

meaningful way as it carries out its activities. People should have the best possible 

information about the air they breathe and what is being done to reduce unhealthful air 

pollution in their communities. The ARB recognizes its obligation to work closely with all 

communities, environmental and public health organizations, industry, business owners, 

other agencies, and all other interested parties to successfully implement these Policies. 

 

During the development process, the ARB staff provided opportunities to present 

information about the proposed regulation at places and times convenient to 

stakeholders. For example, the meetings were held at times and locations that 

encouraged public participation, including evening sessions. Attendees included 

representatives from environmental community organizations, terminal operators, port 

and rail representatives, engine and diesel emission control associations, and other 

parties interested in mobile cargo handling equipment. These individuals participated 

both by providing data and reviewing draft regulations and by participating in open 

forum workshops, in which staff directly addressed their concerns. Table I-3 below 
I - 9 

provides meeting dates that were made to apprise the public about the development of 

the proposed regulation. 

Table I-3: Workshop/Workgroup and Public Outreach Meetings 

 

Date Meeting Location Time 

July 7, 2004 Public Workshop Port of Los Angeles 1:30 p.m. 

July 8, 2004 Public Workshop Elihu Harris Building, Oakland 1:30 p.m. 

September 9, 2004 

San Pedro Conference on 

Air Quality, International 

Trade, & Transportation 

Marina San Pedro Hotel, 

San Pedro 10:15 a.m. 

September 22, 2004 Public Working Group Cal/EPA Building, Sacramento 

(teleconference) 1:30 p.m. 

October 27, 2004 No Net Increase Air Quality 

Task Force 

Sheraton Los Angeles Harbor 

Hotel, San Pedro 1:00 p.m. 

November 10, 2004 Public Workshop Cal/EPA Building, Sacramento 10:45 a.m. 

December 1, 2004 Public Working Group Cal/EPA Building, Sacramento 

(teleconference) 1:30 p.m. 

January 19, 2005 

Port Community Advisory 

Committee: Air Quality 

Subcommittee 

Port of Los Angeles 4:30 p.m. 

February 24, 2005 California Air Resources 

Board: Board Meeting Cal/EPA Building, Sacramento 9:00 a.m. 

April 7, 2005 Environmental Law Super 

Symposium Omni Hotel, Los Angeles 1:00 p.m. 

May 18, 2005 Public Workshop Cal/EPA Building, Sacramento 9:00 a.m. 

August 11, 2005 Public Working Group Cal/EPA Building, Sacramento 

(teleconference) 1:30 p.m. 

August 24, 2005 Public Workshop Port of Long Beach 10:00 a.m. 

August 24, 2005 Public Workshop Long Beach Senior Center 6:00 p.m. 

October 4, 2005 Public Working Group Cal/EPA Building, Sacramento 

(teleconference) 1:30 p.m. 

The proposed regulation is consistent with the environmental justice policy to reduce 

health risks from TACs in all communities, including those with low-income and minority 

populations, regardless of location. The regulation will reduce diesel PM emissions 

from mobile cargo handling equipment at ports and intermodal rail yards by requiring 

accelerated turnover to cleaner engines and the use of the best available control 

technologies. The proposed regulation will provide air quality benefits for all 

Californians, particularly those living near ports and intermodal rail facilities where cargo 

handling equipment operate. 

Outreach Efforts

Since the identification of diesel PM as a TAC in 1998, the public has been more aware 

of the health risks posed by the emissions of this TAC. At many of the ARB's 

community outreach meetings over the past few years, the public has raised questions 
I - 10 

regarding our efforts to reduce exposure to diesel PM. At these meetings, ARB staff 

told the public about the Diesel Risk Reduction Plan adopted in 2000 and described 

some of the measures in that plan, including those for off-road diesel-fueled engines 

such as cargo handling equipment. 

The ARB has held six public workshops and four public working group meetings since 

July 2004 in developing this rule (see Table I-3). Over 700 individuals and/or 

companies were notified for each workshop/meeting through a series of mailings. 

Notices were posted to ARB's cargo handling equipment and public workshops web 

sites and e-mailed to subscribers of the cargo handling equipment electronic list server. 

The majority of the workshops were broadcast live via the internet, and working group 

meetings were held via teleconference, making them more easily accessible the public. 

In addition to the public workshops and working group meetings presented in Table I-3, 

ARB staff and management participated in numerous industry, government agency, and 

community meetings over the past three years, presenting information on the Diesel 

Risk Reduction Plan and our proposed regulatory approach for cargo handling 

equipment at ports and intermodal rail yards. Some of the industry groups and 

environmental associations participating were railroad companies, California ports, the 

American Lung Association, the Wilmington Coalition for a Safe Environment, Citizens 

for a Better Environment, Coalition for Clean Air, the Manufacturers of Emission 

Controls Association, National Resources Defense Counsel, Environmental Defense, 

the Pacific Merchant Shipping Association, the Pacific Maritime Association, private 

businesses, and others. Staff also met periodically with a regulatory workgroup, 

comprised of representatives from local air pollution control or air quality management 

districts and the U.S. EPA. 

As a way of inviting public participation and enhancing the information flow between the 

ARB and interested parties, staff created a cargo handling equipment Internet web site 

(http://www.arb.ca.gov/cargo) in March 2004. Since that time, staff has consistently 

made available on the web site all related documents, including meeting presentations 

and draft versions of the proposed regulatory language. The web site has also provided 

background information on diesel PM, workshop and meeting notices and materials, 

and other diesel related information, and has served as a portal to other web sites with 

related information. 

Outreach efforts have also included hundreds of personal contacts via telephone, 

electronic mail, regular mail, surveys, facility visits, and individual meetings with 

interested parties. These contacts have included interactions with engine 

manufacturers and operators, emission control system manufacturers, local, national, 

and international trade association representatives, and environmental, community, and 

public health organizations. 
I - 11 

REFERENCES: 

(ARB, 2001) California Air Resources Board. Policies and Actions for Environmental 

Justice; December 2001. 

(ARB, 1998a) California Air Resources Board. Report to the Air Resources Board on 

the Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant; Part A, 

Exposure Assessment; As Approved by the Scientific Review Panel on April 22, 1998. 

(ARB, 1998b) California Air Resources Board. Resolution 98–35: Identification of 

Particulate Emissions from Diesel-Fueled Engines as a Toxic Air Contaminant; 1998. 

(ARB, 2000) California Air Resources Board. Risk Reduction Plan to Reduce 

Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles; October 2000. 

(ARB, 2002) California Air Resources Board. The 2002 California Almanac of Emission 

and Air Quality, 2002. 

(Beeson, 1998) Beeson, W. L; Abbey, D. E.; Knutsen, S. F. Long-term Concentrations 

of Ambient Air Pollutants and Incident Lung Cancer in California Adults: Results from 

the AHSMOG Study; Environmental Health Perspectives; 1998. 

(Dab, 2000) Dab, W. S., et. al. Air Pollution and Health: Correlation or Causality? The 

Case of the Relationship Between Exposure to Particles and Cardiopulmonary Mortality; 

Journal of the Air and Waste Management Association; February 2001. 

(Diaz-Sanchez, 1996) Diaz-Sanchez, D.; Tsien, A.; Casillas, A.; Dotson, A.R.; Saxon, A. 

Enhanced Nasal Cytokine Production in Human Beings after in vivo Challenge with 

Diesel Exhaust Particles; J. Allergy Clin. Immunol; 1996. 

(Kittelson, 1999) Kittelson, D.B., Arnold, M., Watts, W.F. Review of Diesel Particulate 

Matter Sampling Methods (University of Minnesota); 1999 

(Lloyd, 2001) Lloyd, A.C.; Cackette, T.A. Diesel Engines: Environmental Impact and 

Control; J Air Waste Management Association; 2001. 

(Peters, 2001) Peters, A; Dockery, D. W.; Muller, J. E.; Mittleman, M.A. Increased 

Particulate Air Polltion and the Triggering of Myocardial Infarction Circulation; 2001. 
II - 1 

Yard Truck 

II. MOBILE CARGO HANDLING EQUIPMENT AT PORTS AND INTERMODAL 

RAIL YARDS 

A. Definitions and Uses 

Mobile cargo handling equipment at ports and intermodal rail yards is as diverse a 

group of equipment as the cargo that it handles. Cargo that arrives and/or departs by 

ship, truck, or train, can include liquid, bulk (break bulk and dry bulk), and containers. 

Liquid cargo, such as petroleum products and chemicals, are often transported via 

pipelines, and therefore, do not usually have mobile cargo handling equipment 

associated with their operation. Break bulk cargo, such as lumber, steel, machinery, 

and many types of palletized goods, and dry bulk cargo, such as cement, scrap metal, 

salt, sugar, sulfur, and petroleum coke, usually require equipment such as loaders, 

dozers, cranes, forklifts, and sweepers for their operations. Container cargo, which is 

the most common type of cargo at ports and intermodal rail yards, requires equipment 

such as yard trucks, rubber-tired gantry (RTG) cranes, top picks, side picks, forklifts, 

and straddle carriers. There are about 3,700 mobile cargo handling equipment vehicles 

at California’s ports and intermodal rail yards. Below is a description of some of the 

most common equipment types. 

 Container Handling Equipment 

Yard Truck

The most common type of cargo handling equipment is a 

yard truck. Yard trucks are also known as yard goats, utility 

tractor rigs (UTRs), hustlers, yard hostlers, and yard 

tractors. Yard trucks are very similar to heavy-duty on-road 

truck tractors, but the majority are equipped with off-road 

engines. 

Yard trucks are designed for moving cargo containers. 

They are used at container ports and intermodal rail yards 

as well as distribution centers and other intermodal 

facilities. Containers are loaded onto the yard trucks by 

other container handling equipment, such as rubber-tired gantry cranes, top picks, or 

side picks, and they are unloaded the same way. In addition to loading and unloading 

operations, yard trucks are used to move containers around a facility (yard) for stacking 

and storing purposes. 

While most yard trucks are diesel-fueled, there is limited availability of those powered by 

liquefied petroleum gas (LPG), compressed natural gas (CNG), and liquefied natural 

gas (LNG), and the incremental costs of alternative fuel yard trucks is very high 

(between 20 and 66 percent). The Port of Los Angeles has approximately 60 LPG 

fueled yard trucks, and the Port of Long Beach has ordered five natural gas yard trucks 

to be delivered in the Fall 2005. 
II - 2 

Yard trucks have a horsepower (hp) range of about 150 hp to 250 hp, with most being 

around 175 hp to 200 hp. There are approximately 2,300 yard trucks at California's 

ports and intermodal rail yards. 

Top Handler

Another very common type of container handling equipment 

is the top handler. Also known as top picks, top handlers 

are large truck-like vehicles with an overhead boom which 

locks onto the top of containers in a single stack. They are 

used within a terminal to stack containers for temporary 

storage and load containers onto and off of yard trucks. 

Top handlers are capable of lifting loaded cargo containers 

weighing as much as 45,000 pounds. Top handlers have a 

horsepower range of about 250 hp to 400 hp, with most 

being between 250 hp and 350 hp. 

Side Handler

Like the top handler, side handlers (or side picks) are used to 

lift and stack cargo containers. They look very similar to a top 

pick, but instead of grabbing the containers from the top, their 

boom arm extends the width of a container to lift it from the 

front face (or side). Side handlers are most often used to lift 

empty containers; however, some are manufactured to lift 

loaded containers. Side handlers have a horsepower range of 

about 120 hp to 400 hp, with most being between 160 hp and 

250 hp. 

Reach Stacker

Another member of the cargo container handling family is the 

reach stacker. Similar to a top pick, the reach stacker has a 

telescopic boom, usually attached behind the cab, that moves 

upward and outward in order to reach over two or more 

stacks of containers. Reach stackers lock onto the top of the 

containers in a similar fashion to top handlers. However, they 

are not nearly as common as top handlers and side handlers 

because their duties can similarly be performed by rubbertired gantry cranes. They are most often found at port 

container terminals, but rarely at intermodal rail yards. Reach 

stackers have a horsepower range of about 250 hp to 400 hp, 

with most being between 230 hp and 300 hp. 

Top Handler

Side Handler 

Reach Stacker 
II - 3 

Rubber-Tired Gantry Crane

Rubber-tired gantry cranes (or RTG cranes) are very large 

cargo container handlers that have a lifting mechanism 

mounted on a cross-beam supported on vertical legs which 

run on rubber tires. While the propulsion of the crane is 

very slow (about three miles per hour), the lifting

mechanism can move quickly, and is therefore able to load 

and unload containers from yard trucks or from stacks at a 

very fast pace. 

RTG cranes have a horsepower range of about 200 hp to 

1,000 hp, with most being between around 300 hp to 

1,000 hp. There are approximately 300 RTG cranes at 

California's ports and intermodal rail yards. 

Forklift

Used at both container facilities and bulk cargo facilities, 

forklifts are industrial trucks used to hoist and transport 

materials by means of one or more steel forks inserted 

under (or in the case of steel coils, in the middle of) the 

load. Forklifts are extremely diverse in both their size 

and custom cargo handling abilities. While they are 

designed to move and/or lift empty cargo containers or 

stacked or palletized cargo, they can also be designed to 

move or rotate (flip) truck chassis. 

Forklift engines can be powered by either electric motors or internal combustion 

engines, such as compression ignition (i.e., diesel or natural gas) or spark ignition (i.e., 

gasoline or propane) engines. Compression ignition forklifts are usually designed for 

higher lift capacity than their electric or spark ignited counterparts, and are therefore 

more likely to be used in cargo handling operations. 

The cargo handling forklifts used at ports and intermodal rail yards have a horsepower 

range of about 45 hp to 280 hp. There are approximately 460 forklifts at California’s 

ports and intermodal rail yards. 

RTG Crane 

Forklift 
II - 4 

Bulk Cargo Handling Equipment 

Loader

One of the most common dry bulk handling equipment, the 

loader is any type of off-road tractor, with either tracks or 

rubber tires, that uses a bucket on the end of movable arms 

to lift and move material. There are many different types of 

loaders, including but not limited to, front end, skid steer, 

backhoe, rubber tired, and wheeled. Loaders used in 

cargo handling operations range from 36 hp (for small, skid 

steer loaders) to over 1,000 hp (for large, rubber-tired 

loaders), with most being between 200 hp and 750 hp. 

 Dozer

The term dozer refers to an off-road tractor, either 

tracked or wheeled, equipped with a blade. Dozers 

at ports and intermodal rail yards are most often 

used in dry bulk or break bulk cargo handling 

operations. They range in size from 77 hp to 

900 hp, with most being between 300 hp to 400 hp. 

Both loaders and dozers are among the 

approximately 250 bulk cargo handling equipment 

at California’s ports and intermodal rail yards. 

In 2004, the Port of Long Beach (POLB) and the Port of Los Angeles (POLA) published 

emission inventories, which included information on all mobile cargo handling 

equipment, for their respective ports. (POLB, 2004) (POLA, 2004) In addition to the 

data gathered in the two port inventories, ARB staff conducted a statewide survey of 

cargo handling equipment (survey) at ports and intermodal rail yards in December 2004. 

The completed surveys and the POLB and POLA inventory data gave staff important 

information regarding the equipment, such as equipment and engine make, model, 

model year, and fuel types. Additionally, the statewide survey included estimated useful 

life, and expected growth for the years 2010 and 2020. More information is available in 

the emissions inventory appendix (Appendix B). 

Several engine manufacturers were prevalent in the cargo handling equipment that was 

surveyed and inventoried. The most common manufacturer was Cummins, which 

comprised about 80 percent of all of the mobile cargo handling equipment engines. 

Within the Cummins engine families, the 5.9 liter and the 8.3 liter models were the most 

common, and yard trucks made up the majority of the Cummins engines. About 

10 percent of the engines were Caterpillar and Detroit Diesel models. Figure II-1 shows 

the distribution of the most common engine manufacturers and the most common 

equipment types using them. 

Loader 

Dozer 
II - 5 

 Figure II-1: Engine Manufacturers and Equipment Types2

In addition to the statewide survey and the POLA and POLB inventories, ARB staff 

contacted equipment manufacturers to obtain approximate costs for new cargo handling 

equipment. Table II-1 shows the average reported new equipment costs for the most 

common types of mobile cargo handling equipment. 

 

2

 The figure represents only the most common engine manufacturers of mobile cargo handling equipment 

from ARB’s survey and the Ports of Los Angeles and Long Beach inventories and their corresponding 

distribution of equipment types. Therefore, not all manufacturers or equipment types are shown. 

2145

165 165

78

0

500

1000

1500

2000

2500

Cummins Caterpillar Detroit Diesel Perkins

# of Engines

58% Yard Trucks 

13% Forklifts 

12% Loaders 

76% Yard Trucks 

11% Top Handlers 

5% Side Handlers 

44% RTG Cranes 

38% Yard Trucks 

11% Forklifts 

88% Forklifts
II - 6 

Table II-1: Average New Equipment Costs 

Equipment Category Equipment Type 

Average New Cost 

(in thousands $) 

Yard Trucks Yard Truck $60 

Top Handler $400 - $460 

Basic Container Handling Side Handler $240 - $460 

Forklift $40 - $250 

Dozer $25 - $75 (50 – 100hp) 

up to $1,000 for 900hp 

Excavator $200 - $300 

Mobile Crane $60 - $400 

Bulk Cargo Handling 

Loader $15 - $100 (35 – 95hp) 

$125 - $500 (130 – 675hp) 

RTG Cranes RTG Crane $1,000 + 

The POLA and POLB data, along with the data collected from ARB’s survey, were 

integral in developing a statewide population and emissions inventory for cargo handling 

equipment at ports and intermodal rail yards. The developed inventory revealed that 

container handling equipment, such as yard trucks, top handlers, side handlers, and 

RTG cranes, makes up the majority of the population (about 74 percent), with yard 

trucks being the most common equipment type (61 percent). Figure II-2 below shows 

the population by equipment type or category. 

Figure II-2: 2004 Statewide Population Distribution of Cargo Handling Equipment 

at Ports and Intermodal Rail Yards 

Cranes

9%

Forklifts

13%

Container Handling

13%

Yard Trucks

61%

Bulk Cargo

Handling

4%
II - 7 

Detailed information on the statewide emissions inventory for cargo handling equipment 

is available in Appendix B. 

B. Ports and Intermodal Rail Yards 

California is a global gateway for the United States by virtue of its strategic location on 

the Pacific Rim, its border with Mexico, and its major ports and railways. Some of the 

largest ports in the world are located in California, and with the increases in trade and 

general goods movement, both the ports and intermodal rail yards stand to experience 

major growth over the next two decades. 

Currently, the State has 16 primary ports that participate in waterborne commerce: 

Antioch, Benicia, Crockett, Humboldt Bay, Hueneme, Long Beach, Los Angeles, 

Oakland, Pittsburg, Port Chicago, Redwood City, Richmond, Sacramento, San Diego, 

San Francisco, and Stockton. While most of the ports fall under a port authority, the 

smaller ports, such as Antioch, Benicia, and Crockett, generally have docks or terminals 

controlled by the terminal owner(s) or operator(s). Additionally, other small, 

independent ports may exist, or other ports may be developed in the future, to which 

this regulation would be applicable. Figure II-3 shows the current primary ports in 

California and their approximate locations. 

Figure II-3: California’s Ports 

Two major railroad companies, BNSF Railway (BNSF) and Union Pacific Railroad (UP), 

operate 14 intermodal rail yards in California. Additionally, other smaller railroad 

companies may own or operate intermodal rail yards in the state and would be subject 

to compliance with this regulation. The intermodal rail yards generally handle container 

cargo to and from trains, trucks, and in the case of the rail yards being located at the 
II - 8 

ports, to and from ships. Figure II-4 shows the intermodal rail yards operated by BNSF 

and UP in California and their approximate locations. 

Figure II-4: California’s Intermodal Rail Yards 

C. Regulatory Status 

This section provides a regulatory context for the proposed regulation by briefly 

discussing significant existing federal, state, and local air quality regulations and 

programs that apply to cargo handling equipment. 

 Federal and California Emission and Fuel Standards

In all states, off-road engines are required to meet federal standards. However, 

California is authorized under the federal Clean Air Act (CAA), Section 209(e)(2)(A), to 

adopt and enforce emission standards and other requirements for off-road engines and 

equipment not subject to federal preemption, provided California’s standards are at 

least as health-protective as the federal standards. In order to receive this 

authorization, California must apply for and receive approval from the U.S. EPA. 

(EPA, 1990) 

Federal nonroad (off-road) compression ignition engine emission standards are set forth 

for new engines in 40 Code of Federal Regulations (CFR) Part 89. California has 

harmonized with federal emission standards, as set forth in title 13 California Code of 

Regulations (CCR), Article 4, sections 2420-2427, under “Heavy Duty Off-road Diesel 

Cycle Engines.” The off-road engine standards (Tiers) vary depending upon the engine 

model year and maximum rated power. The U.S. EPA adopted more stringent Tier 4 
II - 9 

standards for the control of emissions from nonroad compression ignition engines in 

2004 and ARB approved equivalent off-road standards in 2005. (ARB, 2005) Table II-2 

shows the standards for Tier 1 through Tier 4. 

Table II-2: Off-Road Compression-Ignition (Diesel) Engine Standards 

[NMHC+NOx/CO/PM in g/bhp-hr (g/kW-hr)] 

Federal and California fuel standards specifically apply to manufacturers and 

distributors rather than to mobile sources or their operators. Nevertheless, these 

standards directly affect the fuel used in mobile sources, including cargo handling 

equipment. Fuel standards for sulfur content, aromatic content, and other fuel 

components and parameters play a critical role in meeting emission standards. Federal 

commercial fuel standards are set forth in 40 CFR Part 80 and California fuel standards 

are set forth in title 13 California Code of Regulations sections 2281 and 2282 (diesel). 

In July, 2003, a revision to CCR title 13, section 2281 was adopted by the ARB which 

allows only very low sulfur diesel (<15 ppm) in diesel fuel starting in June 2006. 
II - 10 

(ARB, 2004) Activities involving California nonvehicular diesel fuel are also subject to 

this requirement as if it were vehicular fuel. U.S. EPA plans to adopt a similar sulfur 

restriction that would go into effect in 2006 for on-road fuel use and in 2010 for nonroad 

fuel use. Fuel suppliers for California must meet both federal and California fuel 

standards. 

Some types of cargo handling equipment, particularly yard trucks, have the option to 

use certified on-road engines. The on-road diesel engine standards are included below 

in Table II-3. 

Table II-3: 2004 and Subsequent On-Road Heavy-Duty Diesel Engine Standards 

Model Year HC CO NMHC + NOx NOx PM 

2004-2006 A - 15.5 2.4 B - 0.10 

2007 and subsequent 0.14 C 15.5 - 0.2 D 0.01

A

 October 1, 2002, for EPA Consent Decree signers 

B

 manufacturers can chose a 2.5 g/bhp-hr NMHC+NOx standard with a 0.5 g/bhp-hr NMHC cap 

C

 non-methane hydrocarbons (NMHC) 

D

 phase-in schedule: 50 percent from 2007 to 2009, 100 percent in 2010

 

 California Statutes and Local Air District Rules

In addition to harmonized state/federal off-road/nonroad diesel engine emission 

standards, cargo handling equipment are subject to several other air quality-related 

statutes and regulations in the California Health and Safety Code. 

HSC section 41700 is an important statutory requirement that applies to any source of 

air pollution whatsoever (with some very narrow exceptions), that prohibits any person 

from discharging such quantities of air contaminants which cause injury, detriment, 

nuisance, or annoyance to any considerable number of persons or the public, or which 

endanger the comfort, repose, health, or safety of any such persons or the public, or 

which cause or have the natural tendency to cause injury or damage to business or 

property.” 

HSC section 41701 also applies similarly to any source whatsoever and prohibits air 

contaminant emissions that obscure an observer’s view to no more than Ringelmann 2 

or an opacity of 40 percent. 

Local air districts all have prohibitory rules that are at least as stringent as HSC sections 

41700 and 41701. These two statutes and the local rules provide broad authority to air 

districts to enforce the statutory prohibition against any source whatsoever causing a 

nuisance or emitting excessive smoke. 
II - 11 

 Voluntary Retrofit Programs

Federal, State, and local programs have been developed to encourage less-polluting 

diesel engines. These programs include: 

• ARB’s Carl Moyer Program; 

• Retrofit programs at the Ports of Long Beach, Los Angeles, and Oakland; and 

• U.S. EPA's Voluntary Diesel Retrofit Program. 

ARB’s Carl Moyer Memorial Air Quality Standards Attainment Program (Moyer 

Program) provides funds on an incentive-basis for the incremental cost of cleaner than 

required engines and equipment. Eligible projects include cleaner on-road, off-road, 

marine, locomotive and stationary agricultural pump engines, as well as forklifts, airport 

ground support equipment, auxiliary power units, transport refrigeration units, and cargo 

handling equipment. The program achieves near-term reductions in emissions of 

oxides of nitrogen (NOx), which are necessary for California to meet its clean air 

commitments under the State Implementation Plan. In addition, local air districts use 

these NOx emission reductions to meet commitments in their conformity plans, thus 

preventing the loss of federal funding for local areas throughout California. The 

program also reduces particulate matter (PM), a component of diesel exhaust. 

Several large ports in California have developed air quality improvement plans to 

reduce emissions from port-side diesel equipment. The Ports of Los Angeles, 

Long Beach, and Oakland have offered financial incentives to terminal operators to 

install emission control devices, such as diesel oxidation catalysts (DOCs) on cargo 

handling equipment, and to use cleaner-burning diesel fuels, such as ultra-low sulfur 

diesel and emulsified diesel fuel. Yard trucks, which are the largest emission source for 

this category of off-road equipment, have the ability of using certified on-road engines, 

which can reduce diesel PM emissions as much as 30 percent and NOx emissions as 

much as 70 percent. Some of the ports’ incentive programs have helped to encourage 

terminal operators to purchase yard trucks equipped with on-road engines instead of 

those with off-road engines when adding to their fleets. As a result of these voluntary 

programs, more than 1,200 cargo handling equipment vehicles, primarily yard trucks, 

have been retrofitted with DOCs or replaced with new, cleaner engines in the last three 

years. 

Although U.S. EPA plans to significantly reduce pollution from new diesel engines 

through several steps of new diesel engine emission standards, the effects of these 

rules will take many years to implement due to the long lives of diesel engines. 

U.S. EPA has developed the Voluntary Diesel Retrofit Program to help make a 

difference in the immediate future. The program addresses pollution from diesel 

construction equipment and heavy-duty vehicles that are currently on the road today. 

The Program is building a market for clean diesel engines by working with state, local 

and industry partners to create demonstration projects around the country. The Web 

site at http://www.epa.gov/otaq/retrofit is designed to help fleet operators, air quality 
II - 12 

planners in State/local government, and retrofit manufacturers understand this program, 

and to obtain the information they need to create effective retrofit projects. 

More recently, on August 8, 2005, President Bush signed the Energy Policy Act of 2005. 

Subtitle G, Diesel Emissions Reduction, authorizes $200 million each year for fiscal 

years 2007 through 2011 to provide grants and low-cost revolving loans to achieve 

reductions in diesel emissions. These monies cannot be used to fund emission 

reduction measures mandated under Federal, State or local law. It is unknown at this 

time when the monies will be appropriated and how much funding will be made 

available to California. While the proposed regulation for cargo handling equipment is 

clearly a State mandate, the ARB would support the use of these monies by cargo 

handling equipment operators provided the funds are used to comply early or to achieve 

greater emissions benefits similar to the manner in which Carl Moyer funds can be used 

(see Executive Summary item # 10). 
II - 13 

REFERENCES: 

(ARB, 2005) California Air Resources Board. Rulemaking on the Proposed 

Amendments to the California Off-Road Emissions Regulation for Compression-Ignition 

Engines and Equipment (December 9, 2004); September 29, 2005. 

(ARB, 2004) California Air Resources Board. Amendments to the California Diesel Fuel 

Regulations; May 2004. 

(EPA, 1990) United States Environmental Protection Agency. Federal Clean Air Act, 

Title II, Part A, Sec. 209(e); 1990. 

(POLB, 2004) Port of Long Beach. 2002 Baseline Emissions Inventory; March 2004. 

(POLA, 2004) Port of Los Angeles. Baseline Air Emissions Inventory – 2001; 

July 2004. 
III - 1 

III. EMISSIONS, POTENTIAL EXPOSURES, AND RISK 

This chapter presents the most recent emissions inventory for diesel-fueled cargo 

handling equipment engines operating at ports and intermodal rail yards in California as 

well as a discussion on the potential cancer and non-cancer health risks that may occur 

due to exposures to emissions from cargo handling equipment. 

A. Estimated Emissions from Cargo Handling Equipment 

To develop an emissions estimate of the emissions from diesel-fueled cargo handling 

equipment engines operating at ports and intermodal rail yards, the ARB staff 

developed a methodology that integrated information from the following sources: 

• an ARB survey conducted in 2004 of cargo handling equipment owner/operators 

at California’s ports and intermodal rail yards; 

• emission inventories developed for the ports of Los Angeles and Long Beach for 

2001 and 2002, respectively; and 

• the ARB’s OFFROAD model. 

Baseline emission estimates of diesel PM and NOx for the year 2004 were developed 

and emission projections to 2010 and 2020 were also developed using estimates of 

expected growth, equipment turnover, and equipment age distribution. Details of the 

methodology are found in Appendix B. Based on the information available to date, we 

believe the methodology has resulted in a reasonable estimate of the emissions from 

cargo handling equipment. However, there are continuing efforts by the ARB and the 

major California ports to update and improve the cargo handling equipment inventories. 

As new information becomes available from these efforts, the cargo handling equipment 

emission inventory will be updated. 

 Current 2004 Emission Estimates for Diesel-fueled Cargo Handling

Equipment

The ARB staff estimate that diesel-fueled cargo handling equipment engines operating 

at ports and intermodal rail yards result in approximately 0.65 tons per day or 237 tons 

per year of diesel PM emissions statewide. In addition, based on a range of statewide 

NOx to PM conversion factors of 0.3 – 0.5 g NH4NO3/g NOx, ARB staff estimate a 

secondary formation of PM10 nitrate from NOx emissions from diesel-fueled cargo 

handling equipment engines ranges from approximately 5.7 to 9.5 tons per day.3 

Estimates of statewide 2004 diesel PM and NOx from cargo handling equipment are 

presented in Table III-1. 

 

3

 The conversion factor for the transformation of NOx to NH4NO3 was based on an analysis of 

annual-average conversion factors for secondary formation of PM10 nitrate from NOx emissions at a 

number of urban sites in California. A more detailed description of the methodology used to evaluate the 

conversion of NOx to NH4NO3 is found in Appendix I. 
III - 2 

Table III-1: Estimated Statewide 2004 Cargo Handling Equipment Emissions 

 

2004 Pollutant Emissions (tons per day) 

Equipment Types 

Numbers of 

Equipment NOx PM 

Cranes 321 1.93 0.07 

Excavators 28 0.24 0.01 

Forklifts 464 0.54 0.03 

Container Handling Equipment 487 3.25 0.11 

Other Equipment 40 0.08 0.00 

Sweepers/Scrubbers 28 0.04 0.00 

Tractors/Loaders/Backhoes 93 0.18 0.01 

Yard Trucks 2277 12.78 0.42 

Totals 3738 19.04 0.65 

As shown in Table III-1, there are over 3,700 pieces of cargo handling equipment 

operating at ports and intermodal rail yards in California. Of these, the majority, or 

61 percent, are yard trucks. As shown in Figure III-1, yard trucks represent 

approximately 66 percent of the diesel PM emissions and 67 percent of the NOx 

emissions for cargo handling equipment. 

Figure III-1: 2004 NOx and Diesel PM Emission Distributions at California Ports 

and Intermodal Rail Yards 

NOx Diesel PM

67%

10%

17%

3% 3%

Yard Trucks Cranes

Container Handling Equipment Forklifts

All Other Equipment

66%

11%

16%

4% 3%
III - 3 

The ARB staff also estimated district-specific emissions associated with cargo handling 

equipment. The allocation of these estimates is based on the location of the port or 

intermodal rail yard. Table III-2 presents a district-by-district estimate of emissions from 

cargo handling equipment. 

Table III- 2: Estimated 2004 Cargo Handling Equipment Emissions 

 by District (tpd)4

District NOx Diesel PM 

Bay Area 3.34 0.11 

Mojave 0.08 <0.01 

North Coast 0.06 <0.01 

San Diego 0.75 0.03 

San Joaquin 0.55 0.01 

South Coast 13.38 0.45 

Ventura 0.66 0.02 

Yolo-Solano 0.08 <0.01 

Note: The following districts did not have emissions allocated to them; Amador, Antelope Valley, 

Butte, Calaveras, Colusa, El Dorado, Feather River, Glenn, Great Basin Unified, Imperial, Kern, 

Lake, Lassen, Mariposa, Mendocino, Modoc, Monterey Bay, Unified, Northern Sierra, Northern 

Sonoma, Placer, Sacramento, San Luis Obispo, Santa Barbara, Shasta, Siskiyou, Tehama, and 

Tuolumne. The numbers may not match the statewide totals in Table III-1 due to rounding.

Projected 2010 and 2020 Emission Estimates for Cargo Handling

Equipment

The projected emission estimates for the years 2010 and 2020 are presented in 

Table III-3. Based on information provided in the ARB Survey, annual growth rates for 

cargo handling equipment were determined. Additional details on the methodology and 

the growth rates for each equipment type are provided in Appendix B. 

 

4

 The total emissions may vary slightly from the values shown in Table III-1 due to rounding. 
III - 4 

Table III-3: Cargo Handling Equipment Engines Projected Year 2010 and 2020 

Emission Estimates 

2010 Emission, Tons per Day 2020 Emission, Tons per Day 

Equipment 

Types Numbers of 

Equipment NOx Diesel PM Numbers of Equipment NOx Diesel PM 

Cranes 470 1.83 0.06 602 1.33 0.03 

Excavators 29 0.18 0.01 32 0.05 <0.01 

Forklifts 530 0.39 0.02 607 0.17 0.01 

Container 

Handling 

Equipment 

738 3.43 0.12 1111 1.70 0.05 

Other 

General 

Industrial 

Equipment 

60 0.08 <0.01 93 0.04 <0.01 

Sweepers/ 

Scrubbers 43 0.04 <0.01 64 0.02 <0.01 

Tractors/ 

Loaders/ 

Backhoes 

132 0.17 0.01 200 0.08 <0.01 

Yard Trucks 2810 10.20 0.31 3790 3.02 0.09 

Total 4811 16.34 0.53 6500 6.41 0.18 

These estimates include benefits from new engine standards and benefits from 

pre-2005 voluntary efforts undertaken at California’s ports and intermodal rail yards to 

reduce emissions from cargo handling equipment, but do not include the projected 

reductions expected from implementation of the proposed regulation. As can be seen 

from Table III-3 and Figure III-2, emissions are expected to decline significantly over the 

next 15 years, despite an increase in the number of equipment and operating hours at 

the ports and intermodal rail yards. The reductions of diesel PM can be attributed to 

fleet turnover to newer, cleaner engines and the voluntary emission reduction programs 

implemented prior to 2005 are demonstrated in Figure III-2. 
III - 5 

Figure III-2: Baseline vs. Voluntary Programs Diesel PM Cargo Handling 

Equipment Emissions (tons per year) 

Based on the emission projections, the ARB staff estimates that the voluntary efforts 

undertaken by ports and intermodal rail yards to implement emission control strategies, 

such as diesel oxidation catalysts, result in a reduction of approximately 13 percent in 

diesel PM emissions between 2004 and 2020. 

 

Because the majority of the voluntary efforts involved the installation of diesel oxidation 

catalysts, the ARB staff estimates there are minimal reductions in NOx attributable to 

the voluntary installation of exhaust aftertreatment control devices on cargo handling 

equipment. While a small percentage of cargo handling equipment engines are using 

emulsified fuels, which result in some NOx reductions (up to 20 percent), the ARB staff 

is unable to quantify the benefits at this time. 

Expected emission reductions and the impact on the cargo handling equipment 

emission estimates are discussed in Chapter VI, Environmental Impacts. 

B. Potential Exposures and Risk from Diesel PM Emissions from Cargo 

Handling Equipment Engines 

This section examines the exposures and potential cancer health risks associated with 

particulate matter (PM) emissions from diesel-fueled cargo handling equipment at ports 

and intermodal rail yards. A brief qualitative discussion is provided on the potential 

exposures of Californians to the diesel PM emissions from cargo handling equipment. 

In addition, a summary is presented of a health risk assessment conducted to determine 

the 70-year potential cancer risk associated with exposures to diesel PM emissions 

from cargo handling equipment operated at the Ports of Los Angeles and Long Beach. 

ARB staff believes that the results from this analysis provide quantitative results for 

exposures around the Ports of Los Angeles and Long Beach and are generally 

0

50

100

150

200

250

300

20042007201020152020

Year

TPY

PM Baseline

PM No Voluntary
III - 6 

applicable to other ports and intermodal rail yards in California, providing a qualitative 

estimate for those areas. 

Exposures to Diesel PM

As discussed previously, cargo handling equipment is used at ports and intermodal rail 

yards throughout California. The diesel PM emissions from cargo handling equipment 

contribute to ambient levels of diesel PM emissions. Based on the most recent 

emissions inventory, there are about 3,700 pieces of diesel-fueled cargo handling 

equipment operating at ports and intermodal rail yards in California. The majority of 

ports and intermodal rail yards are in urban areas and, in most cases, are located near 

where people live, work, and go to school. This results in substantial exposures to 

diesel PM emissions from the operation of diesel-fueled cargo handling equipment. 

Because analytical tools to distinguish between ambient diesel PM emissions from 

cargo handling equipment and that from other sources of diesel PM do not exist, we 

cannot measure the actual exposures to emissions from diesel-fueled cargo handling 

equipment. However, modeling tools can be used to estimate potential exposures. To 

investigate the potential risks from exposures to the emissions from cargo handling 

equipment, ARB staff used dispersion modeling to estimate the ambient concentration 

of diesel PM emissions that result from the operation of cargo handling equipment at the 

Ports of Los Angeles and Long Beach. The potential cancer risks from exposures to 

these estimated ambient concentrations of diesel PM were then determined. The 

results from this study are presented below, and additional details on the methodology 

used to estimate the health risks are presented in Appendix C. 

Health Risk Assessment

Risk assessment is a complex process that requires the analysis of many variables to 

simulate real-world situations. There are three key types of variables that can impact 

the results of a health risk assessment for cargo handling equipment: the magnitude of 

diesel PM emissions, local meteorological conditions, and the length of time of 

exposure. Diesel PM emissions are a function of the age and horsepower of the 

engine, the emissions rate of the engine, and the annual hours of operation. Older 

engines tend to have higher pollutant emission rates than newer engines, and the 

longer an engine operates, the greater the total pollutant emissions. Meteorological 

conditions can have a large impact on the resultant ambient concentration of diesel PM, 

with higher concentrations found along the predominant wind direction and under calm 

wind conditions. How close a person is to the emissions plume and how long he or she 

breathes the emissions (exposure duration) are key factors in determining potential risk, 

with longer exposures times typically resulting in higher risk. 

To estimate potential cancer risks from cargo handling equipment, ARB staff conducted 

a risk assessment for cargo handling equipment operated at the Ports of Los Angeles 

and Long Beach. We evaluated the impacts from the 2002 estimated emissions for 

cargo handling equipment operated at the two ports. Meteorological data from 
III - 7 

Wilmington was used for this study. The Wilmington site is about one mile away from 

the ports, and the measurements were collected in 2001. The U.S. EPA’s ISCST3 air 

dispersion model was used to estimate the annual average offsite concentration of 

diesel PM in the area surrounding the two ports. The modeling domain (study area) 

spans a 20 x 20 mile area, which includes both the ports, the ocean surrounding the 

ports, and nearby residential areas in which about 2 million people live. The land-based 

portion of the modeling domain, excluding the property of the ports, comprises about 

65 percent of the modeling domain. A Cartesian grid receptor network (160 x 160 grids) 

with 200 x 200 meter resolution was used in this study. While grids within the ports 

were included in the network, the risks within these grids were excluded from the final 

risk analyses. The elevation of each receptor within the modeling domain was 

determined from the United States Geological Service topographic data. 

The potential cancer risks were estimated using standard risk assessment procedures 

based on the annual average concentration of diesel PM predicted by the model and a 

health risk factor (referred to as a cancer potency factor) that correlates cancer risk to 

the amount of diesel PM inhaled. The methodology used to estimate the potential 

cancer risks is consistent with the Tier-1 analysis presented in the Office of 

Environmental Health Hazard Assessment (OEHHA) Air Toxics Hot Spots Program Risk 

Assessment Guidelines. (OEHHA, 2002) (OEHHA, 2003) Following the OEHHA 

guidelines, we assumed that the most impacted individual would be exposed to 

modeled diesel PM concentrations for 70 years. This exposure duration represents an 

“upper-bound” of the possible exposure duration. The potential cancer risk was 

estimated by multiplying the inhalation dose by the cancer potency factor (CPF) of 

diesel PM (1.1 (mg/kg-d)-1). 

Cancer Risk Characterization

Emissions from cargo handling equipment resulted in significant risk impacts on the 

nearby residential areas. Figure III-3 shows the risk isopleths for diesel PM emissions 

from cargo handling equipment at the Ports of Los Angeles and Long Beach 

superimposed on a map that covers the ports and the nearby communities. As shown 

in Figure III-3, the area in which the risks are predicted to exceed 100 in a million has 

been estimated to be about 4,100 acres with a population of 82,000. For the highest 

risk level of over 500 in a million, the impacted areas have been estimated to be about 

50 acres and about 3,200 people living around the ports who are exposed to the risk 

level. Overall, about 73 percent of the effective modeling domain (excluding the port 

property and the surrounding ocean area) has an estimated risk level of over 10 in a 

million. 

Using the U.S. Census Bureau’s year 2000 census data, we estimated the population 

within the isopleth boundaries. The area impacted and the population affected for the 

risk ranges of 10-100, 100-200, 200-500, and over 500 are shown in Table III-4. As 

shown in the table, nearly three quarters of 2 million people live in the area around the 

ports that has predicted risks of greater than 10 in a million due to emissions from cargo 

handling equipment. Note that the size of the modeling domain was limited by the 
III - 8 

technical capabilities of the model. However, it is clear that a significant number of 

people outside the modeling domain are exposed to risks greater than 10 in a million. 

 

Table III-4: Summary of Area Impacted and Population Affected by Risk Levels 

from Cargo Handling Equipment 

Risk Level Acres Impacted Population Affected 

Risk > 500 50 3,200 

Risk > 200 410 11,100 

Risk > 100 4,100 82,000 

Risk > 10 119,000 1,444,000 

Note: The effective modeling domain is about 255 square miles or 163,435 acres, and the total 

population within the domain is about 2 million. The area with predicted risks greater than 10 in a million 

extends beyond the modeling domain. As such, the actual acres impacted and population exposed to 

levels greater than 10 in a million are larger than those presented in Table III-4. 
III - 9 

Figure III-3: Estimated Diesel PM Cancer Risk from Cargo Handling Equipment 

Activity at the POLA and POLB (Wilmington Met Data, Urban Dispersion 

Coefficients, 80th Percentile Breathing Rate, Emission = 172 TPY, Modeling Domain 

= 20 mi x 20 mi, Resolution = 200 m x 200 m)

C. Non-Cancer PM Health Effects 

A substantial number of epidemiologic studies have found a strong association between 

exposure to ambient particulate matter and adverse health effects. (CARB, 2002) As 

part of this study, ARB staff conducted an analysis of the potential non-cancer health 

impacts associated with exposures to the model-predicted ambient levels of directly 

emitted diesel PM (primary diesel PM) discussed above and extrapolated them to the 

rest of the state. The non-cancer health effects evaluated include premature death, 

asthma attacks, work loss days, and minor restricted activity days. 

380000 385000 390000 395000 400000 405000

Easting (m) 

3725000

3730000

3735000

3740000

3745000

3750000

N

orthing (m)

0 1 2

miles
III - 10 

Based on our analysis, we estimate that the average number of cases statewide in 2004 

that would be expected due to emissions from cargo handling equipment are as follows: 

• 9 premature deaths (for ages 30 and older), 4 to 13 deaths as 95% confidence 

interval (CI); 

• 219 asthma attacks, 53 to 383 as 95% CI; 

• 1,907 days of work loss (for ages 18-65), 1,614 to 2,200 as 95% CI; and 

• 10,127 minor restricted activity days (for ages 18-65), 8,254 to 12,000 as 

95% CI. 

As stated previously, to estimate these statewide potential non-cancer health impacts 

from cargo handling equipment emissions, ARB staff estimated the non-cancer health 

impacts from cargo handling equipment in the area surrounding the ports of Los Angles 

and Long Beach and extrapolated these results to predict statewide values based on 

the ratio of the mass emissions at the POLB and POLA to those in the rest of the State. 

A brief discussion on the methodology used to generate these estimates is provided 

below. Additional information on the data inputs for the non-cancer health impacts 

analysis are provided in Appendix J. 

 Non-Cancer Health Effects Methodology

ARB staff assessed the potential non-cancer health impacts associated with exposures 

to the model-predicted ambient levels of directly emitted diesel PM (primary diesel PM) 

within each 200 meter by 200 meter grid cell within the modeling domain used for the 

POLA-POLB exposure assessment study. Because the study used the 2002 emissions 

estimates for cargo handling equipment at the ports, the ambient concentrations were 

adjusted to reflect the updated 2004 emissions inventory developed by ARB staff. The 

populations within each grid cell were determined from U.S. Census Bureau year 2000 

census data. Using the methodology peer-reviewed and published in the Staff Report: 

Public Hearing to Consider Amendments to the Ambient Air Quality Standards for 

Particulate Matter and Sulfates, (PM Staff Report) (CARB, 2002), we calculated the 

number of annual cases of death and other health effects associated with exposure to 

the ambient PM concentrations modeled for each of the grid cells. For each grid cell, 

each health effect was estimated based on concentration-response functions derived 

from published epidemiological studies relating changes in ambient concentrations to 

changes in health endpoints, the population affected, and the baseline incidence rates. 

The total affected population was obtained by summing the results from each grid cell. 

The selection of the concentration-response functions was based on the latest 

epidemiologic literature, as described in the PM Staff Report (CARB, 2002) and in Lloyd 

and Cackette (Lloyd, Cackette 2001). Staff estimated that the ports of Los Angeles and 

Long Beach account for approximately 70 percent of total statewide emissions related 

to cargo handling equipment activities. Hence, the statewide impact of the cargo 

handling emissions was estimated by dividing the estimated impacts in the modeling 

domain around the ports of Los Angeles and Long Beach by 0.70. 
III - 11 

Several assumptions were used in quantifying the health effects of PM exposure. They 

include the selection and applicability of the concentration-response functions, exposure 

estimation, subpopulation estimation, baseline incidence rates, and the extrapolation 

from results in the modeling domain to the statewide results. These are briefly 

described below. 

• Premature death calculations were based on the concentration-response function 

of Krewski et al. (Krewski et at, 2000) The ARB staff assumed that concentrationresponse function for premature mortality in the model domain is comparable to 

that in the Krewski study. It is known that the composition of PM can vary by 

region, and not all constituents of PM have the same health effects. However, 

numerous studies have shown that the mortality effects of PM in California are 

comparable to those found in other locations in the United States, justifying our 

use of Krewski et al’s results. Also, the U.S. EPA has been using Krewski’s 

study for its regulatory impact analyses since 2000. For other health endpoints, 

the selection of the concentration-response functions was based on the most 

recent and relevant scientific literature. Details are ARB’s PM Staff Report 

(CARB, 2002). 

• The ARB staff assumed the model-predicted exposure estimates could be 

applied to the entire population within each modeling grid. That is, the entire 

population within each modeling grid of 200 meter x 200 meter was assumed to 

be exposed uniformly to modeled concentration. This assumption is typical of 

this type of estimation. 

• The ARB staff assumed the grid cell population had similar age distributions as 

the county in which it was located. The subpopulation used for each health 

endpoint was calculated by multiplying the all-age population for each grid cell by 

the county-specific ratio of the subpopulation used for the endpoint over the allage population. For example, mortality estimates were based on subpopulations 

age 30 or more estimated from ratios of people over 30 over the entire 

population, specific for each county. For Los Angeles County, this value was 

54 percent. These estimates were needed because information on the particular 

subpopulation in each modeling grid was not available. 

• The ARB staff assumed the baseline incidence rates were uniform across each 

modeling grid, and, in many cases, across each county. This assumption is 

consistent with methods used by the U.S. EPA for its regulatory impact 

assessment. The incidence rates match those used by U.S. EPA. 

• Because only impacts from directly emitted diesel PM are estimated and a 

subset of health outcomes is considered here, the estimates should be 

considered an underestimate of the total public health impact. In addition, the 

model domain for the study was 20 miles by 20 miles and did not capture all of 

impacts on the surrounding communities from the POLA and POLB emissions. 
III - 12 

• Without readily available modeled concentrations at other ports in California, staff 

extrapolated the results based on the modeling domain around ports of 

Los Angeles and Long Beach to infer statewide effects. In doing so, it was 

assumed that the population density and the change in concentrations due to the 

regulation would be similar to those in the ports of Los Angeles and Long Beach. 
III - 13 

REFERENCES: 

(OEHHA, 2002) Office of Environmental Health Hazard Assessment. The Air Toxics 

Hot Spot Program Risk Assessment Guidelines: Part II-Technical Support Document for 

Describing Available Cancer Potency Factors; 2002. 

(OEHHA, 2003) Office of Environmental Health Hazard Assessment. Air Toxics Hot 

Spots Program Risk Assessment Guidelines: The Air Toxics Hot Spots Program 

Guidance Manual for Preparation of Health Risk Assessments; 2003. 

(CARB, 2002) California Air Resources Board and Office of Environmental Health 

Hazard Assessment. Staff Report: Public Hearing to Consider Amendments to the 

Ambient Air Quality Standards for Particulate Matter and Sulfates, available at 

http://www.arb.ca.gov/research/aaqs/std-rs/pm-final/pm-final.htm; 2002. 

(Krewski et al. 2000) Krewski D.; Burnett R.; Goldberg M.; Hoover K.; Stemiatychi 

J.; Jerrett M.; Abrahamovicz M.; White W. Reanalysis of the Harvard Six Cities 

Study and the American Cancer Society Study of Particulate Air Pollution and 

Mortality, Health Effects Institute, Cambridge, Massachusetts; 2000. 

http://es.epa.gov/ncer/science/pm/hei/Rean-ExecSumm.pdf 

(Lloyd and Cackette. 2001) Lloyd, A.C.; Cackette, T.A.; Diesel Engines: 

Environmental Impact and Control; J Air Waste Manage. Assoc. 2001, 51: 809- 

847. 

http://www.arb.ca.gov/research/seminars/lloyd/AWMA2001/JAWMADieselCritical 

Review.pdf 
IV - 1 

IV. THE PROPOSED REGULATION AND ALTERNATIVES 

In this chapter, we discuss the key requirements of the proposed regulation for mobile 

cargo handling equipment at ports and intermodal rail yards. This chapter begins with a 

general summary of the regulation, and each major requirement of the regulation is 

discussed and explained. This chapter is intended to satisfy the requirements of 

Government Code section 11343.2, which requires that a noncontrolling “plain English” 

summary of the regulation be made available to the public. Unless otherwise noted 

herein, all references to mobile cargo handling equipment include mobile cargo handling 

equipment at ports and intermodal rail yards, as defined in the regulation. 

A. Summary of the Proposed Regulation 

The proposed regulation for Mobile Cargo Handling Equipment at Ports and Intermodal 

Rail Yards is included in Appendix A. The regulation is designed to use the best 

available control technology (BACT) to reduce the general public’s exposure to diesel 

particulate matter (PM) and oxides of nitrogen (NOx) emissions from mobile cargo 

handling equipment. In addition, the regulation would include recordkeeping and 

reporting requirements to provide staff up-to-date information on cargo handling 

equipment and activities. 

The requirements for newly purchased, leased, or rented equipment, as well as in-use 

equipment would affect owners and operators of mobile cargo handling equipment that 

operate at ports and intermodal rail yards in California. The requirements would also 

affect any person who sells, offers for sale, purchases, leases, or rents mobile cargo 

handling equipment for use at a port or intermodal rail yard in California. This would 

include shipping terminals at ports and intermodal rail yard terminals. Mobile cargo 

handling equipment that does not operate at a port or intermodal rail yard, portable 

compression-ignition engines, and cargo handling equipment used to transport 

personnel and deliver fuel would not be covered by the rule. 

The proposed regulation would require, as of January 1, 2007, newly purchased, 

leased, or rented (new) equipment to meet performance standards, which vary 

depending on the classification of the new equipment (either off-road cargo handling 

equipment or a registered on-road cargo handling equipment vehicle), and the 

availability of certified on-road engines for the equipment type and application. For 

registered on-road vehicles, the new equipment must meet the certified on-road engine 

standards for the model year in which the engine is newly purchased, leased, or rented. 

New yard trucks that are not registered motor vehicles must meet either the current 

model year certified on-road engine standards or the certified off-road final Tier 4 

standards for the rated horsepower. New non-yard truck equipment that are not 

registered motor vehicles must meet either the current model year certified on-road 

engine standards or the certified off-road Tier 4 standards for the rated horsepower and 

model year in which the equipment and engines were newly purchased, leased, or 

rented. However, if that is not available for the specific non-yard truck equipment type 

and application, the highest level certified off-road engine for the model year of the year 
IV - 2 

purchased, leased, or rented and installation of the highest available level verified diesel 

emission control strategy (VDECS) within one year is required. If no VDECS is 

available during the initial year of operation, installation would be required within six 

months after VDECS becomes available. 

The proposed regulation would require in-use yard trucks to meet performance 

standards based on BACT by choosing one of three options. One option is to meet the 

2007 or later model year certified on-road engine standards, another option is to meet 

the certified final Tier 4 off-road standards, and the last option is to apply VDECS that 

would result in emissions less than or equal to the diesel particulate matter (PM) and 

oxides of nitrogen (NOx) emission standards of a certified final Tier 4 off-road engine. 

Compliance dates are soonest for pre-2003 model year yard trucks, and owners of 

more than three yard trucks are given additional time to comply. The proposal also 

provides more time for owners or operators who have installed VDECS prior to 

December 31, 2006, and for those currently using certified on-road engines, by delaying 

the compliance date one year. 

The proposed regulation would require in-use non-yard truck equipment to use BACT to 

meet a selection of performance standards based on the category of equipment. Three 

categories exist: 

• Basic Container Handling (including, but not limited to top handlers, side 

handlers, and forklifts5

); 

• Bulk Cargo Handling (including, but not limited to dozers, loaders, excavators, 

aerial lifts, and sweepers); and 

• Rubber-Tired Gantry (RTG) Cranes. 

Each category has three compliance options, based on BACT. One option is to use an 

engine or power system, including a diesel, alternative fuel, or heavy-duty pilot ignition 

engine, certified to the 2007 or current model year on-road engine standards or Tier 4 

off-road engine standards. Another option is to use a pre-2007 model year certified onroad engine or a certified Tier 2 or Tier 3 off-road engine and apply the highest level 

VDECS available. The last option is to use a pre-Tier 1 off-road engine or a certified 

Tier 1 off-road engine and install the highest level VDECS available. If either of the two 

options requiring VDECS is chosen, an additional compliance step may be necessary, 

depending on the category of equipment and the level of VDECS used. For Basic 

Container Handling and Bulk Cargo Handling Equipment, the additional compliance 

requirement is to replace the engine with a Tier 4 off-road engine or install a Level 3 

VDECS by December 31, 2015. For RTG cranes, the additional compliance 

requirement is the same, but the compliance date is either December 31, 2015, or 

model year plus 12 years, whichever is later. More detail is provided in the discussion 

of the requirements. 

 

5

 While forklifts are used to handle both containerized and bulk cargo, for the purposes of this regulation, 

they are considered to be part of the Basic Container Handling equipment category. 
IV - 3 

The proposal includes provisions that allow qualified owners or operators to delay 

compliance with the in-use performance standards if an engine is within one year of 

retirement, if no VDECS are available, if an experimental diesel PM emission control 

strategy is used, if there are equipment manufacturer delivery delays, or for yard trucks 

that received incentive funding from public agencies to apply VDECS by the end of 

2005 with minimum use requirements. The maximum delay depends on the compliance 

extension granted. 

The proposal also includes an alternative compliance plan (ACP) option for owners and 

operators of non-yard truck cargo handling equipment that would allow them to 

demonstrate that equivalent emission reductions can be achieved through the use of 

alternative strategies. 

Recordkeeping and reporting requirements are also defined in the proposed regulation. 

Owners and operators would be required to maintain records for all mobile cargo 

handling equipment, affix a label to each vehicle (or use an alternative method 

approved by the Executive Officer) with the compliance strategy used or planned 

compliance date, submit a compliance plan and annual statement of compliance for 

their mobile cargo handling equipment, and perform annual reporting by submitting to 

the ARB their contact information and location of their equipment. These requirements 

would allow staff to monitor the implementation of the regulation and provide more 

accurate estimates of pollutant reductions. 

B. Discussion of the Proposed Regulation 

 Purpose

As specified in subsection (a) of the proposed regulation, the purpose of the regulation 

is to reduce diesel PM and criteria pollutant emissions from CI mobile cargo handling 

equipment that operate at ports and intermodal rail yards in California. 

 Applicability

As specified in subsection (b) of the proposed regulation, the regulation would apply to 

anyone who sells, offers for sale, leases, rents, purchases, owns, or operates any CI 

mobile cargo handling equipment that operates at a port or intermodal rail yard in 

California. This would include shipping terminal owners or operators and rail terminal 

owners or operators who either operate their own equipment or contract stevedoring or 

cargo handling services with a company that supplies its own cargo handling 

equipment. In addition, the regulation would apply to contracted companies that supply 

their equipment to terminal owners or operators. 

 Exemptions

Clarifications on applicability are included here in the discussion regarding exemptions. 

The regulation would not apply to mobile cargo handling equipment that is not operated 
IV - 4 

at a port or intermodal rail yard in California. A port is defined in the regulation as a 

facility used for water-borne commerce. While there are many publicly owned or 

operated ports in California, there are also several that are owned and operated by 

private parties. A port can simply mean a terminal that has a dock or other means of 

accepting water-borne cargo or loading cargo onto a vessel that will travel via waterway. 

An intermodal rail yard is defined as a facility where cargo is transferred to or from a 

train and any other form of conveyance, such as train to ship, ship to train, train to truck, 

or truck to train. ARB staff are in the process of developing a general off-road engine 

regulation proposal that will apply to cargo handling equipment that operate at facilities 

other than ports and intermodal rail yards, such as distribution centers and warehouses. 

Cargo handling equipment or vehicles that do no handle cargo at any time but are 

operated at a port or intermodal rail yard for purposes of transporting personnel or 

delivering fuel are exempt from meeting the performance requirements of the regulation. 

However, owners or operators of this equipment are still required to report the 

equipment to the Air Resources Board. Examples of equipment to which this exemption 

might apply may include fuel delivery trucks operating solely on the terminal to deliver 

fuel to terminal equipment and vans and buses used to transport personnel. 

The requirements of the regulation also do not apply to portable CI engines. Portable 

engines are defined as engines that are designed and capable of being carried or 

moved from one location to another. Mobile cranes and sweepers may have auxiliary 

engines that would be considered portable CI engines. 

 Definitions

The proposed regulation provides definitions of all terms that are not self-explanatory. 

There are 56 definitions to help clarify and enforce the regulation requirements. Most of 

the definitions listed in subsection (d) of the proposed regulation were developed by 

staff, with input from the public during workshops and workgroup meetings. Staff 

working on this regulation also coordinated with staff working on other diesel PM 

regulations to provide consistency where it was practical. Please refer to Appendix A, 

subsection (d) for a list of definitions. 

 Requirements

As specified in subsection (e), the proposed regulation would require newly purchased, 

leased, or rented mobile cargo handling equipment to meet performance standards. Inuse equipment would also be required to meet performance standards, which vary by 

equipment type. The requirements are briefly discussed below. 

1. Newly Purchased, Leased, or Rented Equipment 

As of January 1, 2007, newly purchased, leased, or rented (new) equipment that has 

been registered as an on-road vehicle with the Department of Motor Vehicles (DMV) 

would be required to meet the certified on-road emission standards, which are specified 
IV - 5 

in title 13, California Code of Regulations (CCR), section 1956.8, for the year 

purchased, leased, or rented. New yard trucks that are not registered motor vehicles 

must meet either the 2007 or current model year certified on-road engine standards or 

the certified off-road final Tier 4 standards for the rated horsepower. New non-yard 

truck equipment that are not registered motor vehicles must meet either the 2007 or 

current model year certified on-road engine standards or the certified off-road Tier 4 

standards for the rated horsepower and model year of the year purchased, leased, or 

rented. However, if that is not available for the specific non-yard truck equipment type 

and application, the highest level certified off-road engine for the rated horsepower and 

model year of the year purchased, leased, or rented, and installation of the highest 

available level VDECS within one year is required. If no VDECS is available during the 

initial year of operation, installation would be required within six months after VDECS 

becomes available. 

2. In-Use Yard Trucks 

The proposed regulation would require owners or operators of in-use yard trucks to 

meet one of three performance standards, which are considered to be BACT for this 

type of mobile cargo handling equipment: 1) use an engine certified to the 2007 or later 

on-road emission standards for the model year purchased; 2) use an engine certified to 

the final Tier 4 off-road emission standards for the rated horsepower; or 3) install 

VDECS that would result in diesel PM and NOx emissions that are equivalent to or 

lower than the certified final Tier 4 off-road emission standards for an engine with same 

horsepower rating. 

The performance standards are based on the 2007 certified on-road engines, with 

which the Tier 4 certified off-road engines eventually harmonize by 2015. Staff 

considered engine model year and diesel PM and NOx emission rates, with and without 

VDECS, when determining the performance standards and compliance dates for in-use 

yard trucks6

. Figure IV-1 shows the diesel PM emission rate differences between the 

model years and configurations. 

 

6

 Pre-2003 model year off-road yard trucks are considered to be either uncontrolled or Tier 1 engines, 

which means their diesel PM emission rates are 0.40 g/bhp-hr or greater. With a Level 1 VDECS 

(25 percent PM reduction) or Level 2 VDECS (50 percent PM reduction), their emission rates are at least 

0.30 g/bhp-hr and 0.20 g/bhp-hr, respectively. In comparison, 2003-2006 model year off-road yard trucks 

(Tier 2 or Tier 3) have a diesel PM emission rate of 0.15 g/bhp-hr. With a Level 1 or Level 2 VDECS, the 

rates drop to 0.11 g/bhp-hr and 0.075 g/bhp-hr, respectively, which is equivalent to a pre-2007 certified 

on-road yard truck with a Level 1 VDECS. In comparison, a 2007 model year certified on-road yard truck 

emits only 0.01 g/bhp-hr PM. 
IV - 6 

0

0.05

0.1

0.15

0.2

0.25

0.3

0.35

0.4

1996-2002 Off-road

w/Level 1 VDECSw/Level 2 VDECSw/Level 3 VDECS

2003-2006 Off-road

w/Level 1 VDECSw/Level 2 VDECSw/Level 3 VDECS

2004-2006 On-road

w/Level 1 VDECSw/Level 2 VDECSw/Level 3 VDECS

2007-2010 On-road

Diesel PM (g/bhp-hr)

Figure IV-1: Diesel PM Emission Rates for Yard Trucks with Off-Road and OnRoad Engines with and without VDECS 

Note: The diesel PM emission standard for Tier 4 off-road engines is equivalent to the 2007 and later 

on-road engines. Tier 4 for yard truck engines begins in 2011. 

In addition to large reductions in diesel PM emissions, the 2007 and 2010 on-road 

engines also have a large NOx benefit. NOx emission rates go from 6.9 g/bhp-hr for 

1996 through 2002 model year off-road engines to 0.2 g/bhp-hr for 2010 model year 

on-road engines. Figure IV-2 shows the emission rates for the off-road and on-road 

engines for each model year group. 
IV - 7 

Figure IV-2: NOx Emission Rates for Yard Trucks with Off-Road and On-Road 

Engines 

Notes: 

1. The NOx standard for 2003 through 2005 model year off-road yard trucks is 4.6 g/bhp-hr. The NOx 

standard changes for 175-299 hp off-road engines in 2006 (Tier 3) to 2.7 g/bhp-hr. 

2. The NOx standard shown for the 2007 on-road engines is a weighted average, since 50 percent of 

these engines must meet 0.2 g/bhp-hr NOx in 2007. 

3. The NOx standard for early (interim) Tier 4 off-road yard truck engines is between 1.5 and 

2.5 g/bhp-hr; the final Tier 4 NOx standard for yard trucks, which begins in 2014, is 0.30 g/bhp-hr. 

The compliance dates for in-use yard trucks vary based on the engine certification (offroad or on-road), the model years, whether or not VDECS have been installed, and 

whether the owners or operators have more than three yard trucks in their fleets. Fleets 

of four or more yard trucks would have a phased-in compliance schedule, which would 

allow them to spread out the compliance over a period of one to three years. Yard 

trucks that have VDECS or certified on-road engines installed as of December 31, 2006, 

would be given an additional year to comply with the in-use performance standards. 

The compliance schedules for in-use yard trucks are listed below in Tables IV-1 and 

IV-2. Fleets of four or more yard trucks have initial compliance dates that are the same 

as the compliance dates for fleets of three or less. 

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

5.5

6

6.5

7

1996-2002 Off-road 2003-2006 Off-road 2004-2006 On-road 2007 On-road 2010 On-road

NOx (g/bhp-hr)
IV - 8 

Table IV-1: Compliance Schedule for In-Use Yard Truck Fleets of Three or Less 

Off-road without VDECS Installed by 

December 31, 2006 

 Off-road with VDECS Installed by 

December 31, 2006 

Model Year Compliance Deadline Model Year Compliance Deadline 

Pre-2003 Dec. 31, 2007 Pre-2003 Dec. 31, 2008 

2003 Dec. 31, 2010 2003 Dec. 31, 2011 

2004 Dec. 31, 2011 2004 Dec. 31, 2012 

2005 Dec. 31, 2012 2005 Dec. 31, 2013 

2006 Dec. 31, 2013 2006 Dec. 31, 2014 

 

On-road without VDECS Installed by 

December 31, 2006 

 On-road with VDECS Installed by 

December 31, 2006 

Model Year Compliance Deadline Model Year Compliance Deadline 

Pre-2000 Dec. 31, 2007 Pre-2000 Dec. 31, 2008 

2000 Dec. 31, 2008 2000 Dec. 31, 2009 

2001 Dec. 31, 2009 2001 Dec. 31, 2010 

2002 Dec. 31, 2010 2002 Dec. 31, 2011 

2003 Dec. 31, 2011 2003 Dec. 31, 2012 

2004 Dec. 31, 2012 2004 Dec. 31, 2013 

2005 Dec. 31, 2013 2005 Dec. 31, 2014 

2006 Dec. 31, 2014 2006 Dec. 31, 2015 
IV - 9 

Table VI-2: Compliance Schedule for In-Use Yard Truck Fleets of Four or More 

Off-road without VDECS Installed by 

December 31, 2006 

 

Off-road with VDECS Installed by 

December 31, 2006 

Model 

Year 

% of Model Year Compliance 

Deadline 

Model 

Year 

% of Model Year Compliance 

Deadline 

Greater of 3 or 50% Dec. 31, 2007 Greater of 3 or 50% Dec. 31, 2008 Pre-2003 

100% Dec. 31, 2008 

Pre-2003 

100% Dec. 31, 2009 

Greater of 3 or 25% Dec. 31, 2010 Greater of 3 or 25% Dec. 31, 2011 

2003 50% Dec. 31, 2011 50% Dec. 31, 2012 

100% Dec. 31, 2012 

2003 

100% Dec. 31, 2013 

Greater of 3 or 25% Dec. 31, 2011 Greater of 3 or 25% Dec. 31, 2012 

2004 50% Dec. 31, 2012 50% Dec. 31, 2013 

100% Dec. 31, 2013 

2004 

100% Dec. 31, 2014 

Greater of 3 or 25% Dec. 31, 2012 Greater of 3 or 25% Dec. 31, 2013 

2005 50% Dec. 31, 2013 50% Dec. 31, 2014 

100% Dec. 31, 2014 

2005 

100% Dec. 31, 2015 

Greater of 3 or 25% Dec. 31, 2013 Greater of 3 or 25% Dec. 31, 2014 

2006 50% Dec. 31, 2014 50% Dec. 31, 2015 

100% Dec. 31, 2015 

2006 

100% Dec. 31, 2016 

On-road without VDECS Installed by 

December 31, 2006

On-road with VDECS Installed by 

December 31, 2006 

Model 

Year 

% of Model Year Compliance 

Deadline 

Model 

Year 

% of Model Year Compliance 

Deadline 

Greater of 3 or 25% Dec. 31, 2007 Greater of 3 or 25% Dec. 31, 2008 

Pre-2000 50% Dec. 31, 2008 50% Dec. 31, 2009 

100% Dec. 31, 2009 

Pre-2000 

100% Dec. 31, 2010 

Greater of 3 or 25% Dec. 31, 2008 Greater of 3 or 25% Dec. 31, 2009 

2000 50% Dec. 31, 2009 50% Dec. 31, 2010 

100% Dec. 31, 2010 

2000 

100% Dec. 31, 2011 

Greater of 3 or 25% Dec. 31, 2009 Greater of 3 or 25% Dec. 31, 2010 

2001 50% Dec. 31, 2010 50% Dec. 31, 2011 

100% Dec. 31, 2011 

2001 

100% Dec. 31, 2012 

Greater of 3 or 25% Dec. 31, 2010 Greater of 3 or 25% Dec. 31, 2011 

2002 50% Dec. 31, 2011 50% Dec. 31, 2012 

100% Dec. 31, 2012 

2002 

100% Dec. 31, 2013 

Greater of 3 or 25% Dec. 31, 2011 Greater of 3 or 25% Dec. 31, 2012 

2003 50% Dec. 31, 2012 50% Dec. 31, 2013 

100% Dec. 31, 2013 

2003 

100% Dec. 31, 2014 

Greater of 3 or 25% Dec. 31, 2012 Greater of 3 or 25% Dec. 31, 2013 

2004 50% Dec. 31, 2013 50% Dec. 31, 2014 

100% Dec. 31, 2014 

2004 

100% Dec. 31, 2015 

Greater of 3 or 25% Dec. 31, 2013 Greater of 3 or 25% Dec. 31, 2014 

2005 50% Dec. 31, 2014 50% Dec. 31, 2015 

100% Dec. 31, 2015 

2005 

100% Dec. 31, 2016 

Greater of 3 or 25% Dec. 31, 2014 Greater of 3 or 25% Dec. 31, 2015 

2006 50% Dec. 31, 2015 50% Dec. 31, 2016 

100% Dec. 31, 2016 

2006 

100% Dec. 31, 2017 
 IV - 10 

For fleets of four or more yard trucks, the percentage of yard trucks (25 percent, 

50 percent, or 100 percent) that must meet the performance requirements is determined 

based on the total population of yard trucks for a specific model year or model year 

group (i.e., pre-2003) that exist in the owner’s or operator’s yard truck fleet at the time of 

the first compliance deadline for that model year or model year group. If the number of 

yard trucks is not a whole number, conventional rounding practices apply (i.e., round 

down if less than 0.5; round up if 0.5 or greater).

3. In-Use Non-Yard Truck Equipment 

The proposed regulation would require owners and operators of in-use non-yard truck 

equipment to meet a selection of performance standards (Compliance Options), which 

are based on BACT, and which vary based on the category of equipment. For the 

purpose of this regulation, BACT for non-yard truck cargo handling equipment is a menu 

of compliance options because these equipment types are diverse in their design, 

engines, operation, retrofit control technologies that are available to them, the level of 

risk posed, capital costs, and cost-effectiveness. As such, BACT can vary greatly even 

within each category or type of equipment. 

In determining the BACT compliance options, staff considered the feasibility of using 

certified on-road engines, technological feasibility of emission controls and availability of 

VDECS, ability for engine repowering, average useful life, associated health risks, and 

economic feasibility of replacing equipment. Staff has defined three categories of nonyard truck equipment, and for each category, three BACT compliance options are 

offered. The categories and their corresponding Compliance Options are discussed in 

the sections that follow. 

Basic Container Handling Equipment 

Basic Container Handling equipment consist of top handlers, side handlers, reach 

stackers, forklifts, straddle carriers, and any other equipment type (except RTG cranes) 

that handles cargo containers. The proposed regulation requires the owner or operator 

to select one of three BACT compliance options. One option is to use an engine or 

power system, including a diesel, alternative fuel, or heavy-duty pilot ignition engine, 

certified to the 2007 or later model year on-road engine standards or Tier 4 off-road 

engine standards for the rated horsepower and model year of the year manufactured. 

Another option is to use a pre-2007 model year certified on-road engine or a certified 

Tier 2 or Tier 3 off-road engine for the rated horsepower and model year of the year 

manufactured and apply the highest level VDECS available. If the highest level VDECS 

applied is a Level 1, then by December 31, 2015, the engine must either be replaced to 

a Tier 4 certified off-road engine or a Level 3 VDECS must be installed. Another option 

is to use a pre-Tier 1 off-road engine or a certified Tier 1 off-road engine for the rated 

horsepower and model year of the year manufactured and install the highest level 

VDECS available. If the highest level VDECS is a Level 1 or 2, then by 

December 31, 2015, the engine must either be replaced to a Tier 4 certified off-road 

engine, or a Level 3 VDECS must be installed. Figure IV-3 graphically displays the 
 IV - 11 

Compliance Options for Basic Container Handling Equipment. The compliance dates 

for all non-yard truck cargo handling equipment are listed in Table IV-3. 

Figure IV-3: Basic Container Handling Equipment Compliance Options 

 Bulk Cargo Handling Equipment 

Bulk Cargo Handling equipment consist of dozers, loaders, excavators, mobile cranes, 

sweepers, railcar movers, aerial lifts, and any other equipment type (except forklifts) that 

handles non-containerized or bulk cargo. The proposed regulation requires the owner 

or operator to select one of three BACT compliance options. One option is to use an 

engine or power system, including a diesel, alternative fuel, or heavy-duty pilot ignition 

engine, certified to the 2007 or later model year on-road engine standards or Tier 4 offroad engine standards for the rated horsepower and model year of the year 

manufactured. While the 2007 model year certified on-road engine is not available in 

high horsepower ranges, it may be available for some of the equipment in this category 

in the lower horsepower ranges. Another option is to use a pre-2007 model year 

certified on-road engine or a certified Tier 2 or Tier 3 off-road engine for the rated 

horsepower and model year of the year manufactured and apply the highest level 

VDECS available. If the highest level VDECS applied is a Level 1, then by 

December 31, 2015, the engine must either be replaced to a Tier 4 certified off-road 

engine or a Level 3 VDECS must be installed. Another option is to use a pre-Tier 1 offroad engine or a certified Tier 1 off-road engine for the rated horsepower and model 

year of the year manufactured and install the highest level VDECS available. If the 

highest level VDECS is a Level 1, then by December 31, 2015, the engine must either 
 IV - 12 

be replaced to a Tier 4 certified off-road engine, or a Level 3 VDECS must be installed. 

Figure IV-4 graphically displays the Compliance Options for Bulk Cargo Handling 

Equipment. The compliance dates for all non-yard truck cargo handling equipment are 

listed in Table IV-3. 

Figure IV-4: Bulk Cargo Handling Equipment Compliance Options 

 RTG Cranes 

Because of their unique operation, size, costs, effective life, and retrofit options, RTG 

cranes are in a category of their own. While there is a limited selection of VDECS 

currently available to this category of equipment, the ARB is coordinating a study to 

identify and demonstrate high efficiency retrofit emission control systems for RTG 

cranes, top handlers, and side handlers that will lead to verification. Additional 

information on this project is available in Appendix H. 

As with the other two categories of non-yard truck equipment, the proposed regulation 

requires the owner or operator to select one of three BACT compliance options for RTG 

cranes. One option is to use an engine or power system, including a diesel, alternative 

fuel, or heavy-duty pilot ignition engine, certified to the 2007 or later model year on-road 

engine standards or Tier 4 off-road engine standards for the rated horsepower and 

model year of the year manufactured. While the 2007 model year certified on-road 

engine is not available for most RTG cranes because of their high horsepower ranges, it 

may be available for some of the smaller horsepower RTG cranes. Another option is to 

use a pre-2007 model year certified on-road engine or a certified Tier 2 or Tier 3 off-
 IV - 13 

road engine for the rated horsepower and model year of the year manufactured and 

apply the highest level VDECS available. Another option is to use a pre-Tier 1 off-road 

engine or a certified Tier 1 off-road engine for the rated horsepower and model year of 

the year manufactured and install the highest level VDECS available. If the highest 

level VDECS is a Level 1 or Level 2, then the engine must either be replaced to a Tier 4 

certified off-road engine, or a Level 3 VDECS must be installed, by either 

December 31, 2015, or model year plus 12 years, whichever is later. Figure IV-5 

graphically displays the Compliance Options for RTG Cranes. The compliance dates 

for all non-yard truck cargo handling equipment are listed in Table IV-3. 

Figure IV-5: RTG Crane Compliance Options 

The compliance schedule listed in Table IV-3 is based on engine model year and size of 

the fleet. The oldest engines would be replaced first, and owners or operators of more 

than three non-yard truck equipment would have a phased-in compliance schedule, 

allowing more time to achieve compliance for 100 percent of their fleet. 
 IV - 14 

Table IV-3: Compliance Schedule for In-Use Non-Yard Truck Mobile Cargo 

Handling Equipment 

The percentage of non-yard truck equipment (25 percent, 50 percent, or 100 percent) 

that must meet the performance requirements is determined based on the total 

population of non-yard truck equipment for a specific model year group (i.e., pre-1988) 

that exist in the owner’s or operator’s non-yard truck fleet at the time of the first 

compliance deadline for that model year group. If the number of non-yard truck 

equipment is not a whole number, conventional rounding practices apply (i.e., round 

down if less than 0.5; round up if 0.5 or greater).

 Fuel Requirements

The proposed regulation requires the use of specified fuels, including CARB diesel fuel, 

an alternative fuel, an alternative diesel fuel that meets the requirements of the 

Verification Procedure, CARB diesel fuel used with fuel additives that meets the 

requirements of the Verification Procedure, or any combination of the above. In 

addition, owners or operators who choose to use alternative diesel fuels in order to 

meet the performance requirements of the proposed regulation are required to meet the 

recordkeeping requirements, use only alternative diesel fuels that are VDECS, identify 

the fuel on a label near the vehicle’s fill spout, and comply with the performance 

requirements within 10 days of discontinuing the use of the alternative diesel fuel. 

Owners or operators that retrofit mobile cargo handling equipment with a VDECS that 

requires certain fuel properties to be met in order to achieve the required PM reductions 

or PM emissions must only use fuel that meets these specifications. The same applies 

to the use of a VDECS that requires certain fuel properties to be met in order to prevent 

damage to the VDECS or to prevent increases in pollutants. 

 Compliance Extensions

The proposed regulation includes several possible compliance extensions for specific 

circumstances. Subsection (f) of the proposed regulation in Appendix A details the 

 

7

 Compliance date refers to December 31st of the year indicated. 

Compliance Date7

Non-Yard Truck Fleets of 4 or More 

Engine Model 

Years 

Non-Yard Truck 

Fleets of 3 or Fewer 

First 3 or 25% 

(whichever is greater) 50% 75% 100% 

pre-1988 2007 2007 2008 2009 2010 

1988-1995 2008 2008 2009 2010 2011 

1996-2002 2009 2009 2010 2011 2012 

2003-2006 2010 2010 2011 2012 2013 
 IV - 15 

requirements for each compliance extension. Unless specifically stated, compliance 

extensions may not be combined or used consecutively. 

Engine Near Retirement

Engines that are within one year of retirement are eligible for a one-year compliance 

extension and, therefore, would not have to meet the in-use requirements of 

subsection (e). The owner or operator would have to demonstrate that their equipment 

did indeed retire on or before the assigned retirement date to avoid penalties for 

noncompliance. 

No Verified Diesel Emission Control Strategy 

Non-yard truck mobile cargo handling equipment that do not have the availability of 

VDECS may be eligible for an annual compliance extension up to two years. Owners or 

operators would be required to comply with the in-use requirements of subsection (e) for 

all other equipment before applying this extension.

 Use of Experimental Diesel Particulate Matter Emission Control Strategies 

Because the availability of VDECS is limited, and because those that are verified may 

not always be feasible for specific equipment types or applications, staff determined that 

a compliance extension for the use of non-verified emission control strategies was an 

appropriate option to maintain flexibility in complying with the performance standards, 

while at the same time, continuing to achieve emission reductions. If no VDECS is 

available for a non-yard truck mobile cargo handling equipment engine or if the 

available VDECS is not feasible for the specific equipment or application, the owner or 

operator can apply for a compliance extension to use an experimental diesel PM 

emission control strategy. Feasibility may be determined based on one or more criteria, 

which could include technology, economics, operations, safety, contractual agreements, 

infrastructure, systems compatibility, training, maintenance, and security issues. The 

application process includes submitting engine and emission control test data to 

demonstrate at least a Level 1 (25 percent diesel PM reduction) control. An owner or 

operator must apply each year if they wish to continue receiving the extension, but the 

experimental controls may not be used past December 31, 2015. At the end of the 

experiment, the owner or operator would be required to comply with the in-use non-yard 

truck equipment requirements in subsection (e) of the proposed regulation within six 

months of the end of the compliance extension period. 

Equipment Manufacturer Delays 

An owner or operator who has, at least six months prior to their required compliance 

date, purchased or entered into contractual agreement to purchase new equipment in 

order to meet the requirements of the regulation, but has not received the equipment by 

their compliance date due to manufacturer delays, would be considered to be in 
 IV - 16 

compliance until the equipment is received. This compliance extension can be used 

following any other compliance extension except for an engine near retirement. 

Minimum Use Requirements 

Yard trucks that were retrofitted with VDECS prior to December 31, 2005, using 

incentive funding from public agencies (i.e., NOx and PM Bank or Carl Moyer Program) 

may be eligible for a compliance extension if the funding program stipulated minimum 

use requirements that would expire after the required compliance date. The maximum 

compliance extension could not exceed three years from the VDECS installation date. 

 Diesel Emission Control Strategy Special Circumstances

For mobile cargo handling equipment that has VDECS installed in order to comply with 

the in-use requirements, the proposed regulation contains provisions in the event of a 

failure or damage to the VDECS. If the failure or damage occurs within the warranty 

period and cannot be repaired, the owner or operator would be required to replace the 

VDECS with either the same level VDECS, or choose another Compliance Option, 

within 90 days. If the failure or damage occurs outside of the warranty period and 

cannot be repaired, the owner or operator would be required to return to the original 

Compliance Options and bring the equipment into compliance within 90 days. 

 Alternative Compliance Plan for Non-Yard Truck Cargo Handling Equipment

As stated previously, the need for flexibility is important when considering options to 

reduce emissions from non-yard truck mobile cargo handling equipment. The proposed 

regulation includes an alternative compliance plan (ACP) option for owners and 

operators of non-yard truck cargo handling equipment that would allow them to 

demonstrate that equivalent emission reductions can be achieved through the use of 

alternative strategies. Alternative strategies can include equipment engine 

modifications, exhaust treatment control, engine repowering, equipment replacement, 

the use of alternative fuels or fuel additives, and operational controls. Applications for 

the ACP must be approved by the Executive Officer, and until such approval is granted, 

the owner or operator would be required to meet the performance requirements in 

subsection (e)(3). 

 Recordkeeping and Reporting Requirements

As specified in subsections (i) and (j) of the proposed regulation, the proposal includes 

provisions for mobile cargo handling equipment owner or operator recordkeeping and 

reporting that would allow staff to obtain more accurate information on the number of 

mobile cargo handling equipment in California, to monitor the implementation of the 

regulation, to estimate pollutant reductions based on compliance choices the owners or 

operators make, and to facilitate inspections by ARB’s Enforcement Division. Beginning 

in 2007, owners or operators would be required to report mobile cargo handling 

equipment inventory information (e.g., make, model, serial number, etc.), where they 
 IV - 17 

operate, and how and when they come into compliance with the in-use requirements of 

the regulation. Owners or operators would also be required to affix a label to each 

equipment that will display information such as the engine model year, compliance 

strategy used or the planned compliance date, engine certification (e.g., off-road or onroad), or experimental diesel emission control strategy test dates. An alternative 

approach to using labels may be used if approved by the Executive Officer. 

Beginning January 31, 2007, owners or operators would be required to submit a 

compliance plan to the Executive Officer. The plan would identify how the owner or 

operator plans to meet the in-use requirements of the regulation. The plan is not 

binding and can be changed prior to the compliance date(s). 

For owners and operators of off-road mobile equipment that do not handle cargo at any 

time but is used to transport personnel or deliver fuel, a one-time reporting of that 

equipment is required by January 31, 2007. The information gathered from this 

reporting will help staff to determine if additional regulatory requirements are 

appropriate for this equipment. 

The proposed regulation currently requires submittals to the ARB by mail, however, staff 

plans to develop the potential for electronic report submittals in time for owner or 

operator reporting deadlines. In addition, staff plans to conduct outreach to owners and 

operators to explain and clarify these reporting requirements. 

 Right of Entry, Prohibitions, and Severability

The proposed regulation includes Right of Entry, Prohibitions, and Severability clauses. 

As specified in subsection (k), the Right of Entry clause allows an ARB agent or 

employee to enter the premises of a port or intermodal rail yard where mobile cargo 

handling equipment operate in order to inspect the equipment that are subject to the 

regulation. 

As specified in subsection (l) of the proposed regulation, the Prohibitions clause states 

that people engaged in the State in the business of selling, renting, or leasing new or 

used mobile cargo handling equipment are prohibited from selling, importing, delivering, 

purchasing, receiving, or otherwise acquiring a new or used mobile cargo handling 

equipment for the purpose of selling, renting, or leasing, that does not meet the 

performance requirements of the regulation. 

As specified in subsection (m) of the proposed regulation, the Severability clause 

ensures that if any portion of the regulation is deemed invalid or unconstitutional, that 

portion would be deemed a separate, distinct, and independent provision, and will not 

affect the validity of the remaining portions of the regulation. 

 
 IV - 18 

 Submittal of Documents

Documents that are required to be submitted to the ARB may be submitted by mail or 

by an alternative method approved by the Executive Officer, which may allow for 

electronic submittals in the future. The address for mailing documents to the ARB is 

included in subsection (n) of the proposed regulation. 

C. Alternatives Considered 

The Government Code section 11346.2 requires the ARB to consider and evaluate 

reasonable alternatives to the proposed regulation and provide the reasons for rejecting 

those alternatives. ARB staff evaluated three alternative strategies to the current 

proposal. Based on the analysis, none of the alternative control strategies were 

considered more effective than the proposed regulation. Full implementation of the 

proposed regulation is necessary to achieve ARB’s goal, as described in the Diesel Risk 

Reduction Plan, to reduce by 85 percent diesel PM emissions and associated potential 

cancer risks by 2020. (ARB, 2000) The proposed regulation provides owners or 

operators of mobile cargo handling equipment with flexibility in determining the most 

cost-effective control strategy that will meet the proposed emission standards and 

operational requirements for their operation. 

This section discusses each of the three alternatives and provides reasons for rejecting 

those alternatives. 

Do Not Adopt This Regulation: Rely on New Engine Standards and Voluntary 

Programs

One alternative would be to do nothing and rely on existing governmental programs and 

voluntary programs. Beginning in 1996, manufacturers and vendors of diesel engines 

have been subject to U.S. EPA's nonroad (off-road) diesel emission regulations 

(40 CFR Part 89). The standards are tiered and the date upon which each tier takes 

effect depends on the engine size. As of January 1, 2000, all engine sizes were subject 

to Tier 1 standards. In 2004, the U.S. EPA adopted new engine standards (Tier 4) for 

off-road diesel engines that will begin in 2008, but not be fully implemented until 2015. 

These stringent standards will significantly reduce emissions of PM and NOx, which 

contribute to adverse public health impacts. In addition, U.S. EPA's rule requires offroad diesel engines to use diesel fuel with a maximum sulfur content of 500 ppm in 

2007 and 15 ppm in 2010. (EPA, 2003) California has harmonized its new engine 

standards for off-road diesel engines with the U.S. EPA off-road standards. 

However, the U.S. EPA’s Tier 4 new engine standards do not address existing in-use 

diesel engines, and the new standards would be implemented on a phased-in schedule 

based on engine size beginning in 2008 through 2015. Additionally, the federal 

standards offer various alternatives to demonstrate (use of emission reduction credits) 

or delay compliance to certain phase-in schedules. These critical implementation 

measures will not produce the greatest potential reductions in diesel PM emissions in 
 IV - 19 

the shortest timeframe. Further, the long useful life of diesel engines and the lack of 

stringent standards for in-use off-road diesel engines will significantly limit the potential 

reduction in ambient concentrations of diesel PM and associated cancer and noncancer 

health risks. ARB staff does not recommend this alternative because it would result in 

less reduction in diesel PM and NOx emissions and fewer public health benefits than 

the proposed regulation. 

While federal, State, and local programs have been developed to encourage lesspolluting diesel engines, the effects of these programs are expected to be far less 

significant than the proposed regulation. The U.S. EPA’s Voluntary Diesel Retrofit 

Program, which addresses pollution from diesel construction equipment and heavy-duty 

on-road vehicles, applies only to a very small fraction of cargo handling equipment. 

ARB’s Carl Moyer Incentive Funding Program, which provides funds on an incentivebasis for the incremental cost of cleaner than required engines and equipment, has 

focused primarily on agricultural equipment. And, while the voluntary retrofit programs 

at the Ports of Long Beach, Los Angeles, and Oakland have made great strides in 

reducing diesel PM emissions from the existing fleets of cargo handling equipment at 

their ports, they are local programs whose reductions will not be realized elsewhere in 

the State, and the level of emission reductions fall short of what is needed to protect 

public health. 

It is estimated that the proposed regulation will achieve an additional 744 tons reduction 

in diesel PM and an additional 18,310 tons reduction in NOx emissions beyond what 

voluntary measures would achieve. Therefore, ARB staff does not recommend this 

alternative. 

 Adopt Requirements for Yard Trucks Only

Another option would be to adopt requirements only for yard trucks and not address the 

non-yard truck equipment. While this option achieves emission reductions for one 

equipment type, it does not address the cargo handling equipment emissions at bulk 

cargo facilities or other equipment types at container facilities, both of which pose 

significant health risks. The full regulation would reduce diesel PM emissions by an 

estimated additional 241 tons and NOx emissions by an estimated additional 1,233 

tons. Therefore, ARB staff does not recommend this alternative. 
 IV - 20 

REFERENCES: 

(ARB, 2000) California Air Resources Board. Risk Reduction Plan to Reduce 

Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles; October 2000. 

(EPA, 2003) United States Environmental Protection Agency. Regulatory 

Announcement, Summary of EPA's Proposed Program for Low Emission Nonroad 

Diesel Engines and Fuel; April 2003. 
V - 1

V. TECHNOLOGICAL FEASIBILITY OF THE PROPOSED REGULATION 

There are a variety of technologies available to reduce diesel PM emissions from cargo 

handling equipment engines. Since the 1970's, much of the diesel emission control has 

been achieved through emission-conscious engine design. For example, emission 

improvements have included modifications in combustion chamber geometry, increased 

fuel injection pressure, and design for better fuel atomization and mixing with the air. 

(DieselNet, 1998) In the past 15 years, more development effort has been put into 

catalytic exhaust emission control devices for diesel engines, especially in the areas of 

particulate matter control. These developments have made the widespread commercial 

use of diesel exhaust emission controls feasible. (ARB, 2003a) 

In this chapter of the staff report, we provide descriptions of diesel PM emission control 

strategies currently available and projected to be available in the near future. We focus 

on those we believe will be employed to comply with the proposed regulation. 

Additional information on the wide variety of emission reduction options for diesel fueled 

engines is provided in the Diesel Risk Reduction Plan. (ARB, 2000) We also list actual 

in-use experience with diesel PM emission control strategies and clean fuels that cargo 

handling equipment engine operators are using currently. 

A. New Engine Standards 

Due to the efforts of the ARB and U.S. EPA in establishing new engine standards that 

reflect advanced technology options, replacing an older engine with a new one will 

usually result in significant emission reductions. The proposed regulation includes 

performance standards based on best available control technologies (BACT), which in 

many cases can include replacing an older engine with a cleaner, new engine through 

either repowering or equipment replacement. In the case of yard trucks in particular, 

accelerating the turnover to new on-road engines is a very effective means of achieving 

significant reductions in both diesel PM and NOx while maintaining economic feasibility 

(cost-effectiveness). Below we briefly discuss the current off-road and on-road new 

engine emission standards and how they can be part of the strategy for achieving 

emission reductions. 

Off-Road

Because of advancements that have been made in combustion technology and engine 

design, diesel engines today emit over 80 percent less PM and over 60 percent less 

NOx than they did in 1988. (Diesel, 2003) Beginning in 1996, all compression ignition 

(diesel) engine manufacturers have been subject to U.S. EPA’s nonroad (off-road) 

diesel emission regulation (40 CFR Part 89), which the ARB has subsequently adopted 

as well. The off-road engine emission standards are tiered (i.e., Tier 1, 2, 3, 4), and the 

date upon which each tier takes effect depends on the engine size (horsepower). As of 

January 1, 2000, all engine sizes were subject to Tier 1 standards. In 2006, all engine 

sizes will be subject to Tier 2, and in 2008, most engines sizes will be subject to Tier 3 

standards (engines less than 75 horsepower or greater than 750 horsepower do not 
V - 2

have a Tier 3 standard). These standards, which become increasingly more stringent 

with each subsequent tier, will result in the development of new, lower-emitting diesel 

engines in the future years. 

 

Tier 4 standards are divided into two stages: interim, which begins between 2008 and 

2012 for most engines, and final, which is effective for all off-road engines by 2015. The 

final Tier 4 standards will result in diesel engines that will be over 90 percent cleaner 

than 1988 vintage engines. Tier 4 requires most engines to meet a 0.01 g/bhp-hr diesel 

PM emission rate and a 0.3 to 0.5 g/bhp-hr NOx emission rate in the 2011-2015 

timeframe. ARB staff has worked closely with U.S. EPA to develop a harmonized 

federal and California program to more effectively control emissions from off-road 

equipment. ARB’s heavy-duty new engine regulation is found in title 13, California 

Code of Regulations, section 2423. When it has been feasible to do so, the Board has 

adopted a more stringent program than the federal program and adopted engine test 

procedures that more accurately measure emissions that occur during typical in-use 

driving conditions. 

Repowering, or replacing an existing engine with a new one, can provide the same 

emissions benefits as replacing the equipment, particularly when the new engine is a 

higher tier level (i.e., replacing a pre-Tier 1 engine with a Tier 2 or Tier 3 engine). In 

addition, repowering is often an attractive strategy for owners or operators of cargo 

handling equipment whose engines have reached their useful life before the other 

equipment components are ready for retirement. Repowering is most often 

accomplished on non-yard truck equipment (e.g., top handlers, side handlers, railcar 

movers, and rubber-tired gantry cranes) because their equipment replacement costs are 

much higher than the costs of repowering. While repowering to a Tier 2 or Tier 3 engine 

does not get the same benefits as a Tier 4 engine, it can make the engine more suitable 

to aftertreatment emission controls, and is therefore, one compliance option for nonyard truck cargo handling equipment. 

For owners or operators of some non-yard truck cargo handling equipment that choose 

to use retrofits for their initial compliance, an additional compliance step to replace the 

engines to meet Tier 4 standards at the end of 2015 is required. This strategy achieves 

both near-term and long-term reductions in diesel PM and NOx emissions. 

On-Road

On-road engines are a step ahead of off-road engines and are an even better emission 

reduction strategy for cargo handling equipment that can utilize them. In January 2001, 

U.S. EPA finalized its rule for new emission standards for 2007 and later model year onroad heavy-duty diesel engines and vehicles8

. The 2007 standards break new ground 

by setting emission standards that require aftertreatment-based technologies for all 

classes of heavy-duty diesel engines and vehicles. The adopted standards will reduce 

 

8

 U.S. EPA’s 2007 Final Rule on the Control of Emissions of Air Pollution from 2007 and Later Model Year 

Heavy-Duty Highway Engines and Vehicles; Revision of Light-Duty On-Board Diagnostics Requirements 

(66FR 5002, January 18, 2001). Referred to as U.S. EPA’s 2007 Final Rule or 2007 Final Rule. 
V - 3

exhaust emissions from new diesel-cycle engines meeting the 2004 standards by 

90 percent for NOx, 72 percent for NMHC, and 90 percent for PM. These emission 

standards, which are also applicable to both natural gas-fueled engines and liquefied 

petroleum gas-fueled engines derived from the diesel cycle engine, are shown below in 

Table V-1. The U.S. EPA adopted the requirements for heavy-duty gasoline-fueled 

engines (with implementation starting in 2008) at the same time it adopted emission 

standards for 2007 and later model year heavy-duty diesel engines. ARB adopted 

regulations to harmonize with the federal standards in 2002. 

Table V-1: Exhaust Emission Standards for 2007 and Later Model Year On-Road 

Heavy-Duty Diesel Engines/Vehicles 

Phase-In by Model Year* Pollutant Standard 

(g/bhp-hr) 2007 2008 2009 2010 

NOx 0.20 50% 100% 

NMHC 0.14 50% 100% 

PM10 0.01 100% 100% 100% 100% 

* represents percent of sales 

The Board approved the same phase-in schedules for the NOx, PM, and NMHC 

emission standards as adopted by U.S. EPA. The phase-in schedules, shown in 

Table V-1, represent the percentage of new engines produced for sale in California that 

are required to meet the more stringent emission standards beginning in 2007. Full 

implementation is required starting with the 2009 model year. 

On-road engines are currently available for some types of cargo handling equipment, 

particularly yard trucks. In fact, yard truck manufacturers have provided buyers the 

option to choose the on-road engine for several years with only a minor incremental 

cost differential. Since the 2007 on-road engines have the emission benefits up to eight 

years sooner than off-road engines, they are an effective strategy for achieving both 

near-term and long-term emission reductions. 

Test methods used to certify on-road engines are different than those for off-road 

engines. On-road engine methods use a transient duty cycle while off-road engine 

methods use a steady state duty cycle. ARB staff conducted testing, in partnership with 

the Port of Los Angeles and through the University of Riverside, of yard trucks equipped 

with both on-road and off-road engines, using an off-road duty cycle (C1). The emission 

rates from the off-road duty cycle were compared to the U.S. EPA certified on-highway, 

transient emission rates for this engine family. The comparison indicated the on-road 

engine’s emission rates were similar in both duty cycles, concluding that the off-road 

duty cycle did not increase the on-road engine emissions. Based on these results, staff 

believes the same will hold true for future model year on-road engines. Additional yard 

truck testing is being conducted which includes alternative fuels, data logging to 

evaluate the duty cycles, and in-use emission testing. Information on the test program 

can be found in Appendix E. 
V - 4

The proposed regulation provides an option for yard trucks and other applicable mobile 

cargo handling equipment types to use certified on-road engines. This is clearly 

technically feasible, as many yard trucks are already using on-road engines. Based on 

discussions with manufacturers, this option will continue to be available for future model 

year yard truck engines as well, even as the certified on-road engine standards 

strengthen in 2007 and again in 2010. (ARB, 2005c) Mobile cargo handling equipment 

operating with on-road engines are not required by the regulation to use any verified 

diesel emission control strategy. Chapter IV provides more information on the 

requirements of the proposed regulation. 

B. Diesel PM Exhaust Aftertreatment Emission Controls 

There are various advanced exhaust aftertreatment technologies commercially available 

that can provide significant reductions in diesel PM, particularly when combined with 

ultra low-sulfur diesel fuel. Several of these technologies have been verified by the 

ARB to reduce diesel PM emissions and are one option that owners and operators of 

non-yard truck cargo handling equipment can use to meet the performance 

requirements of the proposed regulation. (The verification procedure is discussed later 

in this chapter). While several VDECS are currently available for non-yard truck cargo 

handling equipment, the verification extends only to select model years and engine 

families. Therefore, flexibility in applying these and other emission control strategies is 

necessary and contributes to the technological feasibility of the proposed regulation. 

The proposal would allow owners and operators to apply for a compliance extension for 

the use of experimental diesel emission control technologies, which in turn, is expected 

to result in additional verifications. 

The principal technologies that have been successfully used to reduce diesel PM from 

diesel-fueled engines are diesel oxidation catalysts (DOCs), emulsified diesel fuel, and 

diesel particulate filters (DPFs). Since 2002, more than a thousand DOCs have been 

installed on many types of cargo handling equipment, primarily yard trucks, at the ports 

of Los Angeles, Long Beach, and Oakland. (ARB, POLA; ARB, POLB; ARB, Port of 

Oakland) Additionally, several DPFs have been installed on top handlers at the Port of 

Oakland. Flow-through filters, sometimes referred to as enhanced DOCs, are relatively 

new to the market but also show promise in reducing diesel PM from diesel-fueled 

engines. These aftertreatment emission control systems are briefly described below. 

Diesel Oxidation Catalysts

Diesel oxidation catalysts (DOCs) are the most common currently used form of diesel 

aftertreatment technology and have been used for compliance with the PM standards 

for some on-highway engines since the early 1990s. DOCs are generally referred to as 

“catalytic converters.” DOCs are devices attached to the engine exhaust system. They 

have chemicals lining them which catalyze the oxidation of carbonaceous pollutants – 

some of the soot emissions and a significant portion of the soluble organic fraction. 

These carbon-containing pollutants are oxidized to CO2 and water. The catalysts that 

are used are known as the platinum group metals (PGMs). These consist of platinum, 
V - 5

iridium, osmium, palladium, rhodium, and ruthenium. Platinum is best suited as the 

catalyst for diesel engine control devices; therefore, it appears that it will be the main 

catalyst used in diesel catalytic converters. (Kendall, 2002/2003) 

DOC effectiveness in reducing PM emissions is normally limited to about 30 percent of 

diesel PM. This is because the soluble organic fraction portion of diesel PM for modern 

diesel engines is typically less than 30 percent. Additionally, DOCs increase sulfate PM 

emissions by oxidizing the sulfur in fuel and lubricating oil, reducing the overall 

effectiveness of the catalyst. Limiting fuel sulfur levels to 15 ppm allows DOCs to be 

designed for maximum effectiveness (nearly 100 percent control of soluble organic 

fraction emissions). DOCs also reduce emissions of HC and CO with reported 

efficiencies of 76 percent and 47 percent respectively. (Khair, 1999) 

DOCs are also very effective at reducing the air toxic emissions from diesel engines. 

Test data shows that emissions of toxics such as polycyclic aromatic hydrocarbons 

(PAHs) can be reduced by more than 80 percent with a DOC. (DieselNet, 2002) 

Flow-Through Filters

Flow-through filter (FTF) technology is a relatively new technology for reducing diesel 

PM emissions. Unlike a DPF, in which only gasses can pass through the substrate, the 

FTF does not physically "trap" and accumulate PM. Instead, exhaust flows through a 

medium (such as wire mesh) that has a high density of torturous flow channels, thus 

giving rise to turbulent flow conditions. The medium is typically treated with an oxidizing 

catalyst that is able to reduce emissions of PM, HC, and CO, or used in conjunction with 

a fuel-borne catalyst. Any particles that are not oxidized with the FTF flow out with the 

rest of the exhaust and do not accumulate. 

The filtration efficiency of an FTF is lower than that of a DPF, but the FTF is much less 

likely to plug under unfavorable conditions, such as high PM emissions, low exhaust 

temperatures and older engines. The FTF, therefore, is a candidate for use in 

applications that are unsuitable for Diesel Particulate Filters (DPF). Currently, there are 

no verified FTF technologies. If verified, FTF technology could potentially fill an 

emission reduction role on older RTG cranes, construction equipment, and other 

engines where DPF’s would easily clog. 

Diesel Particulate Filters 

DPFs have been successfully used in many applications, including on-road, off-road 

applications, and prime and emergency engines, use of DPF’s in CHE equipment has 

been limited. In general, a DPF consists of a porous substrate that permits gases in the 

exhaust to pass through but traps the diesel PM. Diesel PM emission reductions in 

excess of 85 percent are possible, depending on the associated engine's baseline 

emissions, fuel sulfur content, and emission test method or duty cycle. In addition, up to 

a 90 percent reduction in CO and a 95 percent reduction in HC can also be realized with 

DPFs. (Allansson, 2000) Most DPFs employ some means to periodically regenerate 
V - 6

the filter, i.e., burn off the accumulated PM. In California, diesel-fueled school buses, 

emergency backup generators, solid waste collection vehicles, urban transit buses, 

medium-duty delivery vehicles, people movers, and fuel tankers trucks have been 

retrofitted with DPFs through various voluntary and regulatory mandated programs as 

well as demonstrations programs. Particulate filters can be either active or passive 

systems. 

Active DPFs use a source of energy beyond the heat in the exhaust stream itself to help 

regeneration. Active DPF systems can be regenerated electrically, with fuel burners, 

with microwaves, or with the aid of additional fuel injection to increase exhaust gas 

temperature. Some active DPFs induce regeneration automatically onboard the vehicle 

or equipment when a specified back pressure is reached. Others simply indicate when 

to start the regeneration process. Some active systems collect and store diesel PM 

over the course of a full day or shift and are regenerated at the end of the day of shift 

with the vehicle or equipment shut off. A number of the smaller filters are removed and 

regenerated externally at a "regeneration station." Because they have control over their 

regeneration and are not dependent on the heat carried in the exhaust, active DPFs 

have a much broader range of application and a much lower probability of getting 

plugged than passive DPFs. 

A passive DPF is one in which a catalytic material, typically a platinum group metal, is 

applied to the substrate. The catalyst lowers the temperature at which trapped PM will 

oxidize to temperatures periodically reached in diesel exhaust. No additional source of 

energy is required for regeneration, hence the term "passive." 

Field experience has indicated that the success or failure of a passive DPF is primarily 

determined by the average exhaust temperature at the filter's inlet and the rate of PM 

generated by the engine. These two quantities, however, are determined by a host of 

factors pertaining to both the details of the application and the state and type of engine 

being employed. As a result, the technical information that is readily accessible can 

sometimes serve as a guide, but it may be insufficient to determine whether a passive 

DPF will be successful in a given application. (ARB, 2002) 

With regard to estimating average exhaust temperature in actual use, commonly 

documented engine characteristics such as the exhaust temperature at peak power and 

peak torque are insufficient. The exhaust temperature at the DPF's inlet is highly 

application dependent in that the particular duty cycle experienced plays a prominent 

role, as do heat losses in the exhaust system. Very application-specific characteristics 

enter the heat loss equation, such as the length of piping the exhaust must travel 

through before it reaches the DPF. Lower average exhaust temperatures can also be 

the result of operating engines that are oversized for the application or run without a 

load applied. (ARB, 2002) 

Staff believes that RTG cranes in particular are good candidates for DPFs because of 

their duty cycle and high operating temperatures at load. The ARB is currently 

participating in a study to identify and demonstrate high-efficiency retrofit emission 
V - 7

control systems for RTG cranes, top handlers, and side handlers. The program will 

continue through Spring 2006 is expected to lead to ARB verification for controls such 

as DPFs. Appendix H contains more information on the demonstration program. 

Combinations

Combinations of more than one technology are also being explored to maximize the 

amount of diesel PM and reducing other pollutants. For example, fuel-borne catalysts 

or emulsified fuel can be combined with any of the three main hardware technologies 

discussed above: DOC, FTF, or DPF’s. 

C. Cleaner Diesel Fuels, Alternative Diesel Fuels, and Alternative Fuels 

Diesel PM emission reductions can also be realized through the use of cleaner diesel 

fuels, alternative diesel fuels, or alternative fuels. Using ultra low-sulfur diesel fuel 

(15 ppm) results in modest PM reductions and will also enable the use of advanced 

exhaust aftertreatment systems for those engines that use verified diesel emission 

control strategies (VDECS) to meet the performance standards in the proposed 

regulation. Alternative diesel fuels, such as emulsified diesel, can also reduce diesel 

PM emissions and has been used successfully in cargo handling equipment at the ports 

of Long Beach and Los Angeles. Using alternative fuels, such as compressed natural 

gas (CNG), liquefied natural gas (LNG), and liquefied petroleum gas (LPG) can often 

produce significantly fewer emissions than older diesel engines but there are 

operational and economic constraints associated with cargo handling equipment that 

utilize these fuels. However, while there are limitations to using alternative diesel-fuels 

and alternative fuels, particularly with higher power demanding engines, we believe they 

may provide a satisfactory route to compliance for many categories. Below we describe 

some fuel options for cargo handling equipment engines. 

Ultra-Low Sulfur Diesel Fuel (CARB Diesel)

Lowering the sulfur content of diesel fuel is important to the performance of 

aftertreatment technologies, particularly DPFs. Sulfur affects filter performance by 

inhibiting the performance of catalytic materials upstream of or on the filter (i.e., catalyst 

"poisoning"). This phenomenon not only adversely affects the ability to reduce 

emissions, but also adversely impacts the capability of these filters to regenerate - there 

is a direct trade-off between sulfur levels in the fuel and the ability to achieve 

regeneration. Sulfur also competes with the chemical reactions intended to reduce 

pollutant emissions and creates particulate matter through catalytic sulfate formation. 

The availability of ultra low-sulfur fuel will enable these filters to be designed for 

improved PM filter regeneration and emission control performance, as well as to reduce 

sulfate emissions. Diesel fuel containing less than 15 ppm sulfur is required to ensure 

maximum emission control performance on the broadest range of off-road diesel 

engines. (MECA, 2003) 
V - 8

All diesel-fueled cargo handling equipment will be required to use ultra low-sulfur diesel 

fuel beginning in mid to late 2006 as a result of recently approved amendments to the 

California diesel fuel regulations. This reduced sulfur content will provide a small 

emission benefit because a portion of PM emissions is comprised of sulfates, the 

formation of which is a direct function of the level of sulfur in the fuel. (Diesel, 2003) 

Several port terminals (i.e., at the Port of Oakland) are already using ultra-low diesel 

fuel exclusively in their cargo handling equipment. Currently, this lower sulfur diesel fuel 

costs about 5 to 15 cents more per gallon than CARB off-road diesel fuel. 

Alternative Diesel Fuels

Alternative diesel fuel is a fuel that can be used in a diesel engine without requiring 

engine or fuel system modifications for the engine to operate, although minor 

modifications (e.g., recalibration of the engine fuel control) may enhance performance. 

Examples of alternative diesel fuels include biodiesel, emulsified fuels, Fischer-Tropsch 

fuels, or a combination of these fuels with CARB diesel fuel. The emissions effects of 

these fuels can vary widely. A detailed discussion of alternative diesel fuels is provided 

in the Diesel Risk Reduction Plan. (ARB, 2000) These alternatives may result in 

significant benefits for higher-emitting categories, such as off-road engines. Synthetic 

or alternative diesel fuels may also prove to be part of the preferred control strategy for 

diesel-fueled engines that would otherwise result in relatively high risk, or where control 

retrofit options are very expensive or difficult to implement. 

Several terminals at the ports of Long Beach and Los Angeles are currently using 

emulsified diesel fuel across their fleets of cargo handling equipment, with some of them 

using it in conjunction with a DOC. Engines that are using the fuel must be able to 

tolerate a power loss of up to 20 percent. In ARB’s yard truck testing program that was 

mentioned earlier in this chapter, comparison testing using CARB diesel and emulsified 

diesel showed an overall increase in total hydrocarbon emission factors of 10 to 

33 percent for the emulsified diesel. The reductions in NOx emission factors ranged 

from 18 to 22 percent for the emulsified diesel. PM emission factor reductions ranged 

from 17 to 53 percent. Additional information on the testing program and its results are 

available in Appendix E. 

Alternative Fuels

Using alternative fuels is another option for reducing emissions from off-road dieselfueled engines. Engines using alternative fuels have emission levels than are 

comparable or lower than new diesel engines operating on CARB diesel fuel. However, 

the availability of cargo handling equipment, particularly non-yard truck equipment, that 

use alternative fuels is very limited. In fact, there is no known availability of alternativefueled top handlers, side handlers, RTG cranes, or many other non-yard truck 

equipment types. Yard trucks are commercially available with CNG/LNG or LPG 

engines, but the cost differential is significant, sometimes up to 70 percent more for an 

alternative-fueled yard truck versus the traditional diesel-fueled yard truck. 
V - 9

Currently, the Port of Los Angeles has over 50 LPG yard trucks that have been in use 

for several years as a result of a law suit settlement requiring alternative-fueled yard 

trucks. The experience with the LPG yard trucks has included high fuel infrastructure 

costs and a significant increase in required maintenance. (ARB, 2005a) Issues with 

LPG fuel quality can result in a residue build-up on certain engine components, such as 

vaporizers, carburetors, and injectors, which reduces the effectiveness of heat transfer 

and ultimately causes poor delivery of the fuel and inaccurate fuel-to-air ratios. 

(ARB, 2005b) 

The ARB yard truck testing program, mentioned earlier in this chapter, has completed 

chassis dynamometer testing of a 2004 LPG-fueled yard truck. Results from earlier 

tests conducted with certified off-road and on-road diesel yard trucks were used for 

comparison. The test results indicated that both the total hydrocarbon (TCH) and NOx 

emissions were higher for the LPG engine compared to the same model year on-road 

diesel engine. Particulate matter emissions were significantly lower for the LPG engine 

than either the on-road or off-road engines, which was an expected result since LPG 

does not emit diesel PM. 

Several terminals across the state use spark-ignited engine (i.e., electric and/or LPG) 

forklifts, often in addition to compression-ignition engine (i.e., diesel) forklifts. The fuel 

type for forklifts is usually determined by the desired lift capacity and the type of 

operation. Diesel forklifts usually start with a lift capacity above 6,000 pounds, while 

spark-ignited forklifts are generally used for lift capacities up to 16,000 pounds. 

(Moyer, 2003) 

Staff is not recommending that alternative-fueled engines be considered BACT for the 

purposes of this regulation. This is based on staff’s review of cost, cost-effectiveness, 

availability of both equipment and fuel, and applicability of these engines to the types of 

equipment covered by the regulation. However, for the purposes of complying with the 

in-use requirements for non-yard truck equipment, alternative-fueled engines that are 

certified to the appropriate on-road or off-road standard are an approved compliance 

option. Appendix F contains further discussion of alternative fuels. 

D. Verification of Diesel Emission Control Devices 

In support of the ARB’s regulatory efforts to reduce diesel PM, the Verification 

Procedure, Warranty and In-Use Compliance Requirements of In-Use Strategies to 

Control Emissions from Diesel Engines (Verification Procedure) was adopted by the 

Board in March 2002. The Verification Procedure establishes a process through which 

manufacturers of emission control equipment can demonstrate and verify the emission 

reduction capabilities of control technologies. Examples of emission control 

technologies that can be considered for verification include diesel particulate filters, 

diesel oxidation catalysts, exhaust gas re-circulation, selective catalytic reduction 

systems, fuel additives and alternative diesel fuel systems. The Verification Procedure 

is voluntary and applies to emission control technologies for on-road, off-road and 
V - 10

stationary applications. A brief discussion on the Verification Procedure is provided in 

this section. 

The Verification Procedure requires emission control strategy applicants to establish the 

emissions reduction capabilities for an emission control device, conduct a durability 

demonstration, conduct a field demonstration and submit results along with other 

information in an application to the ARB following a prescribed format. The applicant 

verifies the product for a specific engine manufacturer, years produced, engine family 

and series. If the ARB approves the application, it will issue an Executive Order to the 

applicant stating the verified emission reduction and any conditions that must be met for 

the diesel emission control strategy to function properly. The Verification Procedure 

also requires that the applicants provide a warranty to the end-user and conduct in-use 

compliance testing. 

The results of the Verification Procedure testing determine the control technology 

classification. The multi-level verification system consists of three PM reduction levels. 

The Verification Procedure also has provisions for verifying strategies that reduce NOx 

emissions. Control device verifications for both PM and NOx are classified by level as 

listed in Table V-2. 

Table V-2: Verification Classifications for Diesel Emission Control Strategies 

Pollutant Reduction Classification 

<25% Not Verified 

> 25% Level 1 

> 50 % Level 2 PM 

> 85% or <0.01 g/bhp-hr Level 3 

<15% Not Verified NOx 

>15% Verified in 5% increments 

Once a device has been verified, the executive order and accompanying information is 

posted on the ARB's web site at http://www.arb.ca.gov/diesel/verdev/verdev.htm. The 

ARB has the Diesel Emission Control Strategy Verification Procedure and the 

U.S. EPA’s Voluntary Retrofit Verification Program. Both programs share a common 

goal of verifying the emission reductions from diesel emission control systems. The 

agencies have made tremendous efforts to harmonize key requirements in both 

programs; still differences exist between the two programs. In general, the ARB 

Verification Procedure is designed to support regulatory requirements while the 

U.S. EPA’s program is voluntary. For more detail of the program differences visit 

http://www.arb.ca.gov/diesel/verdev/frmlregdocs.htm. 

There are currently three manufacturers offering Level 1, 2, and 3 VDECS for in-use 

off-road engines, including some engines used in cargo handling equipment. Level 1 

DOC options include the Donaldson Series 6000 with spiracle closed crankcase 

filtration, Extengine Transport Systems Advanced Diesel Emission Control, and Lubrizol 

AZ Purifier and AZ Purimuffler. Lubrizol offers a Level 2 DOC, the AZ Purifier or an 

AZ Purimuffler, which requires the use of Lubrizol’s emulsified diesel fuel, PuriNOx. 
V - 11

The Level 3 VDECS is a Lubrizol Unikat Combifilter, which is an actively regenerated 

uncatalyzed DPF that operates using either CARB diesel or ultra low-sulfur diesel fuel. 

Each of the technologies above have specific model year and engine requirements. 

Appendix G contains the executive orders for each of the verified devices. 

As stated earlier, using VDECS is one possible compliance option for non-yard truck 

cargo handling equipment. The proposed regulation allows for compliance extensions 

to be granted in situations where VDECS are not available for a specific engine and 

equipment type, and/or if the owner or operator chooses to use an experimental diesel 

emission control strategies due to feasibility issues with an available VDECS. Because 

non-yard truck cargo handling equipment is so diverse, several factors can affect the 

feasibility of VDECS, such as duty cycle, load factor, speed, and idling time. Therefore, 

while verification may extend to specific engine families and model years, VDECS are 

not always the right fit for all applications or equipment types. 

The ARB project (mentioned earlier in this chapter) to test and demonstrate highefficiency control systems for RTG cranes, top handlers, and side handlers, along with 

the use of experimental diesel emission control strategies, are both intended to lead to 

the verification of more controls for cargo handling equipment and off-road engines in 

general. As part of the implementation efforts for the proposed regulation, staff plan to 

create a technology workgroup, whose goal will be to monitor the available control 

strategies, address concerns regarding the use of the technologies in non-yard truck 

cargo handling equipment, and encourage manufacturers to apply for ARB verification. 
V - 12

REFERENCES: 

(Allansson, 2000) Allansson, R, Cooper, BJ, Thoss, JE, Uusimake, A, Walker, AP, 

Warren, JP. European Experience of High Mileage Durability Of Continuously 

Regenerating Diesel Particulate Filter Technology; SAE 2000-01-0480; 2000. 

(ARB, 2000) California Air Resources Board. Risk Reduction Plan to Reduce 

Particulate Matter Emission from Diesel-Fueled Engines and Vehicles; October 2000. 

(ARB, 2002) California Air Resources Board. Staff Report: Initial Statement of Reasons 

Proposed Regulation for the Verification Procedure for In-Use Strategies to Control 

Emissions from Diesel Engines, Appendix B, Diesel Emission Control Technologies; 

2002. 

 

(ARB, 2003a) California Air Resources Board. Staff Report: Technical Support 

Document, Proposed Control Measure for Diesel Particulate Matter from On-Road 

Heavy-Duty Diesel-Fueled Residential and Commercial Solid Waste Collection Vehicle 

Diesel Engines; 2003. 

(ARB, 2005a) California Air Resources Board. Phone call with Mr. Kenton Pope, 

Marine Terminals Corporation; March 11, 2005. 

(ARB, 2005b) California Air Resources Board. Staff Report: Initial Statement of 

Reasons for Proposed Rulemaking, Public Hearing to Consider Adoption of Emission 

Standards and Test Procedures for New 2007 and Later Off-Road Spark-Ignition (LSI) 

Engines and Fleet Requirements for Users of Off-Road LSI Engines; May 6, 2005. 

(ARB, 2005c) California Air Resources Board. Phone call with Mr. Don Lawrence, 

Ottawa (Kalmar Industries); September 22, 2005. 

(ARB, POLA) California Air Resources Board e-mail from Ms. Shokoufe Marashi with 

the Port of Los Angeles. August 3, 2005. 

(ARB, POLB) California Air Resources Board e-mail from Ms. Heather Tomley with the 

Port of Long Beach. August 30, 2005. 

(ARB, Port of Oakland) Summary Report #10 Vision 2000 Air Quality Mitigation 

Program, Port of Oakland, Environmental Planning Department, August 2004. 

(DieselNet, 1998) DieselNet. Technology Guide: Emission Control Technologies, 

http://www.dieselnet.com; 1998. 

(DieselNet, 2002) DieselNet. Technology Guide: Diesel Oxidation Catalyst, 

http://www.dieselnet.com; 2002. 
V - 13

(Diesel, 2003) Diesel Technology Forum. Clean Air, Better Performance: Strategies for 

Upgrading and Modernizing Diesel Engines; May 2003. 

(Kendall, 2002/2003) Kendall, Tom; Johnson Matthey. Platinum 2002, 

http://www.platinum.matthey.com/publications/1051543656.html; Platinum 2003,

http://www.platinum.matthey.com/publications/1059138410.html; May 2002 and 

May 2003. 

(Khair, 1999) Khair, Magdi, McKinnon, Dale L. Performance Evaluation of Advanced 

Emission Control Technologies for Diesel Heavy-Duty Engines, SAE 1999-01-3564; 

1999. 

(MECA, 2003) Manufactures of Emission Controls Association. Exhaust Emission 

Controls Available to Reduce Emissions from Non-Road Diesel Engines; April 2003. 

(U.S. EPA 2000) U.S. EPA’s 2007 Final Rule on the Control of Emissions of Air 

Pollution from 2007 and later Model Year Heavy-Duty Highway Engines and Vehicles; 

Revisions of Light-Duty On-Board Diagnostic Requirements (66 FR 5002, 

January 18, 2001). 
VI - 1 

VI. ENVIRONMENTAL IMPACTS 

This chapter describes the potential environmental impacts of this proposed regulation. 

This proposed regulation is intended to protect the health of California’s citizens by 

reducing diesel engine emissions from cargo handling equipment at ports and 

intermodal rail yards. An additional consideration is the impact that implementation of 

the proposed regulation may have on the environment. Based upon available 

information, the ARB staff has determined that no significant adverse environmental 

impacts should occur as the result of adopting the proposed regulation. This chapter 

describes the potential impacts that the proposed regulation may have on wastewater 

treatment, hazardous waste disposal, and air quality. 

A. Legal Requirements 

The California Environmental Quality Act (CEQA) and ARB policy require an analysis to 

determine the potential environmental impacts of proposed regulations. Because the 

ARB's program involving the adoption of regulations has been certified by the Secretary 

of Resources pursuant to Public Resources Code section 21080.5, the CEQA 

environmental analysis requirements may be included in the Initial Statement of 

Reasons (ISOR) for this rulemaking. In the ISOR, ARB must include a “functionally 

equivalent” document, rather than adhering to the format described in CEQA of an Initial 

Study, a Negative Declaration, and an Environmental Impact Report. In addition, staff 

will respond, in the Final Statement of Reasons for the regulation, to all significant 

environmental issues raised by the public during the public review period or at the 

Board public hearing. 

Public Resources Code section 21159 requires that the environmental impact analysis 

conducted by ARB include the following: 

• An analysis of reasonably foreseeable environmental impacts of the methods 

of compliance; 

• An analysis of reasonably foreseeable feasible mitigation measures; and 

• An analysis of reasonably foreseeable alternative means of compliance with 

the regulation. 

Compliance with the proposed regulation is expected to directly affect air quality and 

potentially affect other environmental media as well. Our analysis of the reasonable 

foreseeable environmental impacts of the methods of compliance is presented below. 

Regarding mitigation measures, CEQA requires an agency to identify and adopt 

feasible mitigation measures that would minimize any significant adverse environmental 

impacts described in the environmental analysis. 

The proposed regulation is needed to reduce the risk from exposures to diesel PM as 

required by Health and Safety Code (HSC) section 39666 and 39667, and to fulfill the 

goals of the October 2000 Diesel Risk Reduction Plan. (ARB, 2000) The regulation is 
VI - 2 

also necessary to fulfill ARB’s obligations under HSC 43013 and 43018 to achieve the 

maximum feasible and cost effective emission reductions from all mobile source 

categories, including off-road diesel engines and equipment. The emission reductions 

from the proposed regulation in ambient levels of PM, NOx and reactive organic gases 

(ROG) will help make progress in meeting the State and Federal ambient air quality 

standards for ozone and PM in non-attainment areas of the State. Alternatives to the 

proposed regulation have been discussed earlier in Chapter IV of this report. ARB staff 

have concluded that there are no alternative means of compliance that would achieve 

similar diesel PM emission reductions at a lower cost. 

B. Effects on Air Quality 

The proposed regulation will provide diesel PM and NOx emission reductions 

throughout California, especially in areas having ports and intermodal rail yards, areas 

which in most cases are non-attainment for the State and federal ambient air quality 

standards for ozone, PM10, and PM2.5. The projected controlled emissions from cargo 

handling equipment engines are presented in Table VI-1. 

Table VI-1: Projected Annual Emissions for Cargo Handling Equipment Used in 

Ports and Intermodal Rail Yard Applications with Implementation of 

the Proposed Regulation 

2004 Emissions 

(Tons per Day) 

2010 Emissions 

(Tons per Day) 

2020 Emissions 

Category (Tons per Day) 

PM NOx PM NOx PM NOx 

Cranes 0.07 1.93 0.04 1.75 0.02 1.32 

Excavators 0.01 0.24 0.00 0.18 0.00 0.04 

Forklifts 0.03 0.54 0.01 0.38 0.00 0.17 

Container Handling 

Equipment 0.11 3.25 0.09 3.33 0.04 1.63 

Other General Industrial 

Equipment 0.00 0.08 0.00 0.08 0.00 0.03 

Sweepers / Scrubbers 0.00 0.04 0.00 0.04 0.00 0.02 

Tractors / Loaders / 

Backhoes 0.01 0.18 0.01 0.17 0.00 0.07 

Yard Trucks 0.42 12.78 0.15 6.49 0.05 1.12 

Total 0.65 19.04 0.31 12.43 0.12 4.41 

ARB staff estimates that, with implementation of the proposed regulation, diesel PM 

emissions from cargo handling equipment will be reduced by approximately 0.25 tons 

per day in 2010, and 0.24 tons per day in 2015 relative to uncontrolled levels. As 

shown in Figure VI-1, it is about a 40 and 66 percent reduction from the projected 2010 

and 2015 baseline levels, respectively. In 2020, ARB staff expects a 39 percent 

reduction in PM. We also anticipate reductions in reactive organic compounds and 
VI - 3 

carbon monoxide; however, the emission reductions from these pollutants are not yet 

quantified in the emissions inventory. 

Figure VI-1: Projected Diesel PM Emissions with and without the Regulation 

Between 2007 and 2020, we estimate approximately 865 tons of PM will be removed 

from California's air as a result of the regulation. As shown in Table VI-2, ARB staff 

estimates that, as older engines are replaced with new engines or retrofitted with diesel 

emission control strategies, there will also be a reduction in NOx of approximately 

18,633 tons in the same time frame. 

Table VI-2: Emission Benefits from Implementation of the Proposed 

 Cargo Handling Equipment Regulation 

PM NOx 

Emissions Reduced 

 2007 to 2020 (Tons) 865 18,633 

Annual Average Reductions 

(Tons per Year) 67 1,433 

0

50

100

150

200

250

300

20042007201020152020

Year

TPY

PM Baseline

PM Reg Influence
VI - 4 

Figure VI-2: Projected NOx Emissions with and without the Regulation 

C. Health Benefits Analysis 

Reduced Ambient Particulate Matter Levels 

A substantial number of epidemiologic studies have found a strong association between 

exposure to ambient particulate matter (PM) and adverse health effects. (ARB, 2002) 

For this report, ARB staff evaluated the impacts the proposed regulation would have on 

potential cancer risks and conducted a quantitative analysis of four potential non-cancer 

health impacts associated with exposures to ambient levels of directly emitted diesel 

PM. 

Reduction in Potential Cancer Risks 

The reductions in diesel PM emissions that will result from implementation of the 

proposed regulation will reduce the public’s exposures to diesel PM emissions and the 

potential cancer risks associated with those exposures. ARB staff used the air 

dispersion model and model inputs developed for the POLA and POLB health risk 

assessment to estimate the reductions in potential cancer risk that would result in the 

area surrounding the ports of POLA and POLB from implementation of the proposed 

regulation. ARB staff believes that the results from this analysis provide quantitative 

results for exposures around the Ports of Los Angeles and Long Beach and are 

generally applicable to other ports and intermodal rail yards in California, providing a 

qualitative estimate for those areas. 

To investigate the reductions in potential risks that will result as emissions from cargo 

handling equipment decline, ARB staff used dispersion modeling and the projected 

2010 and 2020 emissions inventories to estimate the ambient concentration of diesel 

PM emissions that result from the operation of cargo handling equipment at the Ports of 

Los Angeles and Long Beach in 2010 and 2020. The potential cancer risks from 

0

1000

2000

3000

4000

5000

6000

7000

8000

20042007201020152020

Year

TPY

NOx Baseline 

NOx Reg Influence
VI - 5 

exposures to the projected 2010 and 2020 emissions were then estimated and 

compared to the 2002 levels to determine how the potential risks will change. As shown 

in Figures VI-3 and VI-4, we expect a significant decline in the number of people 

exposed to high risk levels from cargo handling equipment emissions and the acres 

impacted as the proposed regulation is implemented. Based on our analysis, which is 

summarized in Appendix K, we estimate that in 2010 there will be a 56 percent 

reduction in the population-weighted average risk relative to the risk levels in 2002 from 

cargo handling equipment emissions and an 82 percent reduction in 2020. 

Figure VI-3: Residential Areas Impacted by the Proposed Regulation for Baseline 

Year (2002) and Predicted 2010 and 2020 at the POLA and POLB 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

Residential Areas (Acres)

2002 Baseline

2010 with Reg

2020 with Reg

2002 Baseline 119,000 4,100 410 50

2010 with Reg 61,700 300 80 10

2020 with Reg 14,640 40 10

Risk > 10 Risk >100 Risk > 200 Risk > 500

< 1
VI - 6 

Figure VI-4: Population Affected by the Proposed Regulation for Baseline Year 

(2002) and Predicted 2010 and 2020 at the POLA and POLB 

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

Number of Population

2002 Baseline

2010 with Reg

2020 with Reg

2002 Baseline 1,444,000 82,000 11,100 3,200

2010 with Reg 832,400 9,000 3,630 960

2020 with Reg 224,650 2,770 960 40

Risk > 10 Risk >100 Risk > 200 Risk > 500

Non-Cancer Health Impacts and Valuations

To determine the impacts from the proposed regulation on non-cancer health endpoints, 

ARB staff used the methodology described previously in Chapter III but evaluated the 

change in ambient PM levels that are expected due to implementation of the proposed 

regulation. This analysis shows that the statewide cumulative impacts of the emissions 

reduced through this regulation from year 2007 through 2020 are approximately: 

• 32 premature deaths (16 to 48, 95% CI) 

• 820 asthma attacks (200 to 1,400, 95% CI) 

• 7,100 work loss days (6,020 to 8,200, 95% CI) 

• 38,000 minor restricted activity days (31,000 to 45,000, 95% CI) 

 Value of Non-Cancer Effects 

Premature Death: The U. S. EPA has established $6.3 million (in 2000 $) for a 1990 

income level as the mean value of avoiding one death. (EPA, 2003) As real income 

increases, people may be willing to pay more to prevent premature death. The 

U.S. EPA further adjusted the $6.3 million value to $8 million (in 2000 $) for a 2020 

income level. Assuming that real income grew at a constant rate from 1990 and will 

continue at the same rate until 2020, we adjusted the value of avoiding one death for 

income growth. We then updated the value to 2005 dollars and discounted values of 

avoiding a premature death in the future back to the year 2005. The U.S. EPA’s 
VI - 7 

guidance of social discounting recommends using both three and seven percent 

discount rates. (EPA, 2000) 

Based on these rates, the total valuation of the avoided premature deaths is about 

$160 million at seven percent discount rate, and $220 million at three percent discount 

rate. Based on using the annual avoided deaths as weights, the weighted average 

value of reducing a future premature death, discounted back to the year 2005, is around 

$5 million at seven percent discount rate, and $7 million at three percent. 

Non-Mortality Health Effects: To estimate the values of certain non-mortality health 

effects, we use U.S. EPA valuations, updated to 2005 dollars, for avoiding non-fatal 

health effects (EPA, 2003): 

• $49 for acute asthma attack 

• $180 for work loss day 

• $58 for minor restricted activity day (MRAD) 

The expected reduction in acute asthma attack is about 820 cases. The total valuation 

is about $25,000 using a seven percent discount rate, and $33,000 using a three 

percent discount rate. 

For the 7,120 avoided work loss days, their valuation is about $0.8 million using a seven 

percent discount rate, and $1.1 million using a three percent discount rate. For the 

37,820 avoided MRAD, their valuation is about $1.4 million using a seven percent 

discount rate, and $1.8 million using a three percent discount rate. 

Reduced Ambient Ozone Levels 

Emissions of NOx and ROG are precursors to the formation of ozone in the lower 

atmosphere. Exhaust from diesel engines contributes a substantial fraction of ozone 

precursors in any metropolitan area. Therefore, reductions in NOx and ROG from 

diesel engines would make a considerable contribution to reducing exposures to 

ambient ozone. Controlling emissions of ozone precursors would reduce the 

prevalence of the types of respiratory problems associated with ozone exposure and 

would reduce hospital admissions and emergency visits for respiratory problems. 

D. Reasonably Foreseeable Environmental Impacts as a Result of Potential 

Compliance Methods 

We have identified potential adverse environmental impacts from the use of diesel 

oxidation catalysts (DOCs) and diesel particulate filters (DPFs). These include a 

potential increase in sulfate PM, a potential increase in NO2 from some DPFs, and the 

potential for creating hazardous wastes. As described below, options are available to 

mitigate these potential adverse impacts. 
VI - 8 

Diesel Oxidation Catalyst (DOC)

Two potential adverse environmental impacts of the use of diesel oxidation catalysts 

have been identified. First, as is the case with most processes that incorporate catalytic 

oxidation, the formation of sulfates increases at higher temperatures. Depending on the 

exhaust temperature and sulfur content of the fuel, the increase in sulfate particles may 

offset the reductions in soluble organic fraction emissions. Using low sulfur diesel fuel 

can minimize this effect. Starting in 2006 all off-road engines will be required to use 

CARB fuel (<15 ppm sulfur). 

Second, a diesel oxidation catalyst could be considered a “hazardous waste” at the end 

of its useful life depending on the materials used in the catalytic coating. Because 

catalytic converters have been used on gasoline powered on-road vehicles for many 

years, there is a very well-established market for these items (see, for example, 

http://pacific.recycle.net – an Internet posting of buyers and sellers of various scrap 

materials). In the recycling process, the converters are broken down, and the metal is 

added to the scrap-metal stream for recycling, while the catalysts (one or a combination 

of the platinum group metals) are extracted and reused. 

Because of platinum’s high activity as an oxidation catalyst, it is the predominant 

platinum group metal used in the production of diesel oxidation catalysts. There is a 

very active market for reclaimed platinum for use in new catalytic converters, jewelry, 

fuel cells, cathode ray tube screens, catalysts used during petroleum refining 

operations, dental alloys, oxygen sensors, platinum electrode spark plugs, medical 

equipment, and platinum-based drugs for cancer treatment, to name a few. 

(Kendall, 2002) (Kendall, 2003) 

 Catalyzed Diesel Particulate Filters

These devices are composed of a ceramic diesel particulate filter along with a platinum 

catalyst to catalyze the oxidation of carbon-containing emissions and significantly 

reduce diesel PM emissions. This is an obvious positive environmental impact. 

However, there are also inorganic solid particles present in diesel exhaust, which are 

captured by diesel particulate filters. These inorganic materials are metals derived from 

engine oil, diesel fuel, or engine wear and tear. While the PM filter is capable of 

capturing inorganic materials, these materials are not oxidized into a gaseous form and 

expelled. 

Because these materials would otherwise be released into the air, the filters are 

benefiting the environment by capturing these metallic particles, known as “ash.” 

However, the ash that is collected in the PM filter must be removed from the filter 

periodically to maintain the filter’s effectiveness. 

Ash collected from a diesel engine using a typical lubrication oil and no fuel additives 

has been analyzed and is primarily composed of oxides of the following elements: 
VI - 9 

calcium, zinc, phosphorus, silicon, sulfur, and iron. Zinc is the element of primary 

concern because, if present in high enough concentration, it can make a waste a 

hazardous waste. Title 22, CCR, section 66261.24 establishes two limits for zinc in a 

waste: 250 milligrams per liter for the Soluble Threshold Limit Concentration and 

5,000 milligrams per kilogram for the Total Threshold Limit Concentration. The 

presence of zinc at or above these levels would cause a sample of ash to be 

characterized as a hazardous waste. 

Under California law, it is the generator's responsibility to determine whether their waste 

is hazardous or not. Applicable hazardous waste laws are found in the HSC, 

division 20; title 22, CCR, division 4.5; and title 40 of the Code of Federal Regulations. 

Staff recommends owners that install a diesel particulate filter on an engine to contact 

both the manufacturer of the diesel emission control system and the California 

Department of Toxic Substances Control (DTSC) for advice on proper waste 

management. 

ARB staff has consulted with personnel of the DTSC regarding management of the ash 

from diesel particulate filters. DTSC personnel have advised ARB that it has a list of 

facilities that accept waste from businesses that qualify as a conditionally exempt small 

quantity generator. Such a business can dispose of a specific quantify of hazardous 

waste at certain Household Hazardous Waste events, usually for a small fee. An owner 

who does not know whether or not he qualifies or who needs specific information 

regarding the identification and acceptable disposal methods for this waste should 

contact the California DTSC.9

 

Additionally, the technology exists to reclaim zinc from waste. For example, the 

Swedish company MEAB has developed processes for extracting zinc and cadmium 

from various effluents and industrial waste streams. Whether reclamation for reuse will 

be economically beneficial remains to be seen. (MEAB, 2003) 

Because of the time and costs associated with filter maintenance, there are also efforts 

by industry to reduce the amount of ash formed. Most of the ash is formed from the 

inorganic materials in engine oil, particularly from zinc-containing additives necessary to 

control acidification of engine oil – due in part to sulfuric acid derived from sulfur in 

diesel fuel. As the sulfur content of diesel fuel is decreased, the need for acid 

neutralizing additives in engine oil should also decrease. A number of technical 

programs are ongoing to determine the impact of changes in oil ash content and other 

characteristics of engine oil on exhaust emission control technologies and engine wear 

and performance. 

It may also be possible to reduce the ash level in diesel exhaust by reducing oil 

consumption from diesel engines. Diesel engine manufacturers over the years have 

reduced engine oil consumption in order to reduce PM emissions and to reduce 

 

9

 Information can be obtained from local duty officers and from the DTSC web site at 

http://www.dtsc.ca.gov.
 VI - 10 

operating costs for engine owners. Further improvements in oil consumption may be 

possible in order to reduce ash accumulation rates in diesel particulate filters. 

In addition, measurements of NOx emissions for heavy-duty diesel vehicles equipped 

with passive catalyzed filters have shown an increase in the NO2 portion of total NOx 

emissions, although the total NOx emissions remain approximately the same. In some 

applications, passive catalyzed filters can promote the conversion of nitrogen oxide 

(NO) emissions to NO2 during filter regeneration. More NO2 is created than is actually 

being used in the regeneration process; and the excess is emitted. The NO2 to NOx 

ratios could range from 20 to 70 percent, depending on factors such as the diesel 

particulate filter systems, the sulfur level in the diesel fuel, and the duty cycle. 

(DaMassa, 2002) 

Formation of NO2 is a concern because it irritates the lungs and lowers resistance to 

respiratory infections. Individuals with respiratory problems, such as asthma, are more 

susceptible to the effects. In young children, nitrogen dioxide may also impair lung 

development. In addition, a higher NO2/NOx ratio in the exhaust could potentially result 

in higher initial NO2 concentrations in the atmosphere which, in turn, could result in 

higher ozone concentrations. 

Model simulations have shown that a NO2 to NOX emission ratio of approximately 

20 percent would nearly eliminate any impact of increased NO2 emissions. 

(DaMassa, 2002). According to the model, at the NO2 to NOx ratio of 20 percent, there 

will be a decrease of the 24-hour ozone exposure (greater than 90 parts per billion) by 

two percent while an increase of the peak 1-hour NO2 by six percent (which is still within 

the NO2 standard). 

The health benefits derived from the use of PM filters are immediate and offset the 

possible adverse effects of increases in NO2 emissions. For this reason, a cap of 

20 percent NO2 to NOx emission ratio was established for all diesel emission control 

systems through ARB’s Verification Procedure. 

Alternative Fuels

As discussed in Appendix F, a number of alternative fuels and alternative diesel fuels 

show great promise in their potential to reduce diesel PM emissions. These include 

alternative diesel fuels such as biodiesel, emulsified diesel fuel, and Fischer-Tropsch 

fuels, and alternative fuels such as natural gas. No significant negative environmental 

impacts have been determined from the use of alternative fuels. With respect to 

alternative diesel fuels, there may be a slight increase in NOx emissions as a result of 

biodiesel use. (Hofman and Solseng, 2002) 

To ensure there are no adverse impacts from the use of alternative diesel fuels, the 

proposed regulation requires any alternative diesel-fuel or fuel additives used in a cargo 

handling equipment engine to be verified under the ARB’s Verification Procedure. The 

Verification Procedure permits verification only if a multimedia evaluation of the use of 
 VI - 11 

the alternative diesel fuel or additive has been conducted. In addition, verification 

requires a determination by the California Environmental Policy Council that such use 

will not cause a significant adverse impact on public health or the environment pursuant 

to HSC section 43830.8 (see Public Resource Code, section 71017). 

E. Reasonably Foreseeable Mitigation Measures 

ARB staff has concluded that no significant adverse environmental impacts should 

occur from adoption of and compliance with the proposed regulation. Therefore, no 

mitigation measures would be necessary. 

F. Reasonably Foreseeable Alternative Means of Compliance with the 

Proposed Regulation 

Alternatives to the proposed regulation are discussed in Chapter IV of this report. ARB 

staff has concluded that the proposed regulation provides the most effective and least 

burdensome approach to reducing children’s and the general public's exposure to diesel 

PM, NOx, and other air pollutants emitted from diesel-fueled cargo handling equipment. 
 VI - 12 

REFERENCES: 

(ARB, 2000) Air Resources Board. Risk Reduction Plan to 

Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. 

http://www.arb.ca.gov/diesel/documents/rrpapp.htm; October 2000. 

(ARB, 2002) Air Resources Board and Office of Environmental Health Hazard 

Assessment. Public Hearing to Consider Amendments to the Ambient Air Quality 

Standards for Particulate Matter and Sulfates, Staff Report. 

http://www.arb.ca.gov/research/aaqs/std-rs/pm-final/pm-final.htm; May 2002. 

(DaMassa, 2002) DaMassa, John. California Air Resources Board. Presentation: Air 

Quality Effects of Trap-Related Emissions (Updated); February 6, 2002. 

 

(Kendall, 2002) Kendall, Tom; Johnson Matthey. Platinum 2002; 

http://www.platinum.matthey.com/publications/1051543656.html; May 2002. 

(Kendall, 2003) Kendall, Tom; Johnson Matthey. Platinum 2003; 

http://www.platinum.matthey.com/publications/1059138410.html; May 2003. 

(MEAB, 2003) Metallextraktion AB (MEAB). http://www.meab-mx.se/en/index.htm; 

August 2003. 

(Krewski et al., 2000) Krewski D.; Burnett R.; Goldberg M.; Hoover K.; Stemiatychi 

J.; Jerrett M.; Abrahamovicz M.; White W. Health Effects Institute, Cambridge, 

Massachusetts. Reanalysis of the Harvard Six Cities Study and the American Cancer 

Society Study of Particulate Air Pollution and Mortality. 

http://es.epa.gov/ncer/science/pm/hei/Rean-ExecSumm.pdf; 2000. 

(Lloyd and Cackette, 2001) Lloyd, A.C.; Cackette, T.A.; J Air Waste Management 

Assoc. Diesel Engines: Environmental Impact and Control;., 51:809-847. 

http://www.arb.ca.gov/research/seminars/lloyd/AWMA2001/JAWMADieselCriticalRevie

w.pdf; 2001. 

(U.S. EPA, 1999) United States Environmental Protection Agency. The Benefits and 

Costs of the Clean Air Act 1990 to 2010. EPA-410-R-99-001. 

http://www.epa.gov/air/sect812/copy99.html; November 1999. 

(EPA, 2000) United States Environmental Protection Agency., Guidelines for Preparing 

Economic Analyses. EPA240-R-00-003. http://www.epa.gov/opei/pubsinfo.htm; 

September 2000. 

(EPA, 2003) United States Environmental Protection Agency, Assessment and 

Standards Division, Office of Transportation and Air Quality. Draft Regulatory Impact 
 VI - 13 

Analysis: Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel. 

EPA420-R-03-008. CD-ROM. Research Triangle Park, North Carolina. 

http://www.epa.gov/otaq/cleaner-nonroad/r03008.pdf; April 2003. 
VII - 1 

VII. ECONOMIC IMPACTS 

In this chapter, we present the estimated costs and economic impacts associated with 

implementation of the proposed regulation for cargo handling equipment. The expected 

capital and recurring costs for potential compliance options are presented, the cost and 

associated economic impacts for businesses, as well as an analysis of the costeffectiveness of the proposed regulation. 

A. Summary of the Economic Impacts

Air Resources Board (ARB) staff estimates the cost for compliance with the regulation 

to be approximately 71 million dollars for the total capital and recurring costs. This 

corresponds to about 5.1 million dollars annually on average for the years 2007 through 

2020. This cost, which is based on 2004 dollars, represents the capital cost of 

equipment, maintenance and replacement, and reporting costs from 2007 through to 

2020. 

The cost for a business to comply with this regulation will vary depending on the number 

and type of cargo handling equipment and whether the equipment is equipped with a 

verified diesel exhaust control system (VDECS) and/or later replaced with a new Tier 4 

engine in 2015. For example, the costs for a typical crane engine (rated at 210 hp 

operated 1370 hours per year) with a diesel particulate filter (DPF) is about $17,500 for 

equipment and installation. The estimated annual ongoing costs are based on a 

reporting cost of about $500 per terminal with the cost spread over many pieces of 

equipment. To determine the cost a typical business may incur, we used the ARB 

Survey data on the average number and type of equipment operated by a port container 

terminal, a port bulk handling terminal, and an intermodal rail yard and applied the 

annual average costs for the various equipment types. Based on our analysis, we 

estimate that the total 2007 to 2020 costs to a typical business will be in the range of 

$343,000 to $1,373,000. 

California businesses are affected by the proposed annual cost of the regulation to the 

extent that the implementation of the proposed regulation reduces their profitability. 

Overall, most affected businesses will be able to absorb the costs of the proposed 

regulation with no significant adverse impacts on their profitability. This finding is based 

on the staff’s analysis of the estimated change in “return on owner’s equity” (ROE). The 

analysis found that the overall change in ROE ranges from negligible to a decline of 

about 0.1 percent. Generally, a decline of more than ten percent in ROE suggests a 

significant impact on profitability. Because the proposed regulation would not alter 

significantly the profitability of most businesses, we do not expect a noticeable change 

in employment, business creation, elimination, or expansion, and business 

competitiveness in California. The change in ROE is expected to be a little larger for a 

small business, but still well below the 10 percent limit. 

Staff does not have access to financial records for most of the companies that 

responded to the survey. However, the small business status of the survey 
VII - 2 

respondents was determined by including a query on the ARB Survey for the owner of 

the equipment to indicate if their business was a small business (annual gross receipts 

of $1,500,000 or less for transportation and warehousing per California Government 

Code Section 11342.610). Approximately 10 percent (7 out of 69) of the respondents 

identified themselves as small businesses. Six of these small businesses provided 

sufficient data on their equipment inventory to allow an estimation of the estimated costs 

for compliance with the proposed regulation. Based on our analysis, the total 2007-

2020 costs to small businesses ranged from $41,000 to $638,000 with an average cost 

of $227,000. 

Cost-effectiveness is expressed in terms of control costs (dollars) per unit of air 

emissions reduced (pounds). The cost-effectiveness for the proposed regulation is 

determined by dividing the total capital costs plus the annual operation and 

maintenance and reporting costs by the total pounds of diesel PM reduced during the 

years 2007 to 2020. All costs are in 2004 equivalent expenditure dollars. With a total 

cost of 71 million dollars reducing approximately 1.73 million pounds of diesel PM, we 

estimate the overall cost-effectiveness of the proposed regulation to be about $41 per 

pound of diesel PM reduced, considering only the benefits of reducing diesel PM. 

Because the proposed regulation will also reduce NOx emissions, we could allocate half 

of the costs of compliance against these benefits, resulting in cost-effectiveness values 

of approximately $21/lb of diesel PM and $1/lb of NOx reduced. 

 

The health benefits of implementing the proposed regulation are substantial. The 

estimated statewide benefit of reduced premature mortality is about $160 million using a 

seven percent discount rate or $220 million using a three percent discount rate 

(2005 dollars). 

ARB staff performed the cost analysis relative to the year 2004 (current value of the 

control costs), and unless otherwise stated, all costs are given in 2004 dollars. Where 

future costs are mentioned in the cost-effectiveness and mortality sections, they are 

based on 2004 dollars. In addition, all cost estimates are based on currently available 

technology as described below; staff believes it is likely that the costs will decrease as 

technology improves and production and sales volumes increase. Additional details on 

the cost analysis can be found in Appendix D. 

B. Legal Requirements 

In this section, we explain the legal requirements that must be satisfied in analyzing the 

economic impacts of the regulation. 

Section 11346.3 of the Government Code requires State agencies to assess the 

potential for adverse economic impacts on California business enterprises and 

individuals when proposing to adopt or amend any administrative regulation. The 

assessment shall include a consideration of the impact of the proposed regulation on 

California jobs, business expansion, elimination or creation, and the ability of California 

business to compete with businesses in other states. 
VII - 3 

Also, State agencies are required to estimate the cost or savings to any State or local 

agency and school district in accordance with instructions adopted by the Department of 

Finance (DOF). The estimate shall include any non-discretionary cost or savings to 

local agencies and the cost or savings in federal funding to the State. 

In addition, Health and Safety Code section 57005 requires the Air Resources Board to 

perform an economic impact analysis of submitted alternatives to a proposed regulation 

before adopting any major regulation. A major regulation is defined as a regulation that 

will have a potential cost to California business enterprises in an amount exceeding ten 

million dollars. Because the estimated cost of the regulation does exceed 10 million 

dollars, we have conducted an economic analysis of submitted alternatives to the 

proposal. 

The following is a description of the methodology used to estimate costs as well as ARB 

staff’s analysis of the economic impacts on California businesses and State and local 

agencies. 

C. Methodology for Estimating Costs Associated with Implementation 

In this section, we describe how we estimated the costs associated with the proposed 

regulation. Briefly, the methodology entailed: 

• estimating capital and recurring costs in 2004 dollars associated with various 

compliance options i.e. purchasing a new engine, repowering, using a VDECS; 

• identifying the preferred compliance option for the different equipment types and 

age of engine; 

• projecting the 2004 emissions inventory to future years using the OFFROAD 

model to determine the number of new engines in each year and the number of 

pre-2007 engines remaining that need to comply with the regulation in that year; 

and 

• assuming all terminals have 4 or more pieces of equipment, apply the estimated 

costs to the distribution of engines in each future year that need to come into 

compliance. 

Based on the ARB Survey and updated emissions inventory, we estimate that in 2004 

approximately 120 private companies having about 3,700 pieces of equipment using 

diesel engines will be affected by this regulation. Businesses will incur compliance 

costs to the extent that they have equipment that must meet the performance standards 

in the regulation. The compliance costs will vary depending on the number and 

operating parameters of the cargo handling equipment operated and the approach 

taken to comply with the proposed regulation. Costs were estimated for all categories of 

equipment except “other.” The other category contains a diverse set of equipment such 

as aerial lifts, railcar movers, and other off-highway trucks. ARB staff believes that the 
VII - 4 

costs for this equipment should fall within the range of costs estimated for the other 

more well-defined categories. Details of the cost analysis are provided in the following 

sections and in Appendix D. 

Capital and Recurring Costs

The cost evaluation considers both capital and on-going or recurring operating costs. 

Costs associated with application of VDECS, early retirement of equipment and any 

incremental costs associated with the purchase of cleaner equipment were considered 

as described below. 

VDECS: The capital investment costs for purchase and installation of VDECS were 

determined from actual costs of installing VDECS on cargo handling equipment dieselfueled engines or similar equipment in California over the last 3-5 years as shown in 

Table VII-1. Costs were developed for each type of cargo handling equipment. The 

VDECS costs were estimated for those VDECS likely to be available for compliance in 

the regulation timeframe. (POLB DECS) 

Table VII-1: Capital Costs Assumptions for VDECS 

Equipment Category VDECS* Average 

Cost ($) 

Crane Passive DPF $ 17,520 

Excavator DOC $ 2,269 

Forklift Active DPF $ 6,000 

Container Handling Equip DOC $ 2,269 

Sweeper/Scrubber DOC $ 2,269 

Tractor/Loader/Backhoe DOC $ 2,269 

Yard Tractor NA 

*DPF means a diesel particulate filter and DOC is a diesel oxidation catalyst. 

Fuel costs, in cases where operators of container handling equipment with 2003 to 2006 

model year engines choose to install a Level 2 DECS that uses emulsified diesel, were 

also estimated. In some cases, this may be the preferred compliance option since by 

using a Level 2 DECS with 2003 to 2006 model year engines, the owner/operator would 

not have to replace the equipment in 2015. The 2003 to 2006 model year container 

handling equipment are candidates for this Level 2 DECS. The cost estimate assumed 

an additional cost of $0.20 per gallon of emulsified fuel applied to the average fuel 

consumption estimate of 9625 gallons per year. The resulting recurring additional fuel 

cost of $1925 per piece of equipment is applied. 

Early Retirement: For many categories, one compliance option is for accelerated 

turnover (early retirement) of an engine to a cleaner engine. The cost associated with 

early equipment retirement is the remaining residual value of the old equipment based 

on straight line depreciation according to the following equation: 
VII - 5 

Residual 

 Value = (New Equipment Costs – Used Equipment Costs) X # Years Early Retirement

 Expected Useful Life 

The assumptions used for the average costs for new and used equipment i.e. 

equipment at the end of its useful life, are presented in Table VII-2 below. These cost 

values are used to calculate the residual value of equipment subject to early retirement. 

For example, the residual value for a top pick (container handling equipment) being 

replaced 3 years before the end of its normal expected life (16 years) is estimated to be: 

$65,625 = ($400,000 - $50,000) X 3 years

 16 years/useful life 

In this case, the early retirement costs attributed to compliance with the regulation for 

this top pick would be $65,625. 

Table VII-2: Estimated Value of New and Used Equipment10

Equipment Type New 2004 $ Used 

Crane $ 1,200,000 $ 0** 

Excavator $ 350,000 $ 50,000 

Forklift* NA NA 

Container Handling 

Equip $ 400,000 $ 50,000 

Sweeper/Scrubber $ 50,000 $ 5,000 

Tractor/Loader/Backhoe $ 75,000 $ 10,000 

Yard Tractor $ 60,000 $ 6,000 

*The estimated forklift values were difficult to establish due to the wide range of forklift 

sizes and costs. Only five forklifts in the state were estimated to be subject to early 

retirement near the end of their modeled natural attrition. The costs for these two 

forklifts are expected to be very low and were not included in the analysis. 

** Transportation costs could be equal to or more than the resale value. 

Incremental Costs Associated with Cleaner Engines: With the exception of yard trucks, 

it was assumed that there would be no additional incremental costs attributable to the 

regulation associated with purchasing a new cleaner off-road engine (i.e. replacing a tier 

1 engine with a tier 3 engine). For yard trucks, which will be in most cases transitioning 

from an off-road engine to an on-road engine, we assumed an incremental cost 

differential of $1,500 per yard truck. This cost difference is based on the current cost 

difference quoted by manufacturers for yard trucks with an off-road engine versus 

specifying an on-road engine. It is assumed that after 2010, when Tier IV engines are 

expected to become available, there will be no capital costs attributed to the purchase 

of yard trucks with on-road engines. 

Recurring Costs: Operating or recurring costs include expenditures for recordkeeping 

and reporting and possibly incremental fuel costs. Reporting costs for compliance with 

 

10 Various data sources; conversations with terminal operators (ARB, APL, 2005), equipment sales 

personnel inquiries (ARB, Ottawa, 2004), use internet sales websites. 
VII - 6 

the record keeping and reporting requirements in the proposed regulation was assumed 

to be $500 per terminal or business per year. Staff estimated approximately 5 hours 

would be needed to collect and send this information at a pay rate of $100 per hour. 

ARB staff believes this is a conservative assumption since many companies already 

keep these records. For both the passive and active DPF, additional operating and 

recurring costs for cleaning and replacement is expected to be $3,020 and $1,100 

annually for the cranes and forklifts, respectively. This additional operating and 

recurring costs for the cranes and forklifts is based on a $300 cleaning once every three 

years and replacement every six years. Staff estimates that the passive and active 

DPFs will last longer than the 4200 hours given in the warranties and six years for 

cranes and eight years for forklifts is approximately two times this warranty period. The 

cost for periodic cleaning of DPFs was assumed to be $300. These recurring fuel, DPF 

replacement, and cleaning costs are included in the annual costs presented in Table 

VII-7, Table VII-8, and Table VII-9.

Preferred Compliance Option

Based on our understanding of the technology available to comply with the proposed 

regulation and the compliance options, we identified likely compliance pathways that 

were then assumed for the cost analysis. While the proposed regulation provides 

flexibility to operators in determining what compliance option to pursue and the costs 

will vary with the approach chosen, we believe that the assumptions used in this cost 

analysis provide a representative picture of the potential costs associated with 

compliance. Tables VII-3 and VII-4 below summarizes the assumptions for new and inuse equipment respectively. 
VII - 7 

Table VII-3: Compliance Assumptions for New Equipment 

Equipment Category Compliance Path Assumed in Cost Analysis 

Cranes Until 2011, purchase new crane with current model year off-road 

engine. Apply passive DPF within one year of purchase. After 

2010, purchase crane equipped with Tier IV off-road engine. 

Excavators Until 2011, purchase new excavator with current model year offroad engine. Apply DOC within one year of purchase. After 

2010, purchase excavator equipped with Tier IV off-road engine. 

Forklifts Until 2011, purchase new forklift with current model year off-road 

engine. Apply active DPF within one year of purchase. After 

2010, purchase forklift equipped with Tier IV off-road engine. 

Container Handling 

Equipment 

Until 2011, purchase new container handling equipment with 

current model year off-road engine. Apply DOC within one year 

of purchase. After 2010, purchase container handling equipment 

equipped with Tier IV off-road engine. 

Sweeper/Scrubber Until 2011, purchase new sweeper/scrubber with current model 

year off-road engine. Apply DOC within one year of purchase. 

After 2010, purchase sweeper/scrubber equipped with Tier IV offroad engine. 

Tractor/Loader/ 

Backhoes 

Until 2011, purchase new tractor/loader/backhoe with current 

model year off-road engine. Apply DOC within one year of 

purchase. After 2010, purchase tractor/loader/backhoe equipped 

with Tier IV off-road engine. 

Yard Trucks Purchase yard truck with current model year on-road engine until 

2010. After 2010, purchase Tier IV off-road engine equipped yard 

truck. 
VII - 8 

Table VII-4: Compliance Assumptions for In-Use Equipment 

Equipment Category Compliance Path Assumed in Cost Analysis 

Cranes For Tier 0 engines, early retirement, either the 

equipment or just the engine depending on 

age. For Tier 1-3, assume 91% apply passive 

DPF and 9% early retirement until 2012 when 

Tier IV engines become available. 

Excavators For Tier 0 engines, early equipment 

retirement. For Tier 1-3, assume 100% apply 

DOC until 2012 when Tier IV engines become 

available. 

Forklifts For Tier 0 engines, early equipment 

retirement. For Tier 1-3, assume 100% apply 

Active DPF until 2012 when Tier IV engines 

become available. 

Container Handling 

Equipment 

For Tier 0 engines, early equipment 

retirement. For Tier 1-3, assume 100% apply 

DOC until 2012 when Tier IV engines become 

available. 

Sweeper/Scrubber For Tier 0 engines, early equipment 

retirement. For Tier 1-3, assume 100% apply 

DOC until 2012 when Tier IV engines become 

available. 

Tractor/Loader/Backhoes For Tier 0 engines, early equipment 

retirement. For Tier 1-3, assume 100% apply 

DOC until 2012 when Tier IV engines become 

available. 

Yard Trucks Early equipment retirement following the 

compliance phase-in schedule starting in 2007 

replacing with new on-road engine yard trucks. 

Assume 65% of the 1996 – 2005 model years 

yard trucks are offroad engines with an ECS, 

10% have offroad engines without any ECS, 

and 25% have on-road engines. 
VII - 9 

Future Year Equipment Populations Subject to the Regulatory Requirements

To determine the distribution of engines in future years and the number of engines 

needing to come into compliance in each year, the 2004 port and intermodal rail yard 

cargo handling equipment inventory was projected to future years using the OFFROAD 

model. The OFFROAD model calculates equipment growth, annual use, age 

distribution, and attrition for eight categories of equipment at ports and intermodal rail 

yards. Built into the model is the estimate of equipment by model year, by engine type 

(on-road or off-road) and with emissions control systems. Because the proposed 

regulation phases in compliance over several years, compliance with the proposed 

regulation in the early years will modify the distribution of engines in future years. To 

ensure the cost analysis was representative of future year equipment populations once 

the regulation takes effect, equipment populations in each year were evaluated after the 

compliance schedule for the previous year(s) had been incorporated into the model. 

When determining the percent of engines needing to come into compliance in a given 

year, it was assumed that all facilities had four or more pieces of equipment. For 

example, in 2007, 50 percent of yard trucks without VDECS which are 2002 model year 

or older need to come into compliance. To estimate the number of yard trucks in this 

group required to come into compliance, the population of yard trucks remaining in 2007 

with model years 2002 or older, that do not have VDECS, is multiplied by 0.50. 

Tables VII-5 and VII-6 below provide summaries of the yard truck and non yard truck 

equipment populations in each year (2007-2015) that resulted in compliance costs 

attributable to the proposed regulation. Additional details on the population distributions 

are provided in Appendix D. 

Table VII-5: Population of Yard Trucks Having Compliance Costs Associated with 

the Proposed Regulation 

Yard Truck Population 

Year New In-Use 

2007 290 83

2008 213 329

2009 195 259

2010 192 46

2011 201 89

2012 218 266

2013 215 303

2014 215 218

2015 226 83

Notes: New includes new yard trucks added to the fleet due to growth and new 

yard trucks added due to replacement of yard trucks at the end of their life (not 

required by the regulation) 
VII - 10 

Table VII-6: Population of Non-Yard Truck Equipment Having Compliance Costs 

Associated with the Proposed Regulation 

Population 

Crane Excavator Forklift Container 

Handling 

Equipment 

Sweeper/ 

Scrubber 

Tractor/ 

Loader/ 

Backhoe 

Year

New IU New IU New IU New IU New IU New IU 

2007 35 3 3 0 39 0 71 0 4 0 10 0

2008 37 14 5 0 34 4 70 5 4 0 12 1

2009 37 29 5 3 29 27 78 55 4 3 14 15

2010 41 86 4 5 30 99 88 107 5 6 15 20

2011 21 88 4 5 29 95 73 98 4 6 24 17

2012* 26 81 4 5 31 90 69 90 4 5 20 13

2013* 28 46 5 3 35 59 76 55 4 3 13 6

2014* 25 0 5 0 39 0 81 0 4 0 12 0

2015* 28 0 18 0 46 0 138 0 20 0 51 0

Notes: IU = In-Use. New includes new equipment added to the fleet due to growth and new 

equipment added due to replacement at the end of their life (not required by the regulation) except in

2015 New includes compliance replacement. 

* No associated cost for New due to available of Tier IV engines. 

Estimated Capital and Recurring Costs 2007-2020

The costs for compliance with the proposed regulation were estimated using the cost 

estimates outlined previously, the compliance assumptions provided in Table VII-3 and 

VII-4, and the populations of equipment subject to the requirements for each year. The 

detailed annual costs are provided in Appendix D and a summary of the total annual 

costs for the various types of equipment at ports and intermodal rail yards is provided in 

Table VII-7. 
VII - 11 

Table VII-7: Estimated Statewide Annual Costs for Businesses 

Annual Costs ($) 

Years 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 20

Port

Crane 657,449 1,267,413 1,444,345 2,304,489 2,069,158 1,756,177 1,396,157 792,553 792,553 792,553 792,553 Excavator 4,791 16,222 13,385 16,811 15,906 10,420 5,773 - 1,086,971 - Forklift 224,202 222,383 335,599 835,529 890,455 769,044 650,304 303,132 303,132 303,132 303,132 ContainerHandling Equip 150,604 324,865 321,960 536,765 582,917 516,350 543,034 423,533 2,134,138 423,533 423,533 Sweeper/ Scrubber 9,228 11,884 16,396 23,841 20,641 11,868 7,336 - 210,910 - Tractor/ Loader/ Backhoe 22,624 35,133 66,701 79,509 90,851 29,989 13,854 - 650,386 - Yard Tractor 1,694,673 6,668,378 4,787,993 964,678 1,762,313 4,500,234 4,976,988 3,201,918 1,083,030 - 

Port 

Total: 2,763,570 8,546,278 6,986,378 4,761,623 5,432,242 7,594,081 7,593,446 4,721,135 6,261,119 1,519,217 1,519,2

Rail

Crane 165,493 227,327 255,086 452,529 450,616 368,748 287,177 160,313 160,313 160,313 160,313 Forklift 8,327 25,270 37,533 46,096 47,500 36,247 22,686 14,318 14,318 14,318 14,318 Container Handling Equip 10,090 89,300 42,306 26,154 21,429 9,630 6,170 - 1,950,325 - Sweeper/ Scrubber 299 337 545 932 1,002 496 348 - 9,171 - Tractor/ Loader/ Backhoe 299 349 548 932 1,002 496 348 - 13,247 - Yard Tractor 124,077 266,602 134,197 96,825 154,285 31,232 38,446 - - - 

Rail Total: 308,585 609,185 470,215 623,469 675,835 446,849 355,177 174,631 2,147,374 174,631 174,63

Reporting Cost 1,200,000 60,000 60,000 60,000 60,000 60,000 60,000 60,000 60,000 60,000 60,0

Reporting, 

Port & Rail 

Total: 4,272,155 9,215,463 7,516,593 5,445,091 6,168,077 8,100,930 8,008,623 4,955,766 8,468,493 1,753,848 1,753,8
VII - 12 

D. Estimated Costs to Businesses 

In this section, we summarize the costs and economic impacts on businesses. The 

analysis estimates the overall total statewide cost to businesses and the total costs to 

different sectors of the industry. We also estimate the overall impact on business 

competitiveness, employment, and other business impacts as required by state law. 

Using the available information from the ARB Survey on the engine population and 

current in-use and expected PM emission rates, staff determined the percent of engines 

that would potentially incur capital costs (either from installing a DECS or purchasing 

new cargo handling equipment) when complying with the proposed regulation. 

We estimate the statewide total costs to businesses to be approximately $71 million 

dollars. The annual costs range from $1.8 million to about $9.2 million per year. The 

total statewide cost to businesses is derived from the combined capital and installation 

costs, using 2004 capital cost values, reporting costs and equipment operating and 

maintenance costs associated with compliance with the regulation. A summary of the 

expected annual costs was presented previously presented in Table VII-7. 

Costs to a Typical Business

For those businesses that operate at ports or intermodal rail yards and have diesel 

powered cargo handling equipment, the cost will vary depending on the age, number 

and type of equipment operated. To provide some perspective on the costs that may be 

incurred by a business, ARB staff estimated the average annual costs to comply with 

the regulation for the various types of equipment per year. This average annual cost is 

calculated by dividing the total annual statewide cost for each equipment type by the 

statewide inventory of that equipment type in a given year. This average annual cost 

can be used to determine the expected costs to a business for compliance with the 

regulation (2007-2020). The annual average reflects the fact that, while a single piece 

of equipment may incur a higher cost during a particular year if it needs to be retrofitted 

or replaced, not all pieces of equipment need to be retrofitted or replaced. To estimate 

the costs for a business, the average annual cost is summed over the consecutive 2007 

to 2020 years and multiplied by the number of pieces of equipment a business 

operates. For example, a business with 4 cranes would potentially incur a cost of 

14yrs X $4,736/yr X 4 cranes or approximately $265,200. The annual average values 

used to estimate the costs for businesses are provided in Table VII-8.
VII - 13 

Table VII-8: Estimated Statewide Average Costs per Equipment Type 

Annual Costs ($) 

Years 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 

Port

Crane 2,651 5,111 5,824 9,292 8,343 7,081 5,630 3,196 3,196 3,196 3,196 3,196 Excavator 171 579 478 600 568 372 206 0 38,820 0 0 0 Forklift 508 504 761 1,895 2,019 1,744 1,475 687 687 687 687 687 Container Handling Equip 327 705 698 1,164 1,264 1,120 1,178 919 4,629 919 919 919 Sweeper/ Scrubber 342 440 607 883 764 440 272 0 7,811 0 0 0 Tractor/ Loader/ Backhoe 246 382 725 864 988 326 151 0 7,069 0 0 0 Yard Tractor 852 3,353 2,407 485 886 2,263 2,502 1,610 545 0 0 0 

Rail

Crane 2,267 3,114 3,494 6,199 6,173 5,051 3,934 2,196 2,196 2,196 2,196 2,196 Forklift 362 1,099 1,632 2,004 2,065 1,576 986 623 623 623 623 623 Container Handling Equip 388 3,435 1,627 1,006 824 370 237 0 75,013 0 0 0 Sweeper/ Scrubber 299 337 545 932 1,002 496 348 0 9,171 0 0 0 Tractor/ Loader/ Backhoe 299 349 548 932 1,002 496 348 0 13,247 0 0 0 Yard Tractor 431 926 466 336 536 108 133 0 0 0 0 0 Reporting Cost 10,000 500 500 500 500 500 500 500 500 500 500 $500 
VII - 14 

Using these average costs, we estimated the costs that would be incurred by typical 

businesses. To determine a typical business, we used the ARB Survey to determine 

the average number and type of equipment operated by a port container terminal, a port 

bulk handling terminal and an intermodal rail yard. As shown in Table VII-9, total costs 

to a typical business can range from about $343,000 to $1,373,000 depending on the 

type and numbers of equipment. 

Table VII-9: Estimated Costs for Typical Businesses 

Port Container 

Terminal 

Port Bulk Terminal Intermodal Rail 

Equipment Yard 

Type Pop 2007-2020 

Cost ($) 

Pop 2007-2020 

Cost ($) 

Pop 2007-2020 

Cost ($) 

Crane 4 265,211 2 132,605 4 265,211 

Excavator 0 - 2 83,591 0 - 

Forklift 5 68,588 4 54,870 1 13,718 

Container 

Handling 

Equipment 

13 215,778 1 16,598 2 33,197 

Sweeper/ 

Scrubber 1 11,559 1 11,559 0 - 

Tractor/ 

Loader/ 

Backhoe 

0 - 2 21,501 0 - 

Yard Truck 54 804,711 1 14,902 17 253,335 

Reporting 

Costs 7,000 7,000 7,000 

Total 77 1,372,847 13 342,627 24 572,460 

Potential Business Impacts

In this section, we analyze the potential impacts of the estimated costs of the proposed 

regulation on business enterprises in California. Section 11346.3 of the Government 

Code requires that, in proposing to adopt or amend any administrative regulation, state 

agencies shall assess the potential for adverse economic impact on California business 

enterprises and individuals. The assessment shall include a consideration of the impact 

of the proposed or amended regulation on the ability of California businesses to 

compete with businesses in other states, the impact on California jobs, and the impact 

on California business expansion, elimination, or creation. 

This analysis is based on a comparison of the annual return on owner's equity (ROE) for 

affected businesses before and after the inclusion of the equipment costs, associated 

recurring costs, and fees. The analysis also uses publicly available information to 

assess the impacts on competitiveness, jobs, and business expansion, elimination, or 

creation. ARB staff does not have access to financial records for most of the privately-
VII - 15 

owned companies that responded to the ARB Survey. However, the small business 

status of the survey respondents was determined by including a query on the ARB 

Survey for the respondent to indicate if their business was a small business (annual 

gross receipts of $1,500,000 or less for transportation and warehousing per California 

Government Code Section 11342.610). Based on the ARB Survey responses, staff 

identified approximately 10 percent of the businesses (7 out of 69 of the respondents) 

identified themselves as small businesses. 

The types of businesses that may be impacted include stevedoring, major shipping 

lines, rail lines, and equipment rental. Based on the ARB Survey, staff estimates 

approximately 120 businesses will be affected by this regulation. 

The approach used in evaluating the potential economic impact of the proposed 

regulation on California businesses is as follows: 

(1) Affected businesses were identified from responses to the ARB survey. ARB staff 

identified four publicly traded companies representing various terminal types and 

Standard Industrial Classification (SIC) codes for evaluation. See Table VII-10. 

(2) Annual costs for the regulation are estimated for each of these businesses based 

on the estimated annual costs of typical businesses. 

(3) The total annual cost for each business is adjusted for both federal and states 

taxes. 

(4) These adjusted costs are subtracted from net profit data and the results used to 

calculate the Return on Owners' Equity (ROE). The resulting ROE is then 

compared with the ROE before the subtraction of the adjusted costs to determine 

the impact on the profitability of the businesses. A reduction of more than 10 

percent in profitability is considered to indicate a potential for significant adverse 

economic impacts. This threshold is consistent with the thresholds used by the 

U.S. EPA and others. 

Using Dun and Bradstreet financial data from 2001 to 2004, staff calculated the ROEs, 

both before and after the subtraction of the adjusted annual costs, for the typical 

businesses from each industry category. These calculations were based on the 

following assumptions. 

• All affected businesses are subject to federal and state tax rates of 35 percent and 

9.3 percent, respectively. 

• An affected business neither increases the prices of their products nor lowers their 

costs of doing business through cost-cutting measures because of the regulation. 

These assumptions, though reasonable, might not be applicable to all affected 

businesses. 
VII - 16 

Table VII-10: Representative Affected Businesses 

Co SIC 

Sales – 

 3 yr. Ave 

(million $) 

Cost 

($) 

Net 

Income 

(million $) 

Net Worth 

(million $) 

Adj. 

Fee ($) 

Adj. Net 

Income ($) 

ROE - 

Before 

ROE - 

After 

% 

Change 

A 

4412 3,279.8 

 

98,061 350.37 1,265.40 

 

57,812 

 

350,312,188 27.688% 27.684% -0.017% 

B 

4424 1,269.4 

 

98,061 80.10 812.87 

 

57,812 

 

80,042,188 9.854% 9.847% -0.072% 

C 

4789 9,823.3 

 

31,928 1,657.30 10,027.70 

 

18,823 

 

1,657,281,177 16.527% 16.527% -0.001% 

D 

4821 12,085.7 

 

36,351 1,176.70 11,886.70 

 

21,431 

 

1,176,678,569 9.899% 9.899% -0.002% 

California businesses are affected by the proposed annual cost of the regulation to the 

extent that the implementation of the proposed regulation reduces their profitability. 

Overall, most affected businesses will be able to absorb the costs of the proposed 

regulation with no significant adverse impacts on their profitability. This finding is based 

on the staff’s analysis of the estimated change in “return on owner’s equity” (ROE). The 

analysis found that the overall change in ROE ranges from negligible to a decline of 

about 0.1 percent. Generally, a decline of more than ten percent in ROE suggests a 

significant impact on profitability. Because the proposed regulation would not alter 

significantly the profitability of most businesses, we do not expect a noticeable change 

in employment, business creation, elimination, or expansion, and business 

competitiveness in California. 

Small Business Costs

Staff does not have access to financial records for most of the companies that 

responded to the survey. However, the small business status of the survey 

respondents was determined by including a query on the ARB Survey for the owner of 

the equipment to indicate if their business was a small business (annual gross receipts 

of $1,500,000 or less for transportation and warehousing per California Government 

Code Section 11342.610). Approximately 10 percent (7 out of 69) of the respondents 

identified themselves as small businesses. Looking at these seven businesses, six 

provided sufficient data on their equipment inventory to estimate the costs using the 

average equipment cost data presented in Table VII-8. Based on our analysis, the total 

2007-2020 costs to small businesses ranged from $41,000 to $638,000 with an average 

cost of $227,000. The company with the highest cost identified on the survey as owning 

nine cranes and four forklifts. The cranes are assumed to be rubber tired gantry cranes 

with the potential high cost of retrofitting a DPF. The company with the lowest cost has 

only three forklifts. Based on the overall change in ROE found for a typical business, 

which ranges from negligible to a decline of about 0.1 percent, the change in ROE is 

expected to be a little larger for a small business, but still well below the 10 percent limit. 

Potential Impact on Employment, Business Creation, Elimination or Expansion

The proposed regulation is expected to have no noticeable impacts on employment and 

business’ status. Businesses that manufacture, sell, install, repair, or clean diesel 

particulate emission control systems may experience an increase in demand for their 
VII - 17 

products or services, resulting in an expansion of those businesses or the creation of 

new businesses. Staff believes used engine dealers would not be eliminated; instead, 

we believe the dealers would adapt to incorporate additional refurbishment and 

upgrading of the engines for resale. 

ARB staff believes jobs will not be eliminated as a result of the regulation, but it may 

lead to the augmentation or alteration of job duties, leading to no net result change in 

the number of jobs. For example, a mechanic who previously worked on muffler 

installation would now be installing a VDECS. Staff believes additional training and 

emissions testing may be required for these additional duties, if not provided by the 

VDECS manufacturers. To the extent that VDECS are manufactured in California, 

some jobs may also be created. Some jobs will be created to install, repair, or clean 

DECS. 

E. Potential Costs to Local, State, and Federal Agencies 

This regulation does not directly affect any local, State, or Federal agencies. We 

anticipate some costs to the ARB to assist in implementation of the regulation; however, 

we believe these costs can be absorbed in our current and future budgets. 

F. Cost-Effectiveness 

In this section, the cost-effectiveness of the regulation is estimated. Cost-effectiveness 

is expressed in terms of control costs (dollars) per unit of air emissions reduced 

(pounds). As described below, for example, the cost-effectiveness for the proposed 

regulation is determined by dividing the total capital costs plus the annual operation and 

maintenance costs by the total pounds of diesel PM reduced during the years 2007 to 

2020. All costs are in 2004 equivalent expenditure dollars. 

Expected Emission Reductions

We estimated the projected total emission reductions under the regulation using the 

statewide inventory. The following Table VII-11 provides a summary of the annual 

statewide diesel PM reductions that will result from the proposed regulation. The total 

diesel PM reduced by this regulation is expected to be 1.73 million pounds over the 

calendar years 2007 to 2020. Table VII-12 provides a summary of the annual statewide 

diesel NOx reductions that will result from the proposed regulation. Negative values in 

the table represent NOx increases compared to the baseline. These slight NOx 

increases represent slight changes in the equipment age distribution and the resulting 

increased activity for newer equipment and little change in NOx emission factors. The 

total NOx reduced by this regulation is expected to be 37.3 million pounds over the 

calendar years 2007 to 2020. 
VII - 18 

Table VII-11: Estimated Statewide Diesel PM Annual Emission Reductions

Annual Diesel PM Reductions (lbs) 

Years 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 20

Port

Crane 1,952 4,636 7,520 11,672 13,792 13,845 13,781 13,066 12,128 12,006 11,621 11,184 Excavator 57 294 528 739 765 848 871 794 1,751 1,520 1,201 914 Forklift 381 944 1,516 2,486 3,165 3,701 3,896 3,701 3,413 3,173 2,976 2,605 Container Handling Equip 1,588 5,161 9,967 16,076 19,257 22,072 23,685 22,284 24,953 21,972 18,067 15,160 Sweeper/ Scrubber 27 83 173 275 331 378 385 350 759 647 515 400 Tractor/ Loader/ Backhoe 68 213 531 891 1,032 956 946 892 1,321 1,210 1,136 954 Yard Tractor 22,664 63,316 97,848 106,072 106,200 113,659 120,423 126,311 114,189 94,279 75,621 58,115 

Port Total: 26,737 74,646 118,082 138,212 144,542 155,460 163,987 167,399 158,516 134,807 111,137 89,333 

Rail

Crane 361 1,008 1,586 2,167 2,329 2,525 2,580 2,332 2,262 2,178 2,103 2,033 

Forklift 11 89 165 203 224 233 218 191 161 139 129 122 

Container Handling Equip 99 750 1,024 1,272 1,430 1,460 1,170 1,165 1,883 1,758 1,638 1,555 Sweeper/ Scrubber 1 3 5 9 11 12 13 13 27 24 19 15 Tractor/ Loader/ Backhoe 0 1 3 6 8 9 10 9 21 18 13 10 Yard Tractor 1,210 3,517 5,436 7,255 9,551 9,964 9,987 9,300 7,919 6,238 4,326 2,221 

Rail Total: 1,682 5,368 8,219 10,911 13,552 14,203 13,977 13,009 12,273 10,354 8,229 5,955 

Port & Rail Total: 28,419 80,014 126,300 149,123 158,094 169,662 177,964 180,408 170,789 145,162 119,366 95,288 
VII - 19 

Table VII-12: Estimated Statewide Cargo Handling Equipment NOx Annual Emission Reductions 

Annual NOx Reductions (lbs) 

Years 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 

Port

Crane 11204 22919 34214 53154 69561 42473 28739 16391 0 0 0 Excavator 0 2657 3651 3103 567 -515 -511 -499 53427 44209 32218 Forklift 0 2184 1980 997 446 -81 -79 -74 -70 -59 -50 Container Handling Equip 0 27842 37884 66627 88567 111192 146843 143493 325862 245301 156578 Sweeper/ Scrubber 0 372 510 433 157 -31 -30 -29 10796 9146 7156 Tractor/ Loader/ Backhoe 0 914 1044 1291 1452 -193 -192 -189 24985 21854 19630 Yard Tractor 636829 1738421 2540635 2585306 2518664 2999365 3446610 3694956 3182828 2468170 1972152 

Port 

Total: 648033 1795310 2619918 2710911 2679412 3152209 3621380 3854049 3597828 2788621 2187685 

Rail

Crane 0 4245 7084 6395 4196 3283 2557 -1950 -1917 -1896 -1865 

Forklift 0 783 1375 1274 1192 938 714 355 -5 -172 -169 

Container Handling Equip 0 7130 8658 9955 11585 10711 5853 5818 47142 42072 37269 Sweeper/ Scrubber 0 10 11 12 7 -2 -2 -2 853 723 552 Tractor/ Loader/ Backhoe 0 2 3 3 2 0 0 0 201 169 127 Yard Tractor 18571 62796 88214 120082 176468 246560 306195 337829 314572 292611 261241 

Rail 

Total: 18571 74965 105346 137721 193449 261490 315316 342051 360847 333506 297156 

Port & Rail Total: 666605 1870275 2725263 2848633 2872861 3413699 3936696 4196100 3958675 3122128 2484841 
VII - 20 

Cost-Effectiveness

To determine the cost-effectiveness of the proposed regulation, we divided the annual 

costs by the diesel PM emission reductions attributable to the regulation. The resulting 

cost-effectiveness in each year of implementation up to 2020 is listed in Table VII-13. 

The estimated overall annual cost-effectiveness, total PM reduced divided by total cost, 

is $41 per pound of diesel PM reduced, if all the costs of compliance are allocated to 

diesel PM reduction. The annual range is from $12 to $150 per pound of diesel PM 

reduction. 
VII - 21 

Table VII-13: Summary of Annual Diesel PM Cost-Effectiveness for the Cargo Handling Equipm

Annual Cost-Effectiveness ($/lbs) 

Years 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 

Port

Crane $337 $273 $192 $197 $150 $127 $101 $61 $65 $66 $68 Excavator $84 $55 $25 $23 $21 $12 $7 $0 $621Forklift $589 $236 $221 $336 $281 $208 $167 $82 $89 $96 $102 Container Handling Equip $95 $63 $32 $33 $30 $23 $23 $19 $86 $19 $23 Sweeper/ Scrubber $336 $142 $95 $87 $62 $31 $19 $0 $278Tractor/ Loader/ Backhoe $334 $165 $126 $89 $88 $31 $15 $0 $492Yard Tractor $75 $105 $49 $9 $17 $40 $41 $25 $9

Port 

Total: $103 $114 $59 $34 $38 $49 $46 $28 $39 $11 $14 

Rail

Crane $459 $226 $161 $209 $194 $146 $111 $69 $71Forklift $749 $285 $228 $227 $212 $156 $104 $75 $89 $103 $111 Container Handling Equip $102 $119 $41 $21 $15 $7 $5 $0 $1,035Sweeper/ Scrubber $329 $133 $113 $110 $95 $41 $27 $0 $344Tractor/ Loader/ Backhoe $615 $302 $195 $167 $132 $55 $36 $0 $620Yard Tractor $103 $76 $25 $13 $16 $3 $4 $0 $0

Rail 

Total: $182 $113 $57 $57 $50 $31 $25 $13 $172 $17 $21 

Port & Rail Total: $150 $115 $59 $36 $39 $48 $45 $27 $49 $12 $15 
VII - 22 

A summary of the overall average cost-effectiveness for the period 2007 through 2020 

is presented in Table VII-14. Overall, the cost-effectiveness for all equipment averages 

about $41 per pound of PM reduction. Since the regulation will also result in reductions 

in oxides of nitrogen (NOx) emissions, staff conducted a second cost-effectiveness 

analysis in which half of the cost of compliance was allocated to PM benefits and half 

the cost was allocated to NOx benefits. This results in cost-effectiveness values of 

$21/lb diesel PM and $1/lb of NOx. 

Table VII-14: Summary of Average Cost-Effectiveness for the Period 2007-2020 

 

Equipment Type 

Total 

Capital 

Cost 

2007 – 2020

Total PM 

Reduced 

(lbs) 

2007 - 2020 

Total PM CostEffectiveness 

($/lb) 

Total NOx 

Reduced 

(lbs) 

2007 - 2020

Port 

Cranes $ 16,443,058 148,598 $111 278,655 

Excavators $ 1,170,277 11,383 $103 181,668 

Forklifts $ 6,049,440 35,918 $168 5,085 

Container Handling 

Equipment $ 7,651,828 222,482 $34 1,534,823 

Sweeper/ Scrubber $ 312,102 4,803 $65 38,793 

Tractor/ Loader/ 

Backhoes $ 989,047 11,401 $87 98,530 

Yard Tractor $ 29,640,206 1,169,414 $25 32,100,651 

Intermodal Rail 

Crane $ 3,329,164 27,227 $122 14,779 

Forklift $ 323,886 2,107 $154 5,815 

Container Handling 

Equip $ 2,155,406 17,864 $121 271,820 

Sweeper/Scrubber $ 13,131 169 $78 2,961 

Tractor/Loader/ 

Backhoes $ 17,222 120 $144 686 

Yard Tractor $ 845,664 77,627 $11 2,731,939 

Reporting $ 1,980,000

Total $ 70,920,430 1,729,113 $41 37,266,204 

The cost-effectiveness of the proposed regulation for diesel PM is somewhat higher 

than other regulations recently adopted by the Board (see Table VII-15 below). For 

example, the diesel PM cost-effectiveness of the solid waste collection vehicle rule was 

estimated at $28 per pound, excluding the benefits of NOx and hydrocarbon reductions 

(ARB, 2003a). The cost-effectiveness of the stationary diesel engine airborne toxic 

control measure (ATCM) was estimated to range from $4 to $26 per pound of diesel PM 

reduced (ARB,2003b). Finally, the transport refrigeration unit ATCM was estimated to 

have a cost-effectiveness of $10 to $20 per pound of diesel PM reduced (ARB, 2003c). 

The cost-effectiveness of the proposed regulation for diesel PM is influenced by the 

adopted new engine standards which reduce the future emission reductions and thus 
VII - 23 

results in higher cost-effectiveness values. Nevertheless, the proposed regulation is an 

important step in reducing the serious public health impacts from diesel PM emissions 

in communities near ports and intermodal rail yards. 

Table VII-15: Diesel PM Cost-Effectiveness of the Proposal and Other 

Regulations/Measures (Attributes All Costs to Each Pollutant Individually) 

Diesel PM CostEffectiveness Regulation or 

Airborne Toxic Control Measure 

Dollars/ Pound PM 

Cargo Handling Equipment Proposal $41 

Solid Waste Collection Vehicle Rule $28 

Stationary Diesel Engine ATCM $4 - $26 

Transport Refrigeration Unit ATCM $10 - $20 

G. Analysis of Alternatives 

In this section, we compare the cost-effectiveness of the proposed regulation to two 

alternative control options. As described below, the two alternatives analyzed would 

achieve significantly less emission reductions and associated health benefits. However, 

the cost of these alternatives would also be lower, resulting in lower cost-effectiveness 

compared to the proposal. 

Alternative 1: Continue Voluntary Efforts

For alternative 1, it was assumed that the voluntary efforts would continue with newly 

purchased equipment until 2012 when new equipment would have Tier 4 off-road 

engines. The estimated costs to the equipment owners is approximately $1.9 million 

during the five years from 2007 to 2011 with an average annual cost of $380,000, if 

terminals and intermodal facilities continued to voluntarily continue their efforts to 

change-over their existing fleets at past rates. The total PM reduction associated with 

this alternative is 121 tons during the same 2007 to 2020 timeframe. The costeffectiveness for this alternative is lower than the regulation at $8 per pound of diesel 

PM reduced. Voluntary efforts would result in emission reductions, however, the 

emissions benefits would be substantially less than that predicted from the proposed 

regulation. The voluntary efforts would forego about 744 tons of PM and 18,215 tons of 

NOx that the proposed regulation would reduce. 

Alternative 2: Regulate Yard Trucks Only

Alternative 2 is similar to the proposed regulation, but would only affect the yard trucks. 

This reduction in the scope of the regulation reduces the cost by 50 percent and costeffectiveness by about 30%. The total cost would be $32.5 million with a diesel PM 

reduction of 1,247,140 pounds resulting in a cost-effectiveness of $26 per pound PM 

reduced. The NOx reduction would be 17,400 tons, about 1,230 tons less than the 
VII - 24 

regulation’s NOx reduction. The full regulation will cost $71 million and reduce diesel 

PM by 1,729,100 pounds. The full regulation is more costly at $41 per pound PM 

reduced, but reduces PM by an additional 481,970 pounds (241 tons) and NOx by an 

additional 1,230 tons during the same 2007 to 2020 timeframe 
VII - 25 

REFERENCES: 

 (ARB, APL, 2005) California Air Resources Board. Phone call with Mr. Michael 

Gedney, APL Terminal in Oakland, CA; Used yard truck and RTG crane values; 

May 2005. 

(ARB, Ottawa, 2004) California Air Resources Board. Conversation with Mr. Donald 

Lawerence, Ottawa; RTG Crane Costs, new and used, and yard truck cost differential 

for on-road engine; November, 3 2004. 

(POLB DECS) Port of Long Beach diesel emission reduction program retrofit cost data. 

Emission control device costs for different equipment. July 26, 2005. 

(ARB, 2003a) Air Resources Board, Staff Report: Initial Statement of Reasons for 

Proposed Rulemaking, Proposed Diesel Particulate Matter Control Measure for OnRoad Heavy-Duty Residential and Commercial Solid Waste Collection Vehicles, June, 

2003. 

(ARB, 2003b) Air Resources Board, Staff Report: Initial Statement of Reasons for 

Proposed Rulemaking, Airborne Toxic Control Measure for Stationary CompressionIgnition Engines, September, 2003. 

(ARB, 2003c) Air Resources Board, Staff Report: Initial Statement of Reasons for 

Proposed Rulemaking, Airborne Toxic Control Measure for In-Use Diesel-Fueled 

Transport Refrigeration Units (TRU) and TRU Generator Sets, and Facilities Where 

TRUs Operate, October, 2003.