1 UPDATED INFORMATIVE DIGEST

REQUIREMENTS TO REDUCE IDLING EMISSIONS FROM NEW AND IN-USE TRUCKS, BEGINNING IN 2008

Sections Affected: Amendment of sections 1956.8, along with the incor porated

“California Exhaust Emission Standards and Test Pro cedures for 2004 and Subsequent Model Heavy-Duty Diesel Engines”, 2404, 2424, 2425, and 2485 of Title 13, California Code of Regulations (CCR).

Background: The California Clean Air Act as codified in Healt h and Safety Code (HSC) sections 43013 and 43018 directs the Air Reso urces Board (ARB or Board) to adopt emission standards for new heavy-duty motor v ehicles to achieve maximum

feasible emission reductions. HSC section 43104 di rects the ARB to adopt test procedures to ensure compliance with those emission standards. Further, in August 1998, the Board identified diesel exhaust particula te matter (diesel PM) as a toxic air contaminant and consequently, in October 2000, it a dopted the “Diesel Risk Reduction Plan” which, among other measures, included a measu re to reduce emissions from idling diesel trucks and buses in order to reduce t he public’s exposure to diesel PM.

Accordingly, on December 12, 2002, the Board adopte d the School Bus Idling Airborne Toxic Control Measure (ATCM) that limits school bus idling and idling at schools. This ATCM requires operators of school buses, transit bu ses, and other commercial vehicles to manually shut off their engines upon arriving at a school and limits idling to thirty seconds before departure from a school. Additional ly, the ATCM limits idling of school buses to 5 minutes outside of school properties.

Subsequent to the adoption of the School Bus Idling ATCM, the ARB, on July 22, 2004, adopted the Diesel-Fueled Commercial Motor Vehicle Idling ATCM, which includes more general requirements to limit emissions from i dling trucks and buses. This ATCM requires operators of commercial trucks and buses t o manually shut off their engines before the idling time limit of five minutes is rea ched. However, this requirement does not apply to idling sleeper berth equipped trucks u nless they are located within 100 feet of residential areas or schools. This exemption wa s provided at the time the rule was adopted because of unresolved issues regarding how emissions from the diesel-fueled auxiliary power system (APS) compared to the emissi ons from “cleaner” 2007 and subsequent model year trucks. Therefore, the Board deferred consideration of sleeper trucks until 2005 in order to thoroughly evaluate a ll commercially available options to main engine idling.

On October 20, 2005, the Board conducted a hearing to consider staff’s proposal to remove the existing sleeper truck exemption so that sleeper trucks would have to comply with the five-minute idling restriction at a ll times and at any location. The proposal also included idling reduction requirement s for new heavy-duty diesel engines and emission performance requirements for technolog ies used as alternatives to main engine idling. At the conclusion of the hearing, t he Board adopted Resolution 05-55, in which it approved the originally proposed amendment s with several modifications and2

directed the Executive Officer to incorporate the m odifications into the proposed regulatory text, with such other conforming modific ations and technical amendments as may be appropriate, and to make the modified text a vailable for a supplemental comment period of at least 15 days.

Staff’s revised regulations and test procedures, wi th the modified text clearly indicated, were made available to the public for a supplementa l 15-day comment period on June 26, 2006. Several written comments were recei ved during the 15-day supplemental comment period. Staff has responded t o all comments received during the regulatory process, including those submitted i n response to the notice of June 26, 2006, in its Final Statement of Reasons re garding this rulemaking.

Description of Regulatory Action: On October 20, 2005, the Board adopted amendments that establish idling reduction requirem ents for sleeper berth equipped trucks and new heavy-duty diesel engines and emissi on performance requirements for technologies used as alternatives to main engine id ling.

Specifically, starting in January 2008, the regulat ion removes the existing sleeper truck exemption so that sleeper trucks would have to comp ly with the five-minute idling restriction at all times and at any location. This requirement applies to trucks registered in California and out-of-state. The requirement al so provides options to accommodate driver comfort during times when the truck is requi red to shut down. Some of the cab comfort devices, such as internal combustion APSs a nd fuel-fired heaters, produce emissions. Therefore, emission performance require ments are established for these systems, which differ depending on whether the truc k’s engine is a 2007 or later model.

Currently, all APS engines have to be certified to the off-road emission standards. Beginning in 2008, trucks with 2007 and subsequent model year engines equipped with a PM filter will have the additional requirement to either retrofit the APS separately with a “level 3” PM reducing device, which achieves an 8 5% reduction in emissions, or route the APS’s exhaust through the PM filter of the truc k’s engine. Trucks equipped with 2006 or older model year engines do not have PM fil ter and so owners may use an APS without adding a PM control device.

Beginning in calendar year 2008, all 2007 and subse quent model year trucks equipped with fuel-fired heaters will need to comply with th e fuel-fired heater emissions requirements, specified in the Low Emission Vehicle Program, to operate in California.

Starting with the 2008 model year, new truck engine s are also required to either be equipped with a non-programmable and tamper-resista nt engine shutdown system that automatically shuts down the engine after 5 minutes of idling or optionally to meet an oxides of nitrogen (NOX) idling standard of 30 gram s per hour. The new engine requirements apply to diesel engines in trucks with a gross vehicle weight rating greater than 14,000 pounds. The new engine requirements do not apply to gasoline engines or engines produced for use in buses (commercial buses as well as school buses), emergency vehicles, military vehicles, and recreati onal vehicles.3

COMPARABLE FEDERAL REGULATIONS

There are no federal or other state requirements th at are equivalent to the requirements adopted in this regulation. However, a number of s tates and local governments have general idling ordinances that require truck operat ors to turn off their engines after a specific period of idling time. California’s diffe rent and more stringent idling reduction program will benefit human health, public welfare, and the environment. In addition, the differences from the federal program are authorized by Health and Safety Code

sections 43013 and 43018.

BENEFITS OF THE PROPOSAL

The combined statewide benefits from reducing idlin g of sleeper berth equipped trucks are estimated to be 46 tons per day of oxides of ni trogen emissions, 4.2 tons per day of reactive organic gas emissions, 0.4 tons per day of PM, and 1930 tons per day (0.7 million tons per year) of carbon dioxide emissions, in 2010, based on the assumption that all sleeper trucks use diesel-fueled APS as a substitute to idling the main engine and all sleeper trucks comply fully with the requir ements in the regulation.

Staff’s proposal is expected to provide a net cost savings to truck owners over the useful life of the cab comfort device through reduc ed fuel use and reduced engine

maintenance. It is difficult to calculate cost sav ings associated with using cab comfort devices since there are many variable that affect t he calculation, such as the cost of the device, whether or not it consumes fuel and how muc h, the amount of time a truck operates at idle, the cost of fuel, and other varia bles. Based upon the least efficient cab comfort technology, a diesel-fuel APS with a Level 3 PM filter, and the average time a sleeper truck operates at idle, staff estimated an operational cost savings of $4,280 per year, from reduced fuel consumption and engine main tenance. Assuming a 5 year useful life for the diesel-fueled APS, staff estima tes a net cost saving of $11,300.

In order to calculate cost effectiveness, staff ign ored the cost savings associated with the use of a cab comfort device in lieu of operatin g the truck engine. The cost effectiveness for 2008 and subsequent model year he avy duty diesel trucks equipped with a non-programmable engine shutdown system and a diesel-fueled APS with a level 3 verified PM filter is estimated to be $2.00 per p ound of NOx plus ROG reduced.

For 2007 model year trucks, the engines would not h ave the automatic shutdown system but the trucks would have a PM filter. Thus , if a diesel-fueled APS was installed it would require a PM filter. Retrofitting 2007 tr ucks with a diesel-fueled APS with a level 3 verified PM filter produces a cost-effectiv eness estimate of $1.98 per pound of NOx plus ROG reduced.

For 2006 and older model year California trucks equ ipped with a diesel-fueled APS, a PM control device would not be required. Thus, the cost-effectiveness is estimated to be $1.44 per pound of NOx plus ROG reduced.4

Because most fleets have a distribution of truck mo del years, the average cost-effectiveness estimate for fleets is $1.51 per pound of NOx plus ROG reduced. These worst-case estimates for pre-2007, 2007, and post-2007 model year heavy-duty diesel engines, all compare favorably to the cost-e ffectiveness estimates of other ARB regulations recently adopted, even if the cost savi ngs are ignored.