A2-1

Attachment 2

Potential Economic Impacts of Modifications to the “No VDECS Available” Compliance 

Extension for Mobile Cargo Handling Equipment Operating at Ports and Intermodal Rail 

Yards

The Board directed staff to make modifications to the amendments to the “Regulation 

for Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards” (Cargo 

Handling Regulation or regulation). These modifications involved subsection 2479(f)(2), 

Compliance Extension Based on No Verified Diesel Emission Control Strategy (VDECS)

for Non-Yard Truck Mobile Cargo Handling Equipment. This section was modified such 

that fleets applying for a third and fourth year “No VDECS Available” compliance 

extension would be required to replace eligible equipment with electric or hybrid 

equipment, if available. The modifications were made to incentivize the addition of 

electric and hybrid cargo handling equipment (CHE) to fleets operating at ports and 

intermodal rail yards. While these modifications will result in an emissions benefit, and 

consequently no significant adverse impacts, they will also result in additional economic 

impacts to CHE fleets. Estimates of possible emissions and cost impacts are provided 

in this attachment. The resulting cost-effectiveness of the amendments, updated to 

include the impacts of these modifications, is also presented. Worksheets with the 

calculations for the emissions and costs impacts for these modifications are posted on 

ARB’s web site at http://www.arb.ca.gov/ports/cargo/cheamd2011.htm (ARB, 2012).

Anticipated Compliance Methods

In order to estimate the possible economic and emissions impacts of requiring the 

purchase of electric or hybrid equipment, ARB staff made an assessment of electric and 

hybrid technologies currently, or imminently, available to CHE fleets. While the 

extension is only available for non-yard truck equipment, the modifications allow other 

equipment to be considered for replacement with electric or hybrid equipment, so both 

yard truck and non-yard truck equipment were evaluated. ARB staff determined that the 

electric and hybrid technologies currently, or imminently, available are confined to yard 

trucks, rubber-tired gantry (RTG) cranes, and forklifts capable of 7,000 pounds of lift or 

less. ARB staff estimates that a 65 horsepower (hp) forklift is comparable to an electric 

forklift capable of lifting 7,000 pounds. Staff determined that compliance with the 

proposed modifications will be primarily through the purchase of electric yard trucks and

the purchase of a few small electric forklifts. Staff does not believe that hybrid or 

electric RTG cranes will be a significant avenue for compliance with the proposed

modifications as there is a VDECS available for RTG cranes and nearly all RTG cranes 

will be brought into compliance through either retrofit, repower, or replacement by the 

final compliance date for non-yard truck equipment, the end of 2013. The purchase of 
A2-2

electric forklifts is also not expected to be a major avenue of compliance because very 

few of the port and rail yard forklifts are small enough to electrify. 

For the updated analysis to determine the impacts of the modifications, ARB staff used

data from its previous economic impact analysis that considered the initial proposal to 

provide fleets with an additional two-year extension for equipment for which no VDECS 

is available for compliance. Those data were set forth in Appendix C of the Initial 

Statement of Reasons Supporting the Proposed Amendments to the Regulation for 

Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards (ISOR). In the 

initial analysis, it was estimated that fleets would request an additional two-year 

extension for 312 pieces of non-yard truck equipment. The years in which these pieces 

of equipment would be required to comply with the regulation was also estimated, as 

shown in Table A2-1 below. 

Table A2-1. Required Compliance Years for Non-Yard Truck Equipment with 

Third and Fourth Year “No VDECS Available” Extension 

Year Number of Equipment 

Required to Comply

2011

2012

2013 13

2014 42

2015 82

2016 88

2017 87

Total 312

Note: All numbers are rounded

The updated analysis assumes that fleets would request this extension for all eligible 

equipment regardless of the proposed additional terms added to the extension 

requirements. This is the most conservative assumption possible for this analysis, 

resulting in the highest possible cost, in that it is anticipated that some fleets will choose 

to bring equipment into compliance rather than purchase hybrid or electric equipment. 

Staff estimated how many of the 312 extensions could potentially result in the purchase 

of electric or hybrid equipment. Fleets that do not have equipment that can feasibly be 

replaced with electric or hybrid equipment may still obtain the extension, provided they 

demonstrate that their fleet does not contain equipment that can be replaced by electric 

or hybrid models. 

Based on the equipment distribution for the 312 pieces of equipment of the original “No 

VDECS Available” economic analysis (ARB,2011g), staff has determined that seven 
A2-3

would be fork lifts that are small enough to be replaced with electric at the end of the

fourth extension year. 

Staff then estimated how many of the remaining 305 pieces of equipment were 

potentially in fleets with noncompliant yard trucks that could potentially be replaced with 

electric models. Staff reviewed the most recent CHE reporting data (ARB, 2011m) to 

determine the number of noncompliant yard truck and non-yard truck equipment and 

concluded that fleets with both noncompliant non-yard truck equipment and 

noncompliant yard truck equipment1 could potentially elect to comply by obtaining 

additional years of extension and ultimately purchasing an electric yard truck. Based on 

the reporting data, it was determined that approximately 62 percent of the noncompliant 

non-yard truck equipment resides in fleets with noncompliant yard trucks. Consequently 

it was assumed that 62 percent of the 305 pieces of equipment (189 pieces of 

equipment) would be in fleets with noncompliant yard trucks, and could potentially 

comply by replacing a noncompliant yard truck. Table A2-2 provides the maximum 

numbers of pieces of equipment required to come into compliance after third and fourth 

year “No VDECS Available” compliance extensions that also have noncompliant yard 

trucks in the same fleet, if all eligible fleets choose to apply for the additional years of 

extension. 

Table A2-2. Noncompliant Non-Yard Truck Equipment Eligible for a “No VDECS 

Available” Compliance Extension with NonCompliant Yard Trucks in 

Fleet

Year Number of Equipment 

Required to Comply

2011

2012

2013 8

2014 25

2015 50

2016 53

2017 53

Total 189

Note: All numbers are rounded

An analysis was made of the noncompliant yard trucks residing in fleets with 

noncompliant non-yard truck equipment to estimate the number of noncompliant yard 

trucks in fleets during the years when the equipment would be required to comply. 

Based on this analysis, the number of noncompliant yard trucks available for potential 

 1 This extension is only applicable to non-yard truck equipment. Therefore, this option is not available to 

fleets containing only noncompliant yard truck equipment.
A2-4

replacement with electric in the different compliance years was estimated and is shown 

in Table A2-3. 

Table A2-3. Noncompliant, Yard Truck Engines Eligible to be Replaced with 

Electric or Hybrid Equipment

Year Noncompliant, Yard 

Truck Equipment 

2013 573

2014 360

2015 137

2016 40

2017 0

Note: All numbers are rounded

Staff compared the number of non-yard truck equipment in fleets that would be required 

to comply after the third and fourth years of extension with the number of noncompliant 

yard trucks in these same fleets that would be available for replacement with electric. 

Based on these comparisons, an estimate of the number of yard trucks which could

potentially be replaced with electric was made and is shown in Table A2-4. 

Table A2-4. Noncompliant Yard Truck Engines Potentially to be Replaced with 

Electric By Compliance Year

Compliance Year Pieces of Equipment

2013 8

2014 25

2015 50

2016 40

2017 0

Total 123

 Note: All numbers are rounded

In total, it was estimated that 123 noncompliant yard trucks could potentially be replaced 

with electric models. Consequently, of the 312 pieces of equipment that could obtain 

the additional years of extension, 7 could potentially result in small forklifts being 

replaced with electric models and 123 could potentially result in a different piece of 

equipment, a noncompliant yard truck, being replaced with electric models. The 

remaining equipment, in fleets without equipment that could feasibly be replaced with 

electric or hybrid models, could receive the additional years of extension and then be 

required to demonstrate that their fleet did not contain any noncompliant equipment that 

could be replaced with electric or hybrid models. 
A2-5

Economic Impacts

The proposed 15-day modifications to subsection 2479(f)(2) would require fleets that 

elect to receive an additional two-year extension for equipment for which no VDECS is 

available to determine if the equipment for which the extension is granted, or a different 

piece of equipment, may be replaced with electric or hybrid equipment. As previously 

discussed in the section “Anticipated Compliance Methods”, staff believes that, in terms 

of the equipment for which the extension is granted, only small forklifts would be 

replaceable with electric or hybrid models. Consequently, for all other equipment in 

fleets that have elected to request the extension, fleets would need to evaluate if there 

is another piece of equipment in the fleet that could be replaced with either electric or 

hybrid models. However, if there is no equipment replaceable with either electric or 

hybrid models, the fleets may still be granted the extension.

It is anticipated that most fleets that elect to receive the third and fourth year extension 

will choose to wait until the end of the final extension period to replace equipment with 

electric or hybrid equipment. If, at that time, it is determined that the equipment for 

which the extension is granted cannot be replaced with electric or hybrid, an evaluation 

of other noncompliant equipment would be made. The proposed modifications allow the 

owner or operator to evaluate only noncompliant equipment for replacement with 

electric or hybrid equipment. It would not require compliant equipment to be replaced 

with electric or hybrid equipment. Staff anticipates that compliance will be achieved 

primarily through replacing noncompliant yard trucks with electric yard trucks along with 

replacing a few small forklifts with electric forklifts. 

The costs and benefits of the initial proposal to allow an additional two years of “No 

VDECS Available” extension were previously evaluated and documented in the 

rulemaking documents for the amendments. The incremental cost for the modifications 

involves only the costs associated with the additional actions required by the 

modifications - that is, the optional requirement that fleets electing to receive a third and 

fourth year of extension must replace equipment with electric or hybrid models, if 

feasible. These costs were evaluated by comparing the cost to bring this noncompliant 

equipment into compliance with the regulation’s performance standards to the costs 

associated with replacing this equipment with electric or hybrid equipment.

Under the regulation’s performance requirement, noncompliant equipment is required to 

be brought into compliance by either retrofit, replacement, or retirement. Currently there 

are no VDECS available for yard trucks that would bring them into compliance with the 

performance requirements, so yard trucks would either be replaced with a yard truck 

with an engine certified to the current on-road engine emission standards or the off-road 

Tier 4 final emission standards or retired. While there are retrofit options for some 
A2-6

forklifts, the primary compliance method for forklifts has been replacement with new 

diesel equipment equipped with an off-road engine certified to the current off-road 

engine emissions standards. Consequently, the incremental cost for these 

modifications can be reasonably estimated based on the difference between the cost for 

new diesel equipment and the cost for electric equipment. 

ARB staff contacted several equipment suppliers to obtain approximate costs for new 

diesel forklifts and yard trucks and new electric forklifts. The cost for new electric yard 

trucks was estimated based on information from the manufacturer of the electric truck 

being demonstrated at the Port of Los Angeles (Balqon, 2011). These costs are

provided in Table A2-5. 

Table A2-5. Equipment Costs for New Diesel and New Electric Equipment (2011 

Dollars)

Equipment Type New Diesel 

Cost($)

New Electric 

Cost($) Cost Differential ($)

Yard Truck $98,500 $204,000 $105,500

Forklift $30,000 $45,000 $15,000

 Note: All numbers are rounded

The estimated additional costs to CHE fleets applying for the third and fourth years of a 

“No VDECS Available” compliance extension are shown in Table A2-6 and Table A2-7. 

The estimated total additional cost is $10,774,000 spread over the period from 2013 to 

2017. As set forth in Appendix C to the ISOR, the original proposal to provide a third 

and fourth year of “No VDECS Available Extension” without being tied to an 

electric/hybrid purchase was estimated to produce a cost savings. The cost savings 

associated with delaying the compliance costs for 312 pieces of equipment was 

estimated at approximately $4.3 million. The net cost for this amendment, including the 

modifications, is about $6,450,000, or approximately $6.5 million.
A2-7

Table A2-6. Additional Cost for Replacing Noncompliant Yard Trucks with 

Electric (2011 Dollars)

Year

Number of 

Yard Trucks

Available

Future Cost

of Electric 

Yard Trucks

(2011 $)

Future Cost

of Diesel 

Yard Trucks

(2011 $)

Present Value

Cost of Electric

Yard Trucks

Present Value

Cost of Diesel

Yard Trucks

Present 

Value

Cost

Differential

2013 8 $1,632,000 $788,000 $1,480,000 $715,000 $766,000 

2014 25 $5,100,000 $2,463,000 $4,406,000 $2,127,000 $2,278,000 

2015 50 $10,200,000 $4,925,000 $8,392,000 $4,052,000 $4,340,000 

2016 40 $8,160,000 $3,940,000 $6,394,000 $3,087,000 $3,306,000 

Total 123 $25,092,000 $12,116,000 $20,671,000 $9,981,000 $10,690,000

Note: All numbers are rounded

Table A2-7. Additional Cost for Replacing Noncompliant Forklifts with Electric

(2011 Dollars)

Year Number of 

Forklifts

Future Cost

of Electric 

Forklifts

(2011 $)

Future Cost

of Diesel 

Forklifts

(2011 $)

Present Value

Cost of Electric

Forklifts

Present Value

Cost of Diesel

Forklifts

Present 

Value 

Cost

Differential

2014 2 $90,000 $60,000 $78,000 $52,000 $26,000

2015 1 $45,000 $30,000 $37,000 $25,000 $12,000

2016 2 $90,000 $60,000 $71,000 $47,000 $24,000

2017 2 $90,000 $60,000 $67,000 $45,000 $22,000

Total 7 $315,000 $210,000 $253,000 $169,000 $84,000

Note: All numbers are rounded

The cost of the initially proposed amendments to the regulation was summarized in 

Table V-1 of Chapter V of the ISOR. The amendments were estimated to result in a net 

savings of $1 million to $2 million, as shown in Chapter V of the ISOR. The costs 

attributed to the proposed 15-day modifications to the regulation have been added to 

the original estimated costs in Table A2-8 below. The 15-day modifications if fully 

utilized could result in an overall net cost of the amendments, as fully proposed, on the 

order of approximately $10 million over the 2011 through 2020 time period. This is the 

most conservative (highest possible) estimate of the amendment costs. Fleets may 

choose to bring their equipment into compliance instead of applying for the additional 

third and fourth year of “No VDECS Available” compliance and having to purchase 

electric or hybrid equipment. In that case, there would be neither a cost nor savings 

attributable to the additional two years of compliance extensions and the requirement to 

purchase hybrid or electric equipment (item 1 in Table A2-8 below). Without the 

additional costs that could be incurred with having to replace equipment with electric or 

hybrid models, the overall net cost of the amendments as proposed would be 

approximately $2.4 million over the 2011 through 2020 time period. 
A2-8

Table A2-8: Costs or Savings Associated With Proposed Amendments over Years 

2011 through 2020 in 2011 Dollars

Amendment Description Costs Savings Costs/(Savings)

($ millions)

1. Additional time for equipment with no 

VDECS available and modifications to 

require purchase of hybrid or electric 

equipment

X 0* to $6.5**

2. Add safety as provision for no VDECS 

available extension 0

3. Low-use compliance extension X ($3.3)

4. Exempt equipment at low-throughput ports in 

NOx-exempt areas not within 75 miles of an 

urban area

X ($1.0)

5. Require CHE opacity testing and set 

maximum allowable levels X $2.1 to $3.0

6. Allow demonstration of emissions 

equivalency X

7. Non-yard truck equipment transfers X ($1.4)

8. Manufacturer delays for new equipment 0

9. Warranty engine replacement X

10.Treat Tier 4 engines certified to FEL Alt PM 

emissions standards as Tier 3 engines X $6.0

11.Add flexibility to extension for experimental 

diesel PM emissions control X 0

12.Allow compliance schedule swapping N/A*** N/A*** 0

Net Costs/(Savings)* X $2.4 to $9.8

*No economic impact if fleets choose not to use this option.

** Estimated highest possible cost for item 1 – may be significantly less depending on choices made by

fleets. 

***N/A - Not applicable 

Note: All numbers are rounded

Emissions Benefit

Benefits Associated with 15-Day Modifications

The emissions benefit resulting from the electrification of equipment was evaluated 

based on the compliance scenario described in the previous section “Anticipated 

Compliance Methods” and evaluated in the section “Economic Impacts.” In this 

scenario, of the 312 pieces of equipment which could potentially receive the third and 

fourth year compliance extension, only 7 small forklifts would be replaced with electric 
A2-9

forklifts at the end of the final extension period. Fleets with the remaining 305 pieces of 

equipment, would determine if there is another noncompliant piece of equipment in their 

fleet that could be replaced with electric or hybrid models. Staff estimated that in the 

case of 123 of this equipment, the fleets would have a noncompliant yard truck that 

could potentially be replaced with an electric yard truck. In the remainder of the cases, 

the fleets would demonstrate that their fleet does not contain any noncompliant 

equipment that could feasibly be replaced with electric or hybrid models. In summary, 

for this scenario, which is the most optimistic in terms of emissions reductions and most 

conservative in terms of cost, all equipment replaced with electric or hybrid equipment 

would be either small forklifts or noncompliant yard trucks and all would be replaced 

with electric models.

The emissions benefit was evaluated as the on-site emissions difference between the

new diesel equipment which would have been purchased for compliance with the 

regulation and electric equipment purchased for compliance with the proposed 

modifications. Staff first estimated the emissions of yard trucks and small forklifts that 

would have complied with the regulation by meeting the regulation’s performance 

standards. The diesel engine evaluated for the forklifts was assumed to be certified to 

off-road Tier 4 final emission standards with an 18 year equipment life. The diesel 

engine evaluated for the yard trucks was assumed to be certified to either the 2010 onroad emissions standards or the off-road Tier 4 final emission standards, both with an 8 

year equipment life. It then compared those estimated lifetime emissions to the on-site

zero emissions that would occur if fleets elected to replace the forklifts and yard trucks 

with electric equipment as part of the extension option. Staff found that the complianceextension options if involving 123 electric yard trucks and 7 electric forklifts would result 

in reductions of approximately 4,299 pounds of PM and 53 tons of NOx over the life of 

the replaced equipment. If hybrid equipment becomes available, the resulting costs and 

emission reductions would both be expected to be reduced. 

Methodology for Determining Modifications’ Emissions Benefits

Average load factor and annual hours of operation for yard trucks and forklifts were 

determined from Appendix B: Emissions Inventory Methodology, of the ISOR. The 

average horsepower for the forklifts were estimated from the original “No VDECS 

Available” Amendment economic analysis (ARB, 2011g). The average yard truck 

horsepower was estimated from the recent CHE reporting data (ARB, 2011m). The 

useful life for forklifts and yard trucks were estimated from the attrition table of the CHEI 

Model (ARB, 2011f). These values are summarized in Table A2-9 below. Emission 

factors and degradation were also determined from the CHEI Model (ARB, 2011f). 
A2-10

Table A2-9. Equipment Description for Determining Emission Benefits

Yard Trucks Forklifts

Average Horsepower 198 62.5

Average Annual Hours of 

Operation 2020 701

Average Load Factor 0.39 0.3

Useful Life (years) 8 18

Diesel Engine Emission 

Limit 2010 on-road or Tier 4 final Tier 4 final

Note: All numbers are rounded

Emissions Benefits of Amendments

The emissions impacts of the amendment were provided in Table IV-9 of Chapter IV of 

the ISOR. As documented in Table IV-9 of the ISOR, an overall diesel PM benefit of

approximately 31 tons or 62,000 pounds of diesel PM and a dis-benefit of 135 tons of 

NOx were estimated for the initially proposed amendments. With the additional benefits 

of the modifications, discussed above, the emissions impacts of the fully implemented 

amendments would have an overall diesel PM benefit of 33 tons, or 66,000 pounds, and 

a reduced NOx dis-benefit of 82 tons of NOx. 

Cost-Effectiveness

The cost-effectiveness of the amendments, including the proposed modifications, was

estimated based on the total estimated cost of the amendments and total estimated 

emissions benefit of the amendments.

Since there was a PM emissions benefit but a NOx disbenefit, cost-effectiveness was 

calculated attributing all costs associated with the amendments, as modified by the 

15-day modifications, to the PM reduction. This value is provided in Table A2-10. 

Table A2-10. Cost-Effectiveness of All Amendments with Modifications

Cost Attribution Total Cost Emissions Benefit Cost-Effectiveness

All costs to PM $8.9 million to 9.9 

million

66,000 pounds PM $135 to $150 per 

pound of diesel PM

Note: all numbers are rounded

The cost-effectiveness of these amendments is higher than that of the initially-adopted 

regulation, which had an estimated cost-effectiveness of $41 per pound of diesel PM 

reduced. Other diesel measures recently approved by the Board have costeffectiveness values as high as $76 per pound (the recently amended in-use off-road 

equipment regulation). However, the optional-extension requirement is not mandatory 

and fleets may choose to bring their equipment for which no VDECS are available into 

compliance through either replacement or retirement. If fleets chose not to apply for the
A2-11

two additional extension years for equipment without VDECS available, any costs or 

savings associated with the “No VDECS Available” amendment would not be realized 

and the overall cost of the amendments would be reduced, as shown in Table A2-8 

above. Additionally, if technology advancements are made in the intervening years, 

costs for electric and hybrid models could be substantially reduced, also resulting in 

reduced costs. Both of these factors would result in improved cost-effectiveness.

Impact on Overall Cost of Amendments per Year

The costs per year for the initially proposed amendments impacting small and typical 

businesses were provided in Table V-12 of Chapter V of the original ISOR. This table is 

reproduced below with the costs of the 15-day modifications added. 

Table A2-11: Summary of Annual Costs/(Savings) Resulting from 

Proposed Amendments (Present Value)

Year

Additional 2 Years for

VDECS*

Low-Use 

Extension*

Small Rural 

Ports

Off-Road*

Require Opacity 

Monitoring

Non-Yard 

Truck

Transfers*

Allow

Tier 4 FEL 

Original Engines*

Proposal*

Modifications:

Purchase 

Hybrid or 

Electric 

Equipment*

Minimum* Maximum*

2011 ($257,000) ($1,468,000) ($303,000)

2012 ($603,000) ($1,094,000) ($560,000) $231,000 $1,446,000 ($190,000) $1,019,000

2013 ($1,169,000) $766,000 ($751,000) ($118,000) $224,000 $186,000 ($181,000) $1,012,000

2014 ($1,181,000) $2,304,000 $226,000 $189,000 ($173,000) $1,521,000

2015 ($1,109,000) $4,352,000 $232,000 $193,000 ($165,000) $1,348,000

2016 $3,330,000 - $236,000 $197,000 ($157,000) $1,142,000

2017 $22,000 $241,000 $201,000 ($149,000)

2018 $242,000 $202,000 ($142,000)

2019 $243,000 $202,000 ($135,000)

2020 $241,000 $200,000 ($129,000)

Total ($4,319,000) $10,774,000 ($3,313,000) ($981,000) $2,116,000 $3,016,000 ($1,421,000) $6,042,000

* Values have been rounded
A2-12

Impact on Small Business

The costs from the proposed 15-day modifications to the regulations would not 

significantly impact the costs for a typical small business subject to the regulation. ARB 

staff reviewed the types of equipment in smaller fleets (estimated as those fleets with 

less than 15 pieces of equipment) (ARB, 2011m) and found that the vast majority of 

these fleets, approximately 75 percent, do not have yard trucks. Therefore, these 

smaller fleets would generally not be in position to replace a noncompliant yard truck 

with an electric yard truck to meet the conditions required for the additional two-year 

extension under the proposed 15-day modifications. However, if the fleet does not have 

noncompliant equipment that could be replaced with electric or hybrid equipment, the 

proposed modifications do not prevent an extension for third and fourth years of “No 

VDECS Available” from being granted. Several small business fleets do have small 

forklifts and may elect to take advantage of the additional two-year extension if they 

have equipment for which no VDECS are available in exchange for agreeing to replace 

its forklifts with electric or hybrid models at the completion of the extension period. 

While the forklifts that are small enough to electrify are a small portion of the total forklift 

population, it was assumed that a typical small business could have one forklift to 

electrify. 

The tables showing the capital and operating and maintenance (O&M) costs for small 

businesses from Appendix C of the ISOR have been updated to include the additional 

costs attributable to the 15-day modifications, which are presented below. The 

incremental cost for the purchase of one electric forklift was estimated as one-seventh 

of the total estimated cost differential for purchase of seven electric forklifts, provided in 

Table A2-7 above. 

Table A2-12 provides the number of equipment impacted by each amendment, as 

provided in Table C-27 in Appendix C of the ISOR, updated to include the impacts 

attributable to the 15-day modifications. As discussed above, the purchase of one

electric forklift is added to this table. 
A2-13

Table A2-12: Numbers of Equipment Affected by Proposed Amendments During 

2011 through 2020 for a Typical Small Business

Typical Small Business

Total Inventory 11 

# of Equipment Affected by Amendment (2011 - 2020)

# No VDECS 2

# Low Use 1

# Equipment Transfers 0

# FEL engines 1

Yard Truck Electrification 0

Forklift Electrification 1

Note: All numbers are rounded

Total capital costs due to the proposed amendments for a typical small business were

estimated for both the situation where the fleet chose to obtain the two additional years 

of “No VDECS Available” extension, and consequently purchase a small electric forklift

and the case where the fleet chose not to apply for the additional years of compliance 

extension. In the second situation, neither the benefits nor the costs associated with the 

additional extension years would be incurred. These costs are provided in Table A2-13 

and summarized in Table A2-14. For the fleet analyzed, the choice of applying for the 

additional years of compliance extension results in a net cost savings of approximately 

$7,500 while the choice not to apply for these additional years of compliance results in a 

net cost of approximately $8,000. 
A2-14

Table A2-13: Capital and O&M Costs/(Savings) as a Result of Proposed 

Amendments During 2011 through 2020 for a Typical Small Business

Overall Capital Costs/(Savings) from 2011 to 2020

No VDECS ($27,690)

Low Use ($18,824)

Equipment Transfers $ -

FEL engine $26,969

Yard Truck Electrification $ -

Forklift Electrification $12,000

Total ($7,545)

Total without costs or savings of 

additional “No VDECS Available” 

extension years

$8,145

Annual Operating and Maintenance: 

Opacity

$660

Note: All numbers are rounded

Note: Opacity costs provided in Table C-28 from Appendix C of the ISOR have been removed as these 

are not capital costs but a summation of the annual O&M costs. The annual O&M costs are reported in

the last row of this table. 

The overall economic impacts of the amendments, including the 15-day modifications, 

are summarized in Table A2-14 below. 

Table A2-14: Summary Economic Impact on Small Business

Small Business 11 CHE

Equipment Population 11

Capital Cost – (2011-2020) ($7,545) to $8,145

Ongoing Annual Costs $660

Note: All numbers are rounded

Impact on Typical Business

A typical business was approximated in the ISOR as a container terminal with 77 pieces 

of equipment. A review of typical container terminals indicated that approximately 

60 percent of the equipment in these fleets are yard trucks. Consequently, it could be 

expected that a typical terminal would be able to comply with the modifications by 

purchasing electric yard trucks at about the same rate as the general fleet population. 

The tables showing the capital and O&M costs for typical businesses from Appendix C 

of the ISOR have been updated to include the additional costs that could be attributed

to the proposed 15-day modifications and are presented below. 
A2-15

Table A2-15 provides the number of equipment impacted by each amendment, as 

provided in Table C-32 in Appendix C of the ISOR, updated to include the impacts 

attributable to the 15-day modifications. As discussed above, the number of electric 

yard trucks to be purchased is added to this table. No electric forklifts were assumed to 

be purchased. 

Table A2-15: Numbers of Equipment Affected by Proposed Amendments During 

2011 through 2020 for a Typical Container Terminal Business

Typical Container Terminal Business

Total Inventory 77 

#of Equipment Affected by Amendment (2011 - 2020)

# No VDECS 4

# Low Use 2

# Equipment Transfers 1

# FEL engines 4

Yard Truck Electrification 4

Forklift Electrification 0

Note: All numbers are rounded

The costs or savings associated with each of the amendments, as modified by the 

15-day modifications, are provided in Table A2-16. The incremental cost of the 

purchase of electric yard trucks was determined based on the estimated incremental 

cost for the purchase of 123 yard trucks in Table A2-6 above. 

Total capital costs due to the proposed amendments for a typical container terminal

business was estimated for both the situation where the fleet chose to obtain the two 

additional years of “No VDECS Available” extension, and consequently purchase 

electric yard trucks, and the case where the fleet chose not to apply for the additional 

years of compliance extension. In the second situation, neither the benefits nor the 

costs associated with the additional extension years would be incurred. These costs 

are provided in Table A2-16 and summarized in Table A2-17. For the fleet analyzed, 

the choice of applying for the additional years of compliance extension results in a net 

cost of approximately $293,000 while the choice not to apply for these additional years 

of compliance results in a net cost of approximately $750.
A2-16

Table A2-16: Capital and O&M Costs/(Savings) During 2011 through 2020 as a 

Result of Proposed Amendments for a Typical Container Terminal Business

Overall Capital Costs/(Savings) from 2011 to 2020

No VDECS ($55,379)

Low Use ($37,648)

Equipment Transfers ($78,976)

FEL engine $107,875

Yard Truck Electrification $347,642

Forklift Electrification $ -

Opacity $9,500

Total $293,014

Total without costs or savings of 

additional “No VDECS Available” 

extension years

$751

Annual Operating and Maintenance: 

Opacity

$3,850

Note: All numbers are rounded

Note: Opacity costs provided in Table C-33 from Appendix C of the ISOR have been replaced with the 

capital costs related to opacity testing. The original costs on Table C-33 were a combination of the 

capital costs and a summation of the annual O&M costs. The annual O&M costs are reported in the last 

row of this table.

The overall economic impacts of the amendments, including the 15-day modifications,

are summarized in Table A2-17 below. 

Table A2-17: Summary Economic Impact on Typical Business

Typical Business 77 CHE

Equipment Population 77

Capital Cost – (2011-2020) $751 to $293,014

Ongoing Annual Costs $3,850

Note: All numbers are rounded

Impact on Local Government

It is not anticipated that the 15-day modifications would have any impact on local 

government agencies. While at least two local government agencies own and operate 

cargo handling equipment and may request additional years of “No VDECS Available” 

compliance extensions, neither of these agencies own yard trucks or small fork lifts that 

would be required to be replaced with electric or hybrid models. Nor is it expected that 

electrified models of the equipment for which the extension is granted would be 

technically feasible at the end of the two-year extension period. 
A2-17

References:

(ARB,2011f) California Air Resources Board, Cargo Handling Emissions Inventory 

Model, http://www.arb.ca.gov/ports/cargo/cheamd2011.htm July 2011.

(ARB, 2011g) California Air Resources Board, EconomicAnalysisWorksheets.xls, 

http://www.arb.ca.gov/ports/cargo/cheamd2011.htm July 2011.

(ARB, 2011m) California Air Resources Board, CHE Equipment Reporting Data

Updated as of September 2011, 2011.

(ARB, 2012) California Air Resources Board, 

ModificationsEconomicAnalysisWorksheets.xls, 

http://www.arb.ca.gov/ports/cargo/cheamd2011.htm February 2012. 

(Balqon, 2011) Personal Correspondence, Samra Balwinder, December 8, 2011.