Appendix L 

Requirements of Two-Engine Cranes 

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I. REQUIREMENTS FOR TWO-ENGINE CRANES 

A. Two- Engines Cranes 

Staff is proposing to address issues regarding two-engine on-road and off-road cranes 

by making both engines of two-engine cranes subject to the In-Use Off-Road Diesel 

Vehicle regulation and to remove the upper engines from the Portable ATCM regulation 

performance requirements. These issues facing the crane operators are related to 

safety and feasibility of repowering or retrofitting crane engines, and the complexity and 

unnecessary cost associated with complying with multiple regulations without any 

appreciable emission benefits. 

Two-engine cranes are defined as mobile diesel-powered machines with a hoisting 

mechanism mounted on a specially constructed truck chassis or carrier; one engine 

provides motive power, and a secondary engine is used to lift and move materials and 

objects. There are three general categories of two-engine cranes: lattice boom 

(conventional), all terrain or truck mounted. All terrain and truck mounted crane are 

very similar and can be categorized as truck mounted hydraulic cranes. The motive or 

drive engine is on-road engine. The secondary engine is off-road engine. 

B. Issues 

Concerns by crane operators regarding on-road cranes raised late during the off-road 

regulatory development process and could not be evaluated and workshopped in time 

to include them in the off-road regulation. The crane owners and operators requested 

that the two-engine cranes be included in the In-Use Off-Road Diesel Regulation. 

Please refer Chapter VII, Diesel Emission Reduction Regulations, of this document 

more information. The following were identified as reasons to support their request: 

• Compliance with more than one regulation 

• Replacement and retrofit of secondary Tier 0 engine feasibility 

• Manufacturers’ approval, technical support and availability for modifications 

• Compliance creates safety and design concerns 

• OSHA and Cal-OSHA re-certifications 

• Costs 

Two-engine cranes would fall under two regulations: one applying to the motive engine 

and another to the secondary engine. Generally, the motive engine would be subject to 

either the proposed On-Road Regulation, the Off-Road Regulation, or the Cargo 

Handling Equipment Regulation, depending on whether the engine is an on-road or offroad engine and where the crane operates. The secondary or upper engine of a twoengine crane is considered a portable engine and would be subject to the Portable 

ATCM Regulation if the engine is greater than 50 horsepower. Crane owners and 

operators can opt to register their secondary engine into PERP, which allows statewide 

equipment registration instead of individual air district permits or registrations (ARB, 

2007a). State fees associated with PERP on Tier 1 and 2 resident engines range from 
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$30 to $5,000 and district inspection and service fees ranged from $30 to $500 for non 

TSE cranes. 

The Portable Equipment ATCM Regulation requires retirement of all Tier 0 portable 

engines on January 1, 2010 and replacement with engines meeting the latest engine 

standard (Tier 3 engines for 75 to 750 horsepower). Additional portable engine PM 

emission reduction is achieved by engine exhaust retrofits or engine replacements, 

repowering, to meet PM emission fleet average based on engine horsepower. The 

compliance dates are January 1, 2013; January 1, 2017; and January 1, 2020 

respectively (ARB, 2007b). 

The Portable ATCM Regulation would require crane owners and operators to buy new 

cranes instead of used units due to the issues with repowering, retrofitting and safety 

discussed later in the document. In comparison, the Off-Road Regulation exhibit a 

smoother transition and spreads out vehicle replacements, allows fleets to clean-up 

other fleet vehicle engines to offset emissions, addresses safety issues, addresses 

replacement availability, and usage and flexibility provisions are already included in the 

Off-Road Regulation. 

For single-engine cranes where the motive engines serve a dual purpose of motive and 

lifting power, the proposed Statewide Truck and Bus Regulation would apply, since 

most single-engine cranes are equipped with an on-road engine. In cases where the 

single-engine crane is equipped with an off-road engine, the Off-Road Regulation will 

apply. However, if a crane operates at any time at a port of intermodal rail yard in 

California, the propulsion engine is subject to the Cargo Handling Equipment 

Regulation, regardless of whether the engine is on-road or off-road or whether the crane 

has only one engine or two (ARB, 2006). Many crane operators own cranes that are 

brought onto the port or intermodal rail yard facilities on an as-needed basis. These 

cranes would be required to comply with the Cargo Handling Equipment Regulation, 

whereas, they would otherwise be required to comply with the proposed On-Road 

Regulation or the Off-Road Regulation, along with rest of the owners’ fleets. 

1. Feasibility of Repowering and Retrofitting 

Any changes to the crane requires the manufacturers to approval those changes. The 

willingness of manufacturers to approve such changes is limited or unlikely and would 

be cost prohibitive. Crane manufacturers assume a huge financial risk for a failure of 

their product. They are reluctant to assume liability for a California market requirement 

which represents low sale volume of cranes worldwide. Some OEM crane 

manufacturers are no longer in existence since there has been a contraction in the 

number of companies producing cranes. 

Crane’s secondary engines are frequently controlled by electronic control systems and 

software unique to the crane make, model and model year (Sierra, 2007). 

Reprogramming the control system to accept a different model or model year engine 

would require technical support of the crane manufacturer. Crane manufacturers would 
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have to update the operation/safety manuals to document the affect of any of the 

changes. 

The repowering or retrofitting of the secondary engine has considerable feasibility 

issues not present for most portable engines including other two-engine vehicles. Since 

the engine and the diesel particulate filter, DPF, could be physically larger than the 

original engine, this fact could lead to space limitations. The engine compartment may 

be too small to physically fit the new engine or allow for proper air circulation in a 

confined area and require modification to the cooling system. Repowering to a Tier 3 

and Tier 4 engine would require the use of electronic fuel injection and an electronic 

control module, ECM. Modification to the existing wiring harness or a new wiring 

harness would be necessary to connect the ECM to engine function sensors and other 

electrically controlled devices to monitor/control engine performance. Modifications to 

the exhaust system may be required to accommodate exhaust exit and DPF locations. 

2. Safety and Design 

The design complexity of cranes and modifications to the original design cannot be 

easily accomplished. Cranes manufacturers would have to engineered the changes 

and design/specify parts to ensure safe crane operations. For example, the repowering 

or retrofitting secondary engine creates safety and design concerns. The secondary 

engine is part of the counterweight system of the crane. A small weight change could 

have a significant impact on a crane’s lifting capacity and interfere with the electronic 

controls programmed into the crane’s positioning system year (Sierra, 2007). 

3. Certifications 

Cranes manufacturers certify their equipment to OSHA and ANSI requirements to 

ensure safe operation and to prevent damage to the crane. Any modification, alteration 

or change to a crane which affects its original design, and not authorized and approved 

by the crane manufacturer is strictly prohibited and voids any manufacturer warranties. 

Repowering or retrofitting secondary crane engines will first require crane 

manufacturers’ approval and secondly require recertification by OSHA and Cal-OSHA 

(Sierra, 2008 and Sierra 2007). 

Even with crane certifications, accidents do occur. There were 72 fatalities in 2006 and 

average of 78 fatalities per year from 2003 to 2005 associated with cranes in 

construction (US BLS, 2008). Crane fatalities can be caused crane tip-over, struck by 

the load or cab/counterweight and boom/cable failures. 

4. Cost 

The crane cost curves were developed from MachineryTrader.com. A limited number of 

two-engine truck mounted hydraulic/all terrain cranes and truck lattice boom cranes 

were for sale and listed with the necessary engine or horsepower information. The 

price curves developed were in dollars per horsepower since the off-road model utilizes 

cost data in this format. These cost curves are located in Appendix. I. Besides age of 
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the crane, cost will vary based on lifting capacity and boom length of these cranes. 

Both types of cranes are expensive compared to most other vehicles. 

C. Emission Impact 

Thirteen crane owners and operators provided us with fleet information. Fleets included 

off-and on-road cranes powered by single off- or on-road motive engines, and off-road 

two-engine cranes powered by off- or on-road motive engines with off-road secondary 

engines. The different crane types listed in various fleets included: all terrain, lattice 

boom, crawler, and rough terrain. The fleets were either medium or large fleets based 

on their total horsepower which included the motive and secondary engines. 

The off-road model was utilized to determine fleet actions and the off road inventory 

was used to calculate the PM and NOx emissions for 2010 through 2030 for both offand on-road motive and secondary engines. The off-road model is able to calculate 

emissions for on-road engines since it has both on- and off-road emission factors. 

Hours of usage, emissions and load factors from the off-road model were used in the 

emission calculations. 

Table 1 and Table 2 contain details of the two-engine cranes used in emission 

calculations. 

Table 1: Two-Engine Crane Types 

Crane Type Quantity 

Truck Mounted Hydraulic 59 

Truck Mounted Lattice Boom 34 

Total 93 

 Table 2: Two-Engine Crane Engines 

Crane Type Off-Road 

Drive Engine 

On-Road 

Drive Engine 

Off-Road 

Secondary 

Engine 

Truck Mounted Hydraulic 6 53 59 

Truck Mounted Lattice Boom NA 34 34 

Currently, PERP has approximately 262 crane secondary engines registered in their 

program. The California Department of Motor Vehicle (DMV) 2006 database had 2,113 

cranes registered as passenger vehicle. The information provided by the crane owners 

and operators had 227 DMV registered cranes. Ninety three of them were two-engine 

cranes or 41 percent (93 divided 227). Using this percentage and applying it to the 

DMV database information, staff estimates that there are 866 two-engine cranes. Staff 

used 93 two-engine cranes in their analysis using the off-road model to estimate the 

emissions benefits of the proposed changes. The results was scaled up by a factor of 

9.31 (866 divided by 93) to reflect the total emissions from the cranes affected. The 

results are compared to the emissions expected with normal replacement and the 
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expected benefits from the Portable Equipment ATCM Regulation and the Off-Road 

Regulation. 

It appears that a minority of crane owners and operators registered their secondary or 

portable engine in PERP and they instead opt to register or permit with the appropriate 

local air quality districts. 

Staff used the off-road model to determine baseline emissions with all existing 

regulations applied to the crane operator fleet equipment. First, the baseline emissions 

were calculated by determining the normal replacement cycle expected to be used by 

the individual fleets analyzed. Second, staff estimated the emissions reductions from 

two engine cranes that would have occurred from eliminating the operation of 

uncontrolled (Tier 0) secondary engines starting January 1, 2010 and by calculating the 

PM reductions expected from the portable ATCM requirements phased in from 2013 to 

2020. Secondary engines in lattice boom cranes are exempt until 2020 and no 

reductions from these engines are estimated until 2020 when few are expected to 

remain operational. Third, staff calculated the emissions reductions expected from all of 

the off-road drive engines subject to the off-road vehicle regulation. Since the off-road 

vehicle regulation does not have engine replacement requirements for fleets with less 

than 2501 hp there were no NOx benefits expected from a number of the fleets. The 

new baseline was then calculated by subtracting the benefits expected from the OffRoad Regulation and the Portable Equipment ATCM from the emissions expected 

without regulation. 

As shown in Figure 2 and Table 3, there is a slight increase in NOx emissions in 2010 

through 2013 from the current proposal compared to emissions with existing 

regulations, but there is a considerable benefit after 2013. 

Figure 1: NOx Emissions Benefits of Staff Proposal 

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

2010201120122013201420152016201720182019202020212022202320242025

NOx (tpd)

Existing Regulations

Staff Proposal
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Table 3: Statewide NOx Emissions Reductions from Proposed Regulation 

NOx Emissions (tons per day) Projected Reductions Calendar 

Year Baseline With the 

Regulation (tons per day) Percent from Baseline 

2010 6.0 6.2 -0.2 -3% 

2014 5.0 4.7 0.3 6% 

2017 4.1 3.2 0.9 22% 

2020 3.3 2.0 1.3 38% 

2023 2.9 1.8 1.0 36% 

As shown in Figure 1 and in Table 4 the PM emissions would be slightly higher in 2010 

and 2011, but would be substantially better thereafter. The baseline emissions with 

existing regulations, shows a considerable drop in 2018 because many of the crane 

fleets would be considered small fleets in the off-road vehicle regulation and would not 

need to replace engines or install PM retrofits until 2015. Because of normal 

replacement, most fleets in 2015 would meet the PM average and would not need to 

install a significant number of exhaust PM retrofit devices until 2018 and 2019. 

Figure 2: PM Emissions Benefits of Staff Proposal 

0.00

0.05

0.10

0.15

0.20

0.25

0.30

0.35

2010201120122013201420152016201720182019202020212022202320242025

PM (tpd)

Existing Regulations

Proposed Regulation
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Table 4: Statewide PM Emissions Reductions from Proposed Regulation 

PM Emissions (tons per day) Projected Reductions Calendar 

Year Baseline With the 

Regulation (tons per day) Percent from Baseline 

2010 0.312 0.326 -0.013 -4% 

2014 0.251 0.177 0.074 29% 

2017 0.224 0.106 0.118 53% 

2020 0.134 0.067 0.066 50% 

2023 0.112 0.062 0.050 45% 

D. References 

ARB, 2006. Air Resources Board. Regulation for Mobile Cargo Handling Equipment at 

Ports and Intermodal Rail Yards. December 2006. 

ARB, 2007a. Air Resources Board, Regulation to Establish a Statewide Portable 

Equipment Registration Program. September 27, 2007. 

http://www.arb.ca.gov/regact/2007/perp07/froreg.pdf

ARB, 2007b. Air Resources Board. Airborne Toxic Control Measure for Diesel 

Particulate Matter From Portable Engines Rated at 50 Horsepower and Greater. 

September 12, 2007. http://www.arb.ca.gov/portable/perp/peatcm091207.pdf

ARB, 2008. Air Resources Board. Regulation for In-Use Off-Road Diesel Vehicles. 

June 15, 2008. http://www.arb.ca.gov/regact/2007/ordiesl07/frooal.pdf

US BLS, 2008, US Bureau of Labor Statistics. Crane Related Occupational Fatalities 

Fact Sheet July 2008. 

MachineryTrader, 2008. Machinery Trader. Construction Equipment for Sale: Crane. 

October 5, 2008. www.machinerytrade.com

Sierra, 2008. Sierra Research. Letter From Gary Rubenstein of Sierra Research to 

Tony Brasil of ARB with attachments. March 14, 2008. 

Sierra, 2007. Sierra Research. Letter From Allan Daly to Clerk of the Board of ARB of 

ARB with attachments. March 21, 2007. 
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Sierra Research 2007 
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Copyrighted page/s removed. Copyrighted material is not available in 

Regulations.gov since it may not be reproduced without consent of 

the copyright holder. 

Contact the EPA Docket Center’s Public Reading Room to view 

or receive a copy of this document. 

Requests for copies may be made as follows: 

In person/writing: 

Environmental Protection Agency, Docket Center 

1301 Constitution Ave NW, 2822T, Room 3334 

Washington, DC. 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov 
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Sierra Research 2008 
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Emission Benefits 

CY

Total Nox 

TPD No 

Rule All 

Engines

Total Nox TPD 

Off Road Rule 

Upper & Drive 

Engines

Nox 

Reduction 

TPD ATCM 

Rule Upper 

Engine

Nox 

Reduction 

TPD Off 

Road Rule 

Drive 

Engine

Nox TPD 

Net 

Benefit

Nox % 

Net 

Benefit CY

9.31X 

Scaled 

Baseline 

Nox TPD

9.31X 

Scaled OffRoad Rule 

Nox TPD CY

9.31X 

Scaled 

Nox TPD 

Net 

Benefit

Average 

Nox TPD

2010 0.647893 0.638169 0.030540 0.000610 -0.021425 -3% 2010 6.032 6.231 2010 -0.199 -0.130

2011 0.644393 0.622010 0.032895 0.000626 -0.011138 -2% 2011 5.999 6.103 2011 -0.104

2012 0.615869 0.591812 0.035673 0.001151 -0.012766 -2% 2012 5.734 5.853 2012 -0.119

2013 0.575626 0.549508 0.035891 0.000543 -0.010317 -2% 2013 5.359 5.455 2013 -0.096

2014 0.532712 0.467304 0.027673 0.004681 0.033053 6% 2014 4.960 4.652 2014 0.308 0.847

2015 0.492167 0.411966 0.024546 0.007408 0.048248 10% 2015 4.582 4.133 2015 0.449

2016 0.470984 0.365102 0.022374 0.012039 0.071469 15% 2016 4.385 3.719 2016 0.665

2017 0.443090 0.304467 0.022227 0.016714 0.099683 22% 2017 4.125 3.197 2017 0.928

2018 0.426081 0.275418 0.020704 0.014005 0.115955 27% 2018 3.967 2.887 2018 1.080

2019 0.367785 0.221082 0.009371 0.021179 0.116153 32% 2019 3.424 2.343 2019 1.081

2020 0.353574 0.183434 0.006642 0.028922 0.134576 38% 2020 3.292 2.039 2020 1.253

2021 0.311082 0.163597 0.007075 0.022192 0.118219 38% 2021 2.896 1.796 2021 1.101

2022 0.303903 0.157305 0.007557 0.020635 0.118404 39% 2022 2.829 1.727 2022 1.102

2023 0.308561 0.167239 0.008098 0.022854 0.110370 36% 2023 2.873 1.845 2023 1.028

2024 0.293607 0.167522 0.008722 0.024468 0.092896 32% 2024 2.733 1.869 2024 0.865

2025 0.289411 0.166875 0.007280 0.015749 0.099507 34% 2025 2.694 1.768 2025 0.926

2026 0.276511 0.158615 0.007695 0.014034 0.096167 35% 2026 2.574 1.679 2026 0.895

2027 0.252758 0.158022 0.006110 0.008944 0.079683 32% 2027 2.353 1.611 2027 0.742

2028 0.245726 0.157766 0.006145 0.009528 0.072288 29% 2028 2.288 1.615 2028 0.673

2029 0.235109 0.152322 0.006231 0.004361 0.072195 31% 2029 2.189 1.517 2029 0.672

2030 0.233823 0.151475 0.003906 0.010224 0.068218 29% 2030 2.177 1.542 2030 0.635

CY

Total PM 

TPD No 

Rule All 

Engines

Total PM TPD 

Off Road Rule 

Upper & Drive 

Engines

PM 

Reduction 

TPD ATCM 

Rule Upper 

Engine

PM 

Reduction 

TPD Off 

Road Rule 

Drive 

Engine

PM TPD 

Net 

Benefit

PM % Net 

Benefit CY

9.31X 

Scaled 

Baseline 

PM TPD

9.31X 

Scaled OffRoad Rule 

PM TPD CY

9.31X 

Scaled 

PM TPD 

Net 

Benefit

Average 

PM TPD

2010 0.033563 0.032050 0.002794 0.000161 -0.001441 -4% 2010 0.312 0.326 2010 -0.013 -0.009

2011 0.033198 0.030533 0.002817 0.000353 -0.000505 -2% 2011 0.309 0.314 2011 -0.005

2012 0.031231 0.026363 0.002885 0.000583 0.001401 4% 2012 0.291 0.278 2012 0.013 0.055

2013 0.029248 0.020427 0.002825 0.001283 0.004713 16% 2013 0.272 0.228 2013 0.044

2014 0.026917 0.014911 0.002592 0.001475 0.007939 29% 2014 0.251 0.177 2014 0.074

2015 0.025449 0.010859 0.002633 0.001876 0.010081 40% 2015 0.237 0.143 2015 0.094

2016 0.024720 0.007738 0.002762 0.002386 0.011835 48% 2016 0.230 0.120 2016 0.110

2017 0.024082 0.004689 0.003073 0.003660 0.012660 53% 2017 0.224 0.106 2017 0.118

2018 0.023073 0.003844 0.003150 0.003226 0.012853 56% 2018 0.215 0.095 2018 0.120

2019 0.015755 0.003109 0.002256 0.002689 0.007701 49% 2019 0.147 0.075 2019 0.072

2020 0.014345 0.002266 0.002425 0.002541 0.007113 50% 2020 0.134 0.067 2020 0.066

2021 0.013344 0.001815 0.002640 0.002312 0.006577 49% 2021 0.124 0.063 2021 0.061

2022 0.012050 0.001741 0.002645 0.002341 0.005323 44% 2022 0.112 0.063 2022 0.050

2023 0.012021 0.001619 0.002600 0.002398 0.005404 45% 2023 0.112 0.062 2023 0.050

2024 0.009550 0.001563 0.002606 0.002259 0.003122 33% 2024 0.089 0.060 2024 0.029

2025 0.009829 0.001573 0.002315 0.001836 0.004106 42% 2025 0.092 0.053 2025 0.038

2026 0.008709 0.001565 0.002168 0.001882 0.003093 36% 2026 0.081 0.052 2026 0.029

2027 0.007202 0.001562 0.002059 0.001797 0.001784 25% 2027 0.067 0.050 2027 0.017

2028 0.006899 0.001569 0.002064 0.001196 0.002070 30% 2028 0.064 0.045 2028 0.019

2029 0.006503 0.001558 0.001964 0.001051 0.001930 30% 2029 0.061 0.043 2029 0.018

2030 0.006452 0.001558 0.001758 0.001063 0.002073 32% 2030 0.060 0.041 2030 0.019
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