STAFF REPORT: INITIAL STATEMENT OF REASONS FOR PROPOSED 

RULEMAKING 

PROPOSED AMENDMENTS TO THE REGULATION FOR IN-USE OFF-ROAD 

DIESEL-FUELED FLEETS AND IMPLEMENTATION UPDATE 

Mobile Source Control Division 

Heavy Duty Diesel In-Use Strategies Branch 

December 2008 

State of California 

AIR RESOURCES BOARD 

STAFF REPORT: INITIAL STATEMENT OF REASONS 

Public Hearing to Consider 

PROPOSED MODIFICATIONS TO THE REGULATION FOR IN-USE OFF-ROAD 

DIESEL-FUELED FLEETS AND IMPLEMENTATION UPDATE 

To be considered by the Air Resources Board at a meeting of the Board that will 

commence on January 22, 2009, and may continue to January 23, 2009, at 

California Environmental Protection Agency 

Air Resources Board 

Byron Sher Auditorium 

1001 I Street 

Sacramento, California 95814 

Mobile Source Control Division: 

Robert Cross, Chief 

Heavy-Duty Diesel In-Use Strategies Branch: 

Erik White, Chief 

Off-Road Implementation Section: 

Kim Heroy-Rogalski, Manager 

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. 

State of California 

AIR RESOURCES BOARD 

PROPOSED MODIFICATIONS TO THE REGULATION FOR IN-USE OFF-ROAD 

DIESEL-FUELED FLEETS AND IMPLEMENTATION UPDATE 

Contributing Authors

Elizabeth Yura 

Michael Baker 

Eric Brown 

Cory Parmer 

Elizabeth White 

Jeff Wilson 

Legal Counsel

Michael Terris, Office of Legal Affairs 

Supporting Divisions

Mobile Source Operations Division 

Planning and Technical Support Division 

Research Division 

Stationary Source Division 

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. 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ................................................................................................ 1

I. INTRODUCTION ...................................................................................................... 9

A. Background .......................................................................................................... 9

B. Report Overview................................................................................................... 9

II. TECHNOLOGY UPDATE....................................................................................... 11

A. ARB’s Verification Program ................................................................................ 11

B. Status of Current Off-Road Verifications ............................................................ 11

C. Status of Current Off-road Demonstration Programs.......................................... 14

D. Total Number of VDECS installations................................................................. 19

E. Cost of Verified Diesel Emission Control Strategies ........................................... 20

F. VDECS Safety.................................................................................................... 21

III. IMPLEMENTATION UPDATE................................................................................ 23

A. Public Outreach.................................................................................................. 23

B. Off-road Implementation Advisory Group ........................................................... 25

C. SOON Program Status ....................................................................................... 25

D. DOORS .............................................................................................................. 26

E. Enforcement Actions and Fines Issued .............................................................. 28

F. Waiver Status ..................................................................................................... 28

IV. PROPOSED MODIFICATIONS TO THE REGULATION FOR IN-USE OFF-ROAD 

DIESEL-FUELED FLEETS..................................................................................... 31

A. Regulatory Authority........................................................................................... 31

B. Public Process.................................................................................................... 31

C. Need for Modifications........................................................................................ 32

D. Proposed Modifications ...................................................................................... 33

E. Staff Recommendation ....................................................................................... 35

V. ECONOMIC IMPACTS........................................................................................... 37

A. Legal Requirements ........................................................................................... 37

B. Methodology....................................................................................................... 37

C. Economic Impacts of Proposed Modifications .................................................... 38

D. Impacts on California Economy.......................................................................... 39

E. Potential Impacts on Small Businesses.............................................................. 39

F. Potential Impacts on Public Agencies................................................................. 39

VI. ENVIRONMENTAL IMPACTS ............................................................................... 41
ii 

A. Legal Requirements ........................................................................................... 41

B. Air Quality Impacts of Proposed Modifications ................................................... 41

C. Future Evaluation of Current Economic Conditions on Emissions...................... 42

D. Other Environmental Impacts ............................................................................. 42

VII. ALTERNATIVES CONSIDERED ........................................................................... 43

A. Extend Early Credit Deadline, but for Less Time................................................ 43

B. Extend Early Credit Deadline by a Full Year ...................................................... 43

C. Give More or Less than Double Credit before March 1, 2010 ............................ 43

D. No Change ......................................................................................................... 44

VIII.REFERENCES ....................................................................................................... 45
iii 

APPENDICES 

APPENDIX A: PROPOSED REGULATION ORDER FOR IN-USE OFF-ROAD 

DIESEL-FUELED FLEETS

APPENDIX B: ASSUMPTIONS FOR STATEWIDE FLEET RETROFITTING 

ANALYSIS

APPENDIX C: SHOWCASE AND SEP

APPENDIX D: OUTREACH SUMMARY

APPENDIX E: DOORS ON-LINE USER-GUIDES

APPENDIX F: LIST OF ACRONYMS
iv 
v 

LIST OF TABLES

Table 1: Currently Verified Level 3 Off-Road DPFs .................................................. 12

Table 2: SEP Funding and Number of Engines Retrofitted ..................................... 17

Table 3: Snowcat Project Locations and Number of Vehicles ................................ 18

Table 4: Summary of Active VDECS Costs in 2008.................................................. 20
vi 
vii 

LIST OF FIGURES

Figure 1: Showcase Installations of DECS ............................................................... 16

Figure 2: DOORS Screenshot .................................................................................... 27

Figure 3: Vehicle Labeled with EIN............................................................................ 28

Figure 4: Breadth of Passive Level 3 Verifications by Fleet Hp 2008 ..................... 33

Figure 5: California Off-Road Diesel Vehicle Fuel Consumption............................ 42
viii 
1

EXECUTIVE SUMMARY 

What is the purpose of this report? 

This report serves several purposes. First, it describes proposed changes to the 

regulation for in-use off-road diesel fueled-fleets (the regulation). These amendments 

are limited and include extending the deadline for double credit for early particulate 

matter (PM) retrofits and several additional minor modifications that clarify the 

regulation. 

Second, when the Air Resources Board (ARB or Board) approved the regulation on July 

26, 2007, the Board directed staff to provide the Board a technology update report by 

January 2009 (ARB, 2007d). This report serves as that technology update. 

Finally, this report updates the Board on how implementation of the regulation has 

proceeded in the year and a half since the regulation was approved by the Board. It 

summarizes the public outreach and reporting work that staff has done, and provides a 

status report on the Surplus Off-road Opt-in for NOx (SOON) program. 

What modifications to the regulation is staff proposing? 

To provide additional flexibility and clarity to the regulation, staff is proposing the 

following changes to the regulation: 

• Extend the deadline for double credit for early PM retrofits by 10 months, from 

March 1, 2009, to January 1, 2010. This will also mean that fleets that ordered 

verified diesel emission control systems (VDECS) by September 1, 2009, would 

receive double credit even if their installation is delayed beyond January 1, 2010. 

• Modify the changing fleet size requirements to not penalize fleets that change 

their designation from small fleets to larger fleets, and then subsequently become 

a small fleet again; 

• Clarify that all sellers, not just dealers, of off-road vehicles must maintain records 

of the disclosure of regulation applicability; 

• Clarify that the provision providing a delay for the turnover of Tier 1 and newer 

vehicles from the turnover requirements of the regulation applies only through the 

March 1, 2012 compliance deadline. This is consistent with staff’s original intent 

for this provision; and 

• Clarify the reporting requirements for VDECS. 

Why should the deadline for early double PM credit be extended? 

In originally providing this double credit in the regulation, staff intended to provide an 

incentive for fleets to take early action and achieve early PM reductions. The double 

credit provisions were also intended to help fleets spread out their costs by reducing the 

annual number of retrofits they would need to perform in the regulation’s first 

compliance years. However, because it has taken longer than anticipated for additional 
2

diesel particulate filters (DPFs), especially passive DPFs, to become verified, many 

fleets have been unable to take full advantage of the early credit provisions. 

Why should the other modifications be made? 

Since the regulation was adopted, in talking with affected fleets and stakeholders, ARB 

staff has determined that several sections of the regulation require clarification. 

What are the emissions impacts of the proposed modifications? 

Staff expects there to be little to no overall adverse impact on emissions from the 

proposed modifications. While the proposed change to extend the deadline for early 

double PM credit may also have a small disbenefit as many fleets take advantage of the 

extended double credit provisions (thereby decreasing the total number of retrofits 

completed by March 1, 2010), evidence from a number of sources indicates that many 

of the industries affected by the regulation (primarily the residential construction, rental, 

and airline industries) have reduced their activity since the regulation was adopted due 

to the current economic downturn, thereby potentially offsetting this impact. Available 

fuel use data supports this, showing total off-road diesel fuel consumption from all 

sources (off-road vehicles, locomotives, marine, etc.) down over 10 percent from year 

2007 levels (BOE, 2008). However, staff cannot precisely quantify at this time the 

extent of the decline in emissions from off-road vehicles subject to the regulation due to 

the poor economy. To better understand the impact of current economic conditions on 

fleets affected by the regulation and their emissions, ARB staff is evaluating available 

data on vehicle activity, as well as attempting to evaluate whether fleets may have 

changed their turnover practices due to the poor economy. Staff will present their 

findings at the January 2009, Board meeting. 

Overall, staff believes the proposed modifications may result in a slight positive effect on 

health, i.e., result in reduced health impact from poor air quality, because extending the 

early credit deadline so that it is usable by more fleets may encourage fleets of all sizes 

to retrofit earlier than they otherwise would, thereby achieving more immediate 

reductions in diesel PM. The earlier diesel PM is reduced, the more health benefits are 

achieved. 

What will the cost impact of the proposed modifications be? 

The proposed modification to extend the early double credit provision for PM VDECS 

should result in no adverse economic impacts, and instead should ease the burden of 

the regulation on affected fleets. This is because the proposed extension would help 

fleets spread out the costs of the regulation, without increasing the overall cost of the 

regulation. The proposed modification is expected to lower costs in 2010, the year of 

maximum expected annual regulation costs (ARB, 2007a). The other proposed 

modifications will not increase compliance costs for the regulation. 

What did the Board direct staff to report back on by January, 2009? 
3

In Resolution 07-19, the Board directed staff to, by January 2009, provide a technology 

update report on the status of VDECS that are available for installation to comply with 

the March 1, 2010 compliance date of the regulation (ARB, 2007d). The Board also 

directed staff to include an update on the number of devices that have been verified, the 

cost of those devices, and information on the ARB/South Coast Air Quality Management 

District/Mobile Source Air Pollution Reduction Review Committee Off-Road Diesel 

Retrofit Showcase (Showcase). 

This is the first of four updates the Board directed staff to provide. Resolution 07-19 

also directed staff to: 

• By December, 2010, provide a status report on compliance with and enforcement 

of the March 1, 2010, compliance date for large fleets, including an analysis of 

the regulation’s flexibility provisions and its economic impacts; and 

• By December, 2013 and December, 2017, provide updates on compliance and 

enforcement for the periods March 1, 2010 through March 1, 2013, and March 1, 

2013 through March 1, 2017, respectively, and updates on the progress of 

engine technology needed to comply with the regulation. 

What diesel emission control strategies have been verified to date? 

ARB’s verification program1

 is intended to ensure that a device achieves the advertised 

emission reductions and meets minimum durability requirements. To receive ARB 

verification, the device manufacturer must submit data showing the device is effective 

and durable and warrant the VDECS and the engine against any damage caused by the 

device. ARB’s verification procedure is a multi-level verification program consisting of 

PM reduction levels (Levels 1, 2, and 3) and optional oxides of nitrogen (NOx) reduction 

levels. 

There are two main types of DPFs – passive and active. Passive DPFs use a catalyst to 

lower the PM ignition temperature, so no outside source of energy is required for 

regeneration. Unlike a passive DPF, an active DPF uses an external source of heat to 

burn off the accumulated PM. The most common sources of heat are (1) plugging in to 

pass a current through the filter medium, and (2) injecting and burning additional fuel. 

Nearly all vehicles can be retrofitted with an active DPF, although for many off-road 

applications DPFs that require plugging in are not feasible, so fuel-burner active DPFs 

like the HUSS Umwelttechnik FS_MK are the most broadly applicable. However, for 

many reasons including cost and ease of operation, many fleets find passive systems to 

be more desirable. 

When the regulation was approved in July 2007, there were only three Level 3 DPFs 

verified for off-road use (all active DPFs). Of the types of systems verified by ARB, 

Level 3 systems are the most effective, reducing diesel PM by at least 85 percent. 

Since the adoption of the regulation, three additional systems have now been verified 

and are available: 

• Caterpillar DPF, 

 

1

 Title 13, California Code of Regulations (CCR), sections 2700-2710. 
4

• DCL International Inc. DPF, and 

• Engine Control Systems’ Purifilter DPF. 

What is the potential penetration of passive DPFs in the off-road fleet? 

Until mid-October 2008, passive DPF systems were available to less than five percent 

of off-road vehicles and 11 percent of off-road vehicle horsepower (hp) covered by the 

regulation. However, in late October, ARB issued additional verifications, which 

significantly expanded the availability of passive off-road DPFs. Staff now estimates 

that up to 24 percent of all off-road vehicles and up to 60 percent of the horsepower of 

affected off-road vehicles could have passive DPFs installed.2

What is the cost of DPFs available today? 

The vast majority of VDECS that have been installed in California so far are active 

systems. Current active VDECS costs range from below $14,000 for a less than 50 hp 

engine to nearly $50,000 for an engine over 500 hp. Very few passive DPFs have been 

installed so far, but the average cost for these passive installations on engines of 230 to 

300 hp was about $21,000. 

The current costs for DPFs are about 30 percent higher than the overall average cost 

over the life of the regulation for DPFs assumed in the initial staff report for the 

regulation (ARB, 2007a)3. However, the cost analysis in the initial staff report was 

based on estimates of the average prices for DPFs over the course of regulation 

(through year 2030). As the market for DPFs expands, staff expects the volume of 

sales, coupled with the increased number of DPF options fleets may choose from, to 

reduce retrofit costs relative to today’s prices. In addition, staff also expects the 

expanded availability of passive DPFs in additional horsepower ranges to provide less 

costly retrofit solutions relative to today. Overall, staff expects these retrofit costs will 

lower over time, bring them in line with the estimated VDECS costs presented in the 

initial staff report. 

What is the status of the Showcase? 

Since 2007, staff in conjunction with the South Coast Air Quality Management District 

(SCAQMD) and the Mobile Source Air Pollution Reduction Review Committee (MSRC) 

has engaged in developing the Showcase program. This program is providing valuable 

experience to staff, fleets, and retrofit manufacturers on the challenges of retrofitting offroad vehicles, and is facilitating an increase in the number of available VDECS. To 

date, the Showcase has been funded at $4.9 million, including $3.7 million from the 

 

2

 The percentages are upper-bounds in that they do not account for several factors, including 

the fact that some engines do not attain sufficient exhaust temperatures to be retrofit with 

passive DPFs. 

3

 This estimate weights current active DPF costs by 70 percent and current passive DPF costs 

by 30 percent, which is the original distribution of active versus passive DPFs assumed in 

the staff report. 
5

MSRC, and $1.2 million from the SCAQMD. As of early November 2008, 18 fleets with 

202 vehicles have applied and been accepted to participate in the Showcase. Of the 

eighteen participating fleets, thirteen are privately-owned, and five are public. In 

addition, 14 emission control manufacturers with 26 systems are participating in the 

Showcase. The 26 systems include 11 active DPFs and 15 passive DPFs. Seven of 

these systems reduce NOx as well as PM, and six of the systems include fuel borne 

catalysts. The vehicles participating in the Showcase include off-road engines with a 

full range of emission standard tier levels, from the highest emitting uncertified Tier 0 

engines to the cleanest new Tier 3 engines. Also, there are systems included in the 

Showcase that are seeking verification for engines of all certification tiers. 

To date, over 60 vehicles have been datalogged, and 9 vehicles have been retrofit, 

which is slower than originally anticipated. A variety of circumstances - including 

contracts taking longer than expected, participating vehicles having reduced usage or 

being pulled from service or retired, and installation designs being more complicated 

than anticipated - have pushed back the timeline from what was originally anticipated. 

However, staff estimates that all the vehicles participating in the Showcase will be 

retrofit by mid-2009. 

In addition to the Showcase, ARB staff is participating in another off-road demonstration 

project with the United States Environmental Protection Agency (U.S. EPA) known as 

the Supplemental Environmental Project (SEP). Its goals are identical to the Showcase, 

and it is funded with $700,000 in settlement funds from two U.S. EPA enforcement 

cases. Thus far, 22 vehicles have been retrofit through the SEP and an additional 16 

are expected to be retrofit in the next three months. In both the Showcase and SEP 

programs, fleets have been satisfied with the operation and reliability of the DECS. 

What major milestones in implementation of the regulation have been achieved? 

First, staff conducted 13 free training seminars throughout the state including at the 

following locations: 

• San Luis Obispo 

• Bakersfield 

• Redding 

• Nevada City 

• Fresno 

• Riverside 

• San Diego 

• El Monte 

• Sacramento 

• San Jose 

• Ventura 

• Oakland 

• South Lake Tahoe 

More than 12,000 flyers were distributed to publicize the seminars, and about 1,300 

stakeholders attended. 

 

Staff has also made presentations to over 15 groups, such as the National Association 

of Demolition Contractors and California Golf Course Superintendents Association. In 

addition, staff has met individually with dozens of individual stakeholders and fleets, and 
6

attended nine conferences and workshops to distribute information regarding the 

regulation. 

ARB also formed an advisory group, called the off-road implementation advisory group 

(ORIAG), in March 2008, to assist staff with outreach and implementation. ORIAG has 

had three general meetings and has formed the following subcommittees: 

• Safety, 

• Diesel emission control strategies (DECS), 

• Fleets, 

• Outreach, and 

• Diesel Off-road On-line Reporting System (DOORS). 

ORIAG has also created a guidance document review group, which reviews guidance 

documents and answers to frequently asked questions before ARB releases them to the 

public. The input from the ORIAG members and subcommittees has proved invaluable 

in implementing the regulation. 

Staff is also currently working with the Contractors State License Board (CSLB) to have 

information about the off-road regulation inserted into their contractor renewal letters. 

Staff expects to be able to reach approximately 15,000 contractors each month through 

CSLB renewal letters. 

Finally, staff has built an electronic reporting system called DOORS to enable fleet 

owners to report their fleet information to the ARB. Staff has been strongly encouraging 

fleets to voluntarily report early. As of November 17, 2008, 64 fleets have reported 

information for over 7,100 vehicles, and a number of fleets have begun labeling their 

vehicles with Equipment Identification Numbers. 

What is the status of obtaining authorization from U.S. EPA to enforce the 

regulation? 

Two provisions in the regulation became enforceable as soon as the regulation became 

effective on June 15, 2008: a five minute limit on unnecessary idling for off-road diesel 

vehicles, and the requirement for sellers located in California to disclose in writing that 

the vehicle sold may be subject to the regulation. ARB enforcement staff has begun 

auditing vehicle dealerships and auction sites and performing unannounced 

construction site inspections to enforce these two provisions. 

However, to fully enforce the regulation’s performance and recordkeeping requires, 

under section 209(e) of the federal Clean Air Act (CAA), ARB needs to obtain formal 

authorization from U.S. EPA. ARB submitted a request for authorization from U.S. EPA 

on August 12, 2008. On October 7, 2008, U.S. EPA published notice of its intent to 

consider California’s request in the Federal Register (U.S. EPA, 2008) at a hearing in 

Washington DC on October 27, 2008. Staff attended the hearing and gave a 

presentation explaining why U.S. EPA should issue such authorization. The comment 

period for U.S. EPA’s consideration of the authorization request was originally 
7

scheduled to end November 28, 2008, but has now been extended until December 19, 

2008 (U.S. EPA, 2008a; U.S.EPA, 2008b). 
8
9

I. INTRODUCTION 

The purpose of this report is to update the Air Resources Board (ARB or Board) on the 

status of retrofit technology available to fleets to comply with the Regulation for In-Use 

Off-Road Diesel-Fueled Fleets (the regulation). This report also discusses the efforts 

taken by staff to implement the regulation. Finally, this report describes a number of 

minor modifications and clarifications to the regulation that are being proposed by staff. 

A. Background 

The regulation was approved by the Board on July 26, 2007, and when implemented 

will reduce emissions of diesel particulate matter (PM) and oxides of nitrogen (NOx) 

from in-use off-road diesel vehicles that operate in California. The regulation is codified 

at California Code of Regulations (CCR), title 13, sections 2449 through 2449.3. The 

regulation will significantly reduce the public’s exposure to diesel PM and NOx 

emissions from the nearly 180,000 off-road diesel vehicles that operate in California by 

requiring fleet owners to accelerate turnover to cleaner engines and install exhaust 

retrofits (ARB, 2007a). The regulation supports the Diesel Risk Reduction Plan to 

Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles, which 

was adopted by the Board on September 30, 2000 and the 2007 State Implementation 

Plans for the South Coast and San Joaquin Valley air basins (ARB, 2000; ARB, 2007c). 

The scope of the regulation is far reaching; affecting vehicles of dozens of types used in 

over 8,000 fleets, in industries as diverse as construction, air travel, manufacturing, 

landscaping, and ski resorts, as well as public agencies. The regulation will affect, 

among others, the warehouse with one diesel forklift, the landscaper with a fleet of a 

dozen diesel mowers, the county that maintains rural roads, the landfill with a fleet of 

dozers, as well as the large construction firm or government fleet with hundreds of 

diesel loaders, graders, scrapers, and rollers. 

The regulation’s requirements vary depending on the size of the fleet and on the vintage 

of its vehicles. Fleets are defined in the regulation as small, medium, or large based on 

their total statewide horsepower. The regulation requires that the largest fleets, which 

have the most significant emissions and are most able to rapidly understand and absorb 

the costs of compliance, are required to meet the most stringent requirements. The 

smallest fleets, and local municipal fleets located in low-population counties, are 

required to meet the least stringent provisions. 

B. Report Overview 

In approving the regulation, the Board directed staff in Resolution 07-19 to provide the 

Board, by January 2009, with a technology update on the status of diesel emission 

control strategies that have been verified by ARB and are available for installation to 

comply with the March 1, 2010, compliance date of the regulation (ARB, 2007d). 

Additionally, the Board directed that the update include information on the number of 

devices that have been verified, the cost of those devices, and the status of the 

ARB/South Coast Air Quality Management District/Mobile Source Air Pollution 
10

Reduction Review Committee Off-Road Diesel Retrofit Showcase (Showcase). This 

report also includes an update on the status of implementation of the regulation, 

including information on public outreach, reporting, enforcement, the status on the 

Surplus Off-Road Opt-In for NOx (SOON) program, and the activities of the Off-Road 

Implementation Advisory Group (ORIAG). Additionally, as part of this update staff is 

proposing to modify the regulation by extending the double credit deadline for the early 

installation of Verified Diesel Emission Control Strategies (VDECS) from March 1, 2009, 

to January 1, 2010. Staff is also proposing a few additional modifications to the 

regulation to clarify certain provisions of the regulation. A full description of these 

proposed changes is provided in Chapter IV, and the proposed regulatory language is 

provided in Appendix A. 
11

II. TECHNOLOGY UPDATE 

This chapter discusses ARB’s verification program for diesel emission control systems 

(DECS), the status of current off-road verifications, ongoing off-road demonstration 

programs, the number of VDECS that have been installed to date, the cost of available 

VDECS, and VDECS safety. 

A. ARB’s Verification Program 

The regulation only requires the installation of a retrofit device that has been verified 

under ARB’s verification program. ARB’s verification program, previously adopted by 

the Board and codified at title 13, CCR, sections 2700 through 2710, is intended to 

ensure that a device achieves the advertised emission reductions and meets minimum 

durability requirements. Also, to receive ARB verification, the device manufacturer is 

required to warrant the VDECS and the engine against any damage caused by the 

device. ARB’s verification procedure is a multi-level verification program consisting of 

three PM reduction levels and optional NOx reduction levels. The regulation gives 

credit for Level 2 and Level 3 PM devices, which achieve at least 50 percent and 85 

percent PM reductions, respectively. 

B. Status of Current Off-Road Verifications 

1. Off-road verifications 

There are several types of diesel particulate filter (DPF) technologies that are available 

to meet the requirements of the regulation. DPF technology that uses a catalyst to 

lower the PM ignition temperature is termed a passive DPF, because no outside source 

of energy is required for regeneration. Unlike a passive DPF, an active DPF system 

uses an external source of heat to oxidize the accumulated PM. The most common 

methods of generating additional heat for oxidation involve electrical regeneration by 

passing a current through the filter medium (i.e., a plug-in system), injecting and burning 

additional fuel to provide additional heat for particle oxidation, or adding a fuel-borne 

catalyst or other reagent to initiate regeneration. Some active systems collect and store 

diesel PM over the course of a full shift and are regenerated at the end of the shift with 

the vehicle or equipment shut off. 

Currently, there are six Level 3 DPFs verified for off-road use. Table 1 below lists all the 

current VDECS for off-road vehicles. All of the VDECS shown in Table 1 are Level 3 

DPFs. Three of these -- the Caterpillar diesel particulate filter (DPF), the DCL 

International Inc. DPF, and Engine Control Systems’ Purifilter DPF – have recently been 

verified and entered the market after the off-road regulation was adopted in July 2007. 

The Caterpillar DPF’s verification was also recently expanded to include track-type 

vehicles. 
12

Table 1: Currently Verified Level 3 Off-Road DPFs 

Product 

Type 

(Active or 

Passive) 

Applicability 

Max Allowable PM 

Certification Level 

of Engine 

Caterpillar 

DPF Passive 

Verified for some 

1996-2008, 175-600 

hp, non-exhaust gas 

recirculation (EGR) 

Less than or equal 

to 0.2 grams per 

brake-horsepower 

hour (g/bhp-hr) 

Cleaire 

Horizon Active; Plug-In 

Conditionally verified 

for many 2007 and 

older, non-EGR, less 

than 15 liters 

Less than or equal 

to 0.4 g/bhp-hr 

DCL MINE-X 

Sootfilter Passive 

Conditionally verified 

for some 1996-2008, 

175-300 hp, non-EGR, 

rubber tired 

Less than or equal 

to 0.15 g/bhp-hr 

Engine 

Control 

System 

Combifilter 

Active; Plug-In 

Verified for many 2007 

and older, 25-300 hp 

(certain conditions) or 

175-300 hp, non-EGR, 

rubber-tired 

Less than or equal 

to 0.45 g/bhp-hr 

Engine 

Control 

Systems’ 

Purifilter 

Passive 

Conditionally verified 

for some 1996-2008, 

50-750 hp, non-EGR 

0.01 to 0.2 g/bhp-hr 

HUSS 

Umwelttechnik 

FS_MK 

Active; Fuel 

Burner 

Verified for most offroad diesel engines 

through 2008, most hp, 

non-EGR 

No restrictions 

In addition to the Level 3 DPFs listed above, there is one Level 2 off-road VDECS4. It 

consists of a diesel oxidation catalyst (DOC) used with an emulsified diesel fuel. 

Although the availability of off-road VDECS is increasing, VDECS have become 

available at a slower pace than staff anticipated. This lack of off-road verifications is 

due to a number of reasons, including: 

• It is challenging to find the proper vehicles and engines for off-road 

demonstration programs to ensure the broadest verification possible for each 

system (discussed in further detail later in this Chapter); 

• It is difficult to accrue the number of hours necessary for datalogging due to 

lower equipment activity related to the current economy; 

• Some manufacturers have limited the resources they have invested in off-road 

verifications, focusing more on the verification of on-road systems; and 

 

4

 Although this device is still listed on ARB’s verification website, the manufacturer of this 

product withdrew it from the market several years ago. 
13

• The Showcase has had a slower start than anticipated (discussed later in this 

Chapter). 

While it is difficult to predict with certainty, ARB staff anticipates that more off-road 

VDECS will become available in the near future. There are over 30 systems currently in 

the verification process for off-road applications, with several systems in the final stages 

of verification. Nearly all are Level 3 systems. Approximately five systems will reduce 

NOx, either alone or in concert with PM reductions. In addition, some manufacturers 

with current off-road VDECS are working to expand the scope of their verifications. 

2. Scope of off-road verifications 

As part of their assessment, staff has estimated the scope of applicability of the current 

off-road VDECS. To do this, staff conducted an analysis using the statewide off-road 

inventory to estimate the fraction of vehicles in the statewide fleet that could potentially 

be retrofit with currently verified off-road retrofits (ARB, 2006). Although a device may 

be verified for a specific engine, it may not always be verified or appropriate for the 

application in which the vehicle is used. Because of this, staff considers this analysis as 

an upper bound estimate of the number of off-road vehicles in the statewide fleet that 

could be retrofit with currently available off-road VDECS. 

To develop this estimate, staff used the following information: 

• The verification letters (also referred to as Executive Orders) for each off-road 

VDECS. The Executive Orders specify the horsepower, model year, emissions 

levels, and whether the device can be used with engines equipped with EGR. 

• Letters from VDECS manufacturers exempting certain vehicle types or models 

from retrofitting under the Carl Moyer program (Bruenke, 2007a; Bruenke, 2007b; 

Bruenke, 2008a; Bruenke, 2008b; Bruenke, 2008c; Bruenke, 2008d; Luksik, 

2008). Staff’s analysis assumes that such exempted vehicle types or models 

cannot be retrofit. 

Appendix B of this report contains further detail about how staff estimated the current 

extent of verifications. 

Of the six Level 3 verifications, the Huss active fuel burner system verification has the 

broadest application. It is verified for most off-road diesel engines through 2008, as 

long as the engine does not come equipped with EGR and is not in one of the high 

horsepower applications for which Huss has indicated its system is not feasible. These 

high horsepower applications include several models of scrapers and dozers, but affect 

only about 1.5 percent of the total statewide fleet (see Appendix B). While from a 

technical perspective nearly all vehicles could be retrofit with the Huss or other active 

systems, as discussed below, fleets have expressed operational concerns regarding the 

use of active systems. 

For a number of reasons, many fleets find active systems to be undesirable; the 

reasons for this include the need for external power, the requirement to shut a vehicle 

down for filter regeneration, and cost. The use of plug-in active systems, such as the 
14

Cleaire Horizon and ECS Combifilter, that require access to high voltage electrical 

power are challenging for vehicles that may be used away from a power source. For 

example, if a loader is operating at a remote construction site, and does not return to a 

central facility each night, it may not be feasible for that fleet to install a plug-in DPF on 

that loader because there is no on-site access to electricity for filter regeneration. On 

the other hand, fuel burner systems, such as Huss’s active DPF fuel burner system, 

avoid this issue since they do not require an external source of power. However, 

despite this, such systems are also not desired by many fleets, especially ones with 

older, lower tier vehicles, because the vehicles have to be turned off so the filter can be 

regenerated. Sometimes this filter regeneration interval can be frequent enough, in 

some cases approaching every few hours, to make use of the vehicle inconvenient or 

impractical (Porcher, 2008). In addition, as described later, active systems are 

generally more expensive than passive systems. However, active systems are still 

appropriate in many applications, and represent a majority of the systems currently 

installed on off-road vehicles. 

Until recently, less than five percent of the vehicles and 11 percent of off-road vehicle 

horsepower covered by the regulation had passive DPF systems available.5 In late 

October 2008, a new ECS system was verified, and the verification for the Caterpillar 

passive VDECS was significantly expanded; staff now estimates that up to 24 percent of 

the vehicles and up to 60 percent of the horsepower of affected off-road vehicles are 

capable of having a passive VDECS installed.5, 6 However, due to the late date of 

verifications, fleets, as presently adopted, had less than two weeks7

 to order these 

systems, which are now available for a wider variety of vehicles, and secure guaranteed 

double PM VDECS credit under the regulation. As is discussed later, this is the primary 

rationale for staff’s proposal to extend the early PM credit provisions of the regulation. 

C. Status of Current Off-road Demonstration Programs 

ARB staff is actively involved with three DECS demonstration programs: the Showcase, 

a United States Environmental Protection Agency (U.S. EPA) Supplemental 

Environmental Project (SEP), and a snowcat demonstration project. These programs 

are providing valuable experience to staff, fleets, and retrofit manufacturers on the 

challenges of retrofitting off-road vehicles, and are facilitating an increase in the number 

of verified off-road DECS. 

 

5

 The percentages estimated are the maximum possible percent of vehicles and engines that 

could be retrofit. They do not account for factors such as that some engines do not attain 

sufficient temperature to be retrofit with passive VDECS. Also, they do not fully account for 

the fact that one passive VDECS, the Caterpillar DPF, was verified only for rubber tired 

applications. ARB’s inventory data do not allow staff to subtract out tracked vehicles for 

vehicle types such as loaders that can be either tracked or rubber tired (ARB, 2006). 

6

 It is estimated that in 2010, approximately 35,000 or 18 percent of the vehicles in the statewide 

fleet will need VDECS to comply with the regulation; by 2011, approximately 60,000 or 30 

percent of the statewide fleet will need VDECS (ARB, 2007b). 

7

 Less than two weeks from the date of the verifications. 
15

1. Showcase 

a) Overview 

In anticipation of the need for additional verified DECS for off-road equipment, ARB, in 

conjunction with the South Coast Air Quality Management District (SCAQMD) and the 

Mobile Source Air Pollution Reduction Review Committee (MSRC), is administering the 

Showcase. Stakeholders in the Showcase include retrofit device manufacturers, fleet 

operators, other local air pollution control districts in California, and U.S. EPA. 

The goals of the Showcase project are to: 

• Demonstrate the effectiveness and durability of DECS on off-road vehicles; 

• Increase the number of VDECS for off-road applications; 

• Support the regulation through increased availability of VDECS; 

• Introduce DECS to off-road fleets; 

• Provide early reductions of emissions from off-road vehicles; and 

• Gain additional experience with the installation and use of DECS on off-road 

vehicles. 

The Showcase has been funded for $4.9 million, including $3.7 million from the MSRC, 

and $1.2 million for devices which control NOx from the SCAQMD. Additional 

information about the Showcase, including background, current status, vehicle data, 

photos, and datalogging results are available at the web site 

http://www.arb.ca.gov/diesel/showcase/showcase.htm. 

b) Current Status 

The Showcase covers a diverse combination of devices and vehicles in an effort to 

demonstrate and verify as many devices as possible covering a broad array of vehicles 

and applications. Vehicles were selected to represent a full range of vehicle types 

affected by the off-road regulation, as well as a full range of engine sizes. Additional 

information is provided in Tables 1 and 2 of Appendix C. As of early November 2008, 

18 fleets with 202 vehicles have applied and been accepted to participate in the 

Showcase. Thirteen of the fleets are privately-owned, and five are public. The 

participating fleets are listed in Table 3 of Appendix C. 

Participation in the Showcase by fleet owners provides them with a number of benefits. 

First, fleet owners are able to gain valuable experience with DECS with little or no 

capital outlay on their part. In addition, fleet participants are able to accumulate early 

double PM retrofit credits to be used to offset future fleet retrofit requirements. 

Fourteen emission control manufacturers with 26 systems are participating in the 

Showcase. The 26 systems include 11 active DPFs and 15 passive DPFs. Seven of 

the systems reduce NOx as well as PM, and six of the systems include fuel borne 

catalysts. As shown in Figure 1 below, the vehicles participating in the Showcase 

include off-road engines with a full range of engine tier levels, from the highest emitting 

uncertified Tier 0 engines to the newest, cleanest Tier 3 engines. Some of the systems 

included in the Showcase are seeking verification for engines of all tiers, while others 
16

are limited to newer engines. The list of participating emission control manufacturers is 

located in Table 4 of Appendix C. 

Figure 1: Showcase Installations of DECS 

0

10

20

30

40

50

60

70

80

90

0 1 2 3

Engine Tier

# of Engines

0

5

10

15

20

25

30

# of Systems

Engines

Systems

As of November 2008, over 60 engines have been datalogged, as described below, and 

9 engines have been retrofitted through the Showcase. Tables 1 and 2 of Appendix C 

include a list of the vehicle types and engines that have been retrofit so far, and a list of 

vehicle types and engines that are remaining to be retrofitted. It will be several more 

months until all vehicles are retrofitted. 

In the initial stages of the Showcase, staff anticipated that all vehicles would have been 

datalogged, installation designs completed, and most retrofits installed by November 

2008. However, a variety of circumstances have pushed back this timeline. The 

primary reasons for the delay are: 

• Contracts took much longer to execute than expected; 

• Economic effects (vehicles had reduced usage or were pulled from service or 

retired); 

• Fleets requested a change of vehicles; 

• Installation designs were more complicated than anticipated, in some cases 

increasing the price; 

• The exhaust temperatures required an active device when initially a passive 

device had been planned; and 

• A few devices were removed prior to installation as the manufacturers felt they 

needed further development. 

However, the data gathered thus far has provided a significant increase in knowledge 

regarding the applications of DECS on off-road vehicles. For example, during the 
17

development of the regulation, staff estimated that most off-road engines (approximately 

70 percent) would require an active, rather than passive, DPF (ARB, 2007b). However, 

datalogging of engine temperature and backpressure through the Showcase program 

indicates that over three-quarters of datalogged engines produce sufficiently high 

exhaust temperatures that would support the use of a passive DPF. This is 

encouraging because passive devices tend to be significantly less expensive than 

active DPFs and - as discussed above - are typically more desirable to fleets. Individual 

datalogging results are available on the Showcase website listed above; one example is 

included in Appendix C (Figure 1 and Figure 2). 

2. U.S. EPA’s Supplemental Environmental Project 

Three refineries in Northern and Southern California, in collaboration with the U.S. EPA 

and the ARB, have agreed to provide funding for retrofitting off-road vehicles with 

DECS. The refineries are providing the funding through the U.S. EPA SEP program, 

under which a violator offsets excess pollution by funding emission reductions projects 

in the immediate vicinity of the violation. 

The goals of the SEP are similar to the Showcase. The SEP will complement the 

Showcase by filling gaps in the test vehicle matrix that were unable to be addressed in 

the Showcase (see Appendix C, Table 10 for the matrix of vehicles). 

The SEP project is divided into three stages – SEP I through SEP III - with total funding 

of $700,000. The funding for each SEP stage and the scope and status of each is 

shown in Table 2. 

Table 2: SEP Funding and Number of Engines Retrofitted

SEP Funding # of 

Fleets 

# of 

Engines Status as of Early Nov 

I $300,000 3 15 DECS Installed 

II $200,000 3 11 DECS Installed 

III $200,000 4 12 Datalogging vehicle 

exhaust temperatures 

Tables 5 and 6 of Appendix C include a list of the vehicle types and engine sizes that 

have been retrofit so far in SEP I and SEP II; a list of vehicle types and engine sizes 

that are proposed to be retrofit in SEP III is also included in Table 7 of Appendix C. 

Similar to the Showcase, fleet owners are able to gain valuable experience with DECS 

with little or no capital outlay on their part. In addition, fleet participants are able to 

accumulate early PM retrofit credits to be used to offset future fleet retrofit requirements. 

However, the SEP – unlike the Showcase – offers only single, not double, retrofit 

credit.8

 

8

 The U.S. EPA specified that fleets should only receive single credit for DECS installations 

funded through the SEP, because the funding was intended to offset emissions violations at 

the three refineries. 
18

SEP information including vehicle data, photos and datalogging results are available at 

the web site http://www.arb.ca.gov/diesel/showcase/showcase.htm. Tables 8 and 9 of 

Appendix C list the fleets and emissions controls manufacturers participating in the 

SEP, respectively. 

3. Snowcat demonstration project 

A typical off-road engine in California operates at low elevations and in mild 

temperatures. The DECS verification procedures do not require testing at high 

elevations or in low ambient air temperatures. During the development of the 

regulation, some stakeholders raised concerns that under these conditions, DECS 

would not perform well. To evaluate these concerns, during the winter of 2007/2008, 

twelve snowcats used for snow grooming operations were datalogged at the three 

northern California ski resorts shown in Table 3. 

Table 3: Snowcat Project Locations and Number of Vehicles 

Ski Resort Number of Vehicles 

Datalogged 

Sugar Bowl 2 

North Star 5 

Mammoth 5 

Snowcat engines operate a majority of the time under medium to heavy load. Many ski 

resorts have some slopes so steep that the snowcats must winch themselves up and 

down those slopes because the treads alone do not provide sufficient traction. Based 

on staff’s evaluation of datalogged information, staff determined that despite the high 

elevation and low ambient air temperature that snowcats are typically subject to, their 

engine exhaust temperatures are high enough that passive DPFs can be used. In fact, 

one resort has already installed passive DPFs on some of their snowcats. 

Snowcat demonstration project information including vehicle data, photos and 

datalogging results are available at the web site 

http://www.arb.ca.gov/diesel/showcase/showcase.htm. 

4. Overall findings of the demonstration programs 

The most significant finding of the Showcase, SEP, and Snowcat demonstration 

programs to date has been that more vehicles than expected have sufficiently high 

exhaust gas temperatures to be retrofit with passive devices. Every engine in every 

vehicle participating in these retrofit demonstration programs has or will be datalogged 

for 5 to 7 days. The datalogging tracks the characteristics of the exhaust by recording 

temperature and backpressure. Analysis of the over 110 vehicles datalogged to date 

demonstrates that over three-quarters of these engines produce sufficiently high 
19

exhaust temperatures to support the use of a passive DPF.9 Passive devices tend to be 

significantly less expensive than active DPFs and less complicated, therefore they are 

often more desirable to fleets. 

The Showcase and SEP programs have also demonstrated that off-road retrofits are 

durable and can function well while effectively reducing diesel PM pollution on a wide 

variety of vehicle types. Thirty devices have been installed on a wide diversity of 

vehicle types including tractors, graders, loaders, backhoes, excavators, and scrapers, 

and all the retrofit devices are working well. In addition, these demonstration programs 

have highlighted the need to ensure proper installation, as there were a limited number 

of installation issues, such as exhaust leaks, encountered during installation; however, 

these issues have been or are in the process of being resolved.10 Despite these 

issues, the overwhelming reaction of fleets participating in these demonstration 

programs to retrofits has been extremely positive. 

Over the next 6 to 12 months in the Showcase and SEP programs, staff plans to 

complete the following tasks: 

• Install devices onto the remaining off-road vehicles; 

• Continue datalogging to gather exhaust temperature data; 

• Monitor the performance of the devices; 

• Measure emissions during vehicle operation with an on-board portable emissions 

measurement system (PEMS); and 

• Survey the fleet owners and operators regarding their opinions concerning 

operation of the retrofits. 

Staff is continuing to work with retrofit manufacturers participating in these 

demonstration programs to develop the data necessary to demonstrate the durability 

and performance of their products in support of verification. Staff is also optimistic that 

the information and lessons learned through these demonstration programs regarding 

the installation and operation of off-road retrofits can be used broadly by affected fleets 

and retrofit installers to assist them during the implementation of the regulation. 

D. Total Number of VDECS installations 

To date, staff estimates that about 430 off-road vehicles have been retrofit in California 

with a Level 3 off-road VDECS, including dozers, loaders, excavators, backhoes, 

graders, and tractors. Because there is as yet no requirement for fleets or VDECS 

installers to report each VDECS installation to ARB, staff does not have details on each 

installation or an exact count of how many VDECS have been installed. However, staff 

has interviewed VDECS manufacturers to obtain an estimate of how many retrofits are 

already in place, and will have a better sense of the actual number of installations once 

 

9

 The Showcase and SEP did not capture smaller horsepower engines, and smaller horsepower 

engines will likely require active DPFs. 

10 At the time of this report’s writing, thirty devices were installed and one device which 

encountered difficulties during installation was awaiting final installation. 
20

fleets begin reporting in the spring of 2009 (Halloran, 2008; Jerman, 2008; Brown, 2008; 

Swenson, 2008; Surma, 2008). 

E. Cost of Verified Diesel Emission Control Strategies 

Table 4 below shows the current average costs11 for purchase and installation of active 

VDECS based on data from three VDECS installers (Cox, 2008; Ostrander, 2008; 

Cram, 2008), and the Carl Moyer program database (CARL, 2008). The data shown in 

Table 4 is for 194 of the estimated 430 VDECS installations that have occurred to date 

on off-road vehicles in California. 

Table 4: Summary of Active VDECS Costs in 2008 

Engine Horsepower 

Range 

Active VDECS 

Cost in 2008 

< 50 $13,800 

50-120 $15,500 

121-175 $19,300 

176-250 $19,100 

251-400 $44,600 

401-500 $44,800 

500+ $48,400 

The data indicates that the cost to apply an active VDECS to a vehicle shows a distinct 

jump at around 250 horsepower. This substantial increase in cost is largely due to the 

necessity of using multiple canisters or larger filter sizes for engines above 250 

horsepower. 

Very few passive VDECS have been sold in California because they were verified only 

recently. Therefore, there are insufficient data to determine the average costs over a 

full range of engine horsepowers. Staff has cost data on a handful of installations of 

passive VDECS that have been installed on engines of approximately 230 to 300 

horsepower, and the average cost for these passive installations was about $21,000. 

ARB staff will continue to collect information on VDECS costs, as more passive systems 

are purchased and installed. 

The current costs for installed VDECS12 are, on average, about 30 percent higher than 

initially estimated by staff during the development of the regulation (ARB, 2007b). 

However, staff’s initial cost analysis was based on estimates of the average prices for 

VDECS over the entire course of the regulation. As the market for VDECS expands, 

staff expects the volume of sales, as well as the increased number of VDECS options 

fleets may choose from, to lower overall retrofit costs. Staff also expects the availability 

of passive VDECS in additional horsepower ranges to provide less costly solutions 

where the application supports the use of a passive system. Staff expects these lower 

 

11 Cost of VDECS unit plus installation. 

12 Assuming a distribution of 30 percent passive DFPs and 70 percent active DPFs. 
21

cost solutions will lower the overall costs of DPFs over time, bringing them in line with 

the estimated VDECS costs presented in the initial staff report. 

F. VDECS Safety 

During the development of the regulation, staff recognized that some VDECS 

installations could present potential safety hazards and that in some cases it would not 

be possible to install a VDECS safely. Potential safety issues include significant 

visibility impairment, thermal hazards, and compromising the structural integrity or 

center of gravity of the vehicle, with visibility impairment likely to be the most common 

issue. Recognizing these potential safety hazards, the regulation includes provisions to 

exempt a vehicle from the VDECS requirements if one can not be installed safely. 

Under the regulation, a fleet owner may request that the Executive Officer review and 

determine whether a VDECS should not be considered the highest level VDECS 

available because of potential conflict with other safety and health requirements. As 

part of these provisions, there is also an appeals process for any party whose request 

has been denied. 

Staff is currently working with staff from the California Occupational Safety and Health 

Administration (Cal\OSHA), the Mining Safety and Health Administration (MSHA), and 

organized labor to develop the protocol for evaluating claims of unsafe installation of 

VDECS. Cal\OSHA and MSHA staff have been helpful in assisting staff in compiling a 

summary of all relevant safety regulations. Cal\OSHA staff has attended Off-road 

Implementation Advisory Group (ORIAG, described in Chapter III) safety committee 

meetings. Cal\OSHA and MSHA staff have also agreed to work with ARB as part of a 

group that will review safety appeals. Staff also anticipates working with this group to 

develop amendments necessary to Cal\OSHA regulations to establish more objective 

criteria for determining whether a specific VDECS installation presents an unsafe 

condition. 
22
23

III. IMPLEMENTATION UPDATE 

This chapter describes staff’s ongoing efforts to implement the regulation. 

A. Public Outreach 

Since the regulation was approved in July 2007, staff has been working with affected 

industry stakeholders and other interested parties on its implementation. 

1. Training seminars 

Since July 2008, staff conducted thirteen free training seminars throughout the state 

including in: 

• San Luis Obispo, 

• Bakersfield, 

• Redding, 

• Nevada City, 

• Fresno, 

• Riverside, 

• San Diego, 

• El Monte, 

• Sacramento, 

• San Jose, 

• Ventura, 

• Oakland, and 

• South Lake Tahoe. 

More than 12,000 flyers were distributed to publicize the seminars, local newspapers 

helped publicize the trainings, and approximately 1,300 stakeholders attended the 

training sessions. The Sacramento training seminar was also webcast so interested 

parties could participate remotely via computer. Each seminar lasted approximately 

three hours and provided a detailed explanation of the regulation and assistance on 

how fleets should address the regulation’s reporting requirements. The seminars also 

provided interested fleets with the opportunity to speak with representatives from 

companies who manufacture or install off-road VDECS. A list of the seminar locations 

and attendance is included in Table 1 of Appendix D. 

ARB staff distributed feedback forms at each of the twelve training sessions. On a 

scale of 1 to 5, with five being the highest, participants ranked the training as a 4.6 

when asked if they thought it was worthwhile and worth their time to attend. Staff has 

another three training sessions currently scheduled and expected to be completed by 

the end of 2008 in Fortuna, Victorville and Sacramento, and plans to conduct additional 

training sessions in 2009. 

2. Other outreach and assistance 

Since the regulation was approved, staff has been making every effort to reach and 

inform interested parties about the regulation. Over the past year and a half, staff has 
24

conducted approximately 28 meetings with individual fleets and dealerships in a one-onone setting. In these meetings, staff provided an overview of the regulation, in addition 

to providing reporting and compliance planning assistance. In addition, staff has not 

waited to be invited to relevant events; staff researched the meeting and conference 

schedules for a number of relevant trade associations and called and offered to speak 

at and attend these meetings. In total, staff has spoken to 17 groups at industry trade 

association meetings and events. During this time, staff also attended nine conferences 

and workshops to give presentations regarding the regulation or to provide fact sheets 

or other information to interested stakeholders. Additionally, some of these events were 

held out-of-state; this enabled staff to more widely outreach to those individuals or 

companies who frequently bring equipment into California from surrounding states. A 

list of the organizations to which staff has made presentations with since approval of the 

regulation is included in Table 2 of Appendix D. Table 3 of Appendix D lists individual 

fleets and stakeholders with which staff has met, and Table 4 in Appendix D describes 

the conferences that off-road implementation staff has attended to talk about the 

regulation. 

Staff has also done multiple mailings to individuals potentially affected by the regulation 

and notified them about upcoming training sessions and outreach opportunities. The 

industry groups and associations that received notification of this information included 

off-road equipment manufactures, off-road engine manufactures, California county 

board of supervisors, county public works departments, auction houses, theme parks, 

and general construction contractors. 

In addition to traditional mailings, ARB has sent out multiple e-mail notifications through 

its Off-road list serve, which contains over 3,700 individual e-mail addresses. Staff is 

also currently working with the Department of Motor Vehicles (DMV) and the 

Contractors State License Board (CSLB) to get information about the off-road regulation 

inserted into the agency’s respective registration and license renewal documents. 

Additionally, ARB staff expects to be able to reach approximately 15,000 contractors 

each month through CSLB renewal letters. 

Staff is also producing a series of training videos to simply and clearly illustrate how to 

choose, install, and maintain VDECS. The goal for these videos is to help fleets gain 

the necessary understanding to more readily implement rules such as the off-road 

regulation that require installation of VDECS. These videos will include information 

such as: 

• What are VDECS and how do they work; 

• How to comply with regulatory VDECS requirements; 

• Who to turn to for technical advice on VDECS; 

• How to select a VDECS; and 

• How to properly install and maintain VDECS. 

Outreach efforts will continue in the future. ARB staff has designed a poster that will be 

placed in dealerships throughout the state where off-road equipment is sold, as well as 

in public works offices and other places where owners of affected vehicles may 
25

frequent. Staff is also pursuing other avenues for getting the word out regarding the 

regulation, including the use of free public service announcements on radio stations. 

B. Off-road Implementation Advisory Group 

At the suggestion of several industry stakeholders, ARB formed an advisory group in 

March 2008 to assist staff with outreach and implementation. The group, called the offroad implementation advisory group (ORIAG), is an informal committee made up of 

approximately 50 members selected to represent a cross-section of fleets, engine 

manufacturers, retrofit manufacturers and installers, equipment dealers and 

manufacturers, trade groups, and others. Thus far, ORIAG has had three general 

meetings, in May, June, and September of 2008, all of which were webcast. ORIAG 

has also formed subcommittees on safety, DECS, fleets, outreach, and the Diesel Offroad On-line Reporting System (DOORS), as well as a guidance document review 

group. 

Every general meeting has been attended by most of the ORIAG members. In addition, 

as the meetings are open to the public, many additional interested members of the 

public have attended and participated. Through the subcommittees and during general 

meetings, ORIAG members have provided excellent suggestions and feedback 

regarding, for example, the content of the training seminars, safe installation of retrofit 

devices, guidance documents (e.g., advisories and answers to frequently asked 

questions), and improving DOORS (the reporting system developed for the regulation). 

The feedback from ORIAG members has helped make ARB staff more aware of the 

needs and opinions of affected stakeholders and more able to effectively implement the 

regulation. Staff plans to continue to meet regularly with ORIAG in the future as 

implementation of the regulation progresses. 

C. SOON Program Status 

The Surplus Off-Road Opt-In for NOx (SOON) program was established by section 

2449.3 of the regulation. It is intended to allow local air districts to fund projects for offroad diesel vehicles operating inside their district to achieve additional NOx emission 

reductions beyond those expected from the base regulation. Funding may come from 

any available funding source; however, staff expects that most of the SOON program 

funding will come from the Carl Moyer incentive program. The SOON program was 

implemented, in part, to assist the South Coast and San Joaquin Valley air districts in 

meeting federal air quality standards for ozone and fine particulate matter. In order for 

the SOON program to take effect, the participating district must develop administrative 

guidelines for the program and have those guidelines approved by ARB. Section 

2449.3 allows the South Coast Air Quality Management District (SCAQMD) and San 

Joaquin Valley Air Pollution Control District (SJVAPCD) to make the SOON program 

mandatory for fleets beginning in 2009. 

While any air district may opt into the SOON program, to date only the SCAQMD has 

officially elected to do so. The SJVAPCD is presently in the process of opting into the 

SOON program. Further details on the status of SOON in the SCAQMD and SJVAPCD 

are provided below. 
26

1. South Coast Air Quality Management District 

The SCAQMD submitted draft SOON guidelines to staff on March 20, 2008, and May 

12, 2008. The SCAQMD’s governing Board formally opted into SOON on May 2, 2008, 

and ARB approved the SCAQMD SOON guidelines on June 6, 2008. The SCAQMD 

released the first solicitation for SOON projects with a submittal deadline of November 

7, 2008 (SCAQMD, 2008). 

Based on the first round of solicitations, the SCAQMD has funded 125 off-road diesel 

vehicle repower projects from 21 private companies and one government agency at a 

cost of $16.6 million.13 SCAQMD has committed to provide $30 million of Carl Moyer 

monies annually for the first four years of their SOON Program and will make another 

$13 million available with another round of solicitations after the November 7, 2008, 

deadline. 

2. San Joaquin Valley Air Pollution Control District 

The SJVAPCD submitted draft SOON guidelines for review and assessment to ARB 

staff on August 25, 2008, and September 19, 2008. However, staff’s comments were 

not addressed in the most recent version of the proposed guidelines, and staff 

disapproved the proposed guidelines on October 15, 2008 (White, 2008). Staff is 

continuing to work with the staff of the SJVAPCD to develop guidelines that are 

consistent with the SOON program. The current SJVAPCD implementation plan calls 

for the investment of five million dollars from Carl Moyer monies annually to fund SOON 

projects (Gamez, 2008). 

D. DOORS 

Staff has developed the DOORS system to enable fleet owners to report their fleet 

information to ARB as required by the regulation. DOORS is a web-based application 

using a database to store fleet data. Fleet owners, vehicle dealers, consultants and 

other members of the DOORS ORIAG subcommittee have provided input on the design 

and function of DOORS and are assisting in developing the compliance planning 

features and other enhancements as needed. 

As shown in Figure 2, DOORS provides fleet owners a number of ways to provide their 

information to ARB, as well as providing many other features. As currently structured, 

DOORS allows fleet owners to: 

• Enter their fleet information directly in on-line entry screens or by uploading 

information from a spreadsheet; 

• View and edit their information; and 

• Request ARB review of their information. 

 

13 Carl Moyer monies were used. 
27

Figure 2: DOORS Screenshot 

Staff has assisted fleets when they have had questions regarding DOORS reporting and 

has prepared an on-line user-guide (which is included in Appendix E) to assist fleet 

owners. Staff also provided comprehensive training on DOORS in the first round of 

statewide training sessions. Building on this, staff is offering half-hour one-on-one 

training sessions to assist interested fleets in using DOORS during the second round of 

training in November and December of 2008. 

The deadlines for initial reporting are rapidly approaching – April 1, 2009, for large 

fleets, June 1, 2009, for medium fleets, and August 1, 2009, for small fleets. In total, 

staff expects that approximately 8,000 fleets with about 180,000 vehicles will be 

required to report their vehicles to DOORS. Staff has been strongly encouraging fleets 

to report early so that they will be able to become familiar with the process and be able 

to fully take advantage of the customer support being provided by staff. As of 

November 17, 2008, 64 fleets have reported information on over 7,100 vehicles. By 

reporting early, these fleets have provided themselves with extra time to label their 

vehicles with Equipment Identification Numbers (EINs) as required by the regulation and 

shown in Figure 3. 
28

Figure 3: Vehicle Labeled with EIN 

E. Enforcement Actions and Fines Issued 

Two provisions in the regulation became enforceable when the regulation became 

effective on June 15, 2008: a five minute limit on unnecessary idling for off-road diesel 

vehicles, and the requirement that California-based sellers of off-road vehicles provide 

written disclosure to purchasers that the regulation may be applicable to the off-road 

diesel vehicles sold and operated in California. 

Enforcement of the idling restrictions began in October, 2008, when ARB enforcement 

staff visited 15 construction sites in Southern California, and issued two citations for 

unnecessary idling and identified a dealer that had failed to include disclosure with offroad diesel vehicle sales. Based on the information provided by the dealer, 

enforcement staff identified 18 violations. Enforcement staff is continuing to perform 

inspections of construction sites and audit dealerships and auction houses, and are 

preparing to enforce the fleet reporting requirements beginning next spring. 

F. Waiver Status 

The federal Clean Air Act (CAA) section 209(e)(2) permits California to adopt emission 

standards and requirements related to emission control for in-use nonroad engines, so 

long as it obtains authorization from the Administrator of the U.S. EPA prior to the 

regulation becoming effective. As part of the authorization process, in Resolution 07-

19, the Board made the requisite protectiveness finding required under CAA section 

209(e)(2) that the adopted regulations will be, in the aggregate, at least as protective of 

public health and welfare as the applicable Federal standards, that California needs its 

nonroad emission standards to meet compelling and extraordinary conditions, and that 
29

the standards and accompanying enforcement procedures approved therein are 

consistent with CAA section 209. 

ARB submitted the request for authorization to U.S. EPA on August 12, 2008. On 

October 7, 2008, U.S. EPA published notice that it would consider California’s request 

(U.S. EPA, 2008) at a public hearing on October 27, 2008. Staff attended the hearing in 

Washington D.C. and gave a presentation in support of its request. The comment 

period for U.S. EPA’s consideration of the authorization request was originally 

scheduled to end November 28, 2008, but has now been extended until December 19, 

2008 (U.S. EPA, 2008a; U.S.EPA, 2008b). 
30
31

IV. PROPOSED MODIFICATIONS TO THE REGULATION FOR IN-USE OFFROAD DIESEL-FUELED FLEETS 

This chapter discusses staff’s proposed modifications to the regulation. 

A. Regulatory Authority 

ARB has authority under California law to adopt the proposed regulation modifications. 

California Health and Safety Code (HSC) sections 43000, 43000.5, 43013(b) and 43018 

provide broad authority for ARB to adopt emission standards and other regulations to 

reduce emissions from new and in-use vehicular and other mobile sources. Under HSC 

sections 43013(b) and 43018, ARB is directly authorized to adopt emission standards 

for off-road vehicular sources, as expeditiously as possible, to meet state ambient air 

quality standards. ARB is further mandated by California law under HSC section 39667 

to adopt Air Toxic Control Measures (ATCMs) for new and in-use vehicular sources, 

including off-road diesel vehicles, for identified TACs, such as diesel PM. 

 

Under federal and California law, ARB is the primary agency in California responsible 

for making certain that all regions of the State attain and maintain NAAQS. To achieve 

this, California must adopt all feasible measures to obtain the necessary emission 

reductions, including measures from mobile sources. The federal CAA preempts states, 

including California, from adopting requirements for new off-road engines less than 

175 horsepower used in farm or construction equipment. However, California may 

adopt emission standards for in-use off-road engines (federal CAA section 209(e)(2)). 

Because the proposed regulation addresses in-use rather than new off-road engines, it 

is permitted by the federal Clean Air Act. For example, turnover of a vehicle is not 

required until a vehicle is older than 10 years. California must obtain authorization from 

the Administrator of the U.S. EPA before the in-use emission standards of this proposed 

regulation become enforceable. Since the proposed regulation is not within the scope 

of any existing U.S. EPA authorizations, California must obtain a new authorization from 

U.S. EPA prior to the regulation becoming effective (ARB, 2007a). 

B. Public Process 

Staff is planning to hold a public workshop on December 19, 2008, in Sacramento, 

California, to solicit public input on the proposed modifications to the regulation. 

However, since the regulation was adopted, staff has met and spoken with numerous 

affected fleets and industry representatives who have expressed significant concerns 

regarding the limited availability of off-road VDECS, and the need for extending the 

early credit provision. 

In addition to the individual meetings, at the September 26, 2008 ORIAG meeting, staff 

solicited input from the ORIAG on the possibility of extending the early credit deadline. 

Staff has considered all comments and recommendations received from various 

stakeholders, and has crafted the proposed amendments to the regulation to help 

address the specific concerns that were expressed. 
32

C. Need for Modifications 

The early credit provision in the regulation currently provides double credit for VDECS 

installed by March 1, 2009. When a highest level VDECS is installed on an engine 

before March 1, 2009, that fleet will get double credit, meaning that the fleet will receive 

carryover retrofit credit equal to double the horsepower of the engine on which the 

highest level VDECS is installed14. If there are manufacturing or installer delays that 

prevent a VDECS from being installed until after March 1, 2009, a fleet will still get 

double credit as long as the VDECS was ordered by November 1, 2008. 

Although the availability of off-road VDECS is increasing, as discussed in Chapter II, 

VDECS have become available at a slower pace than staff initially anticipated and have 

not allowed fleets to take full advantage of this early credit provision. When the 

regulation was initially adopted, staff anticipated there would be many additional offroad exhaust retrofits verified well before the early credit deadline of March 1, 2009 

(ARB, 2007a). In proposing the regulation to the Board, staff noted that the early credit 

provisions for both PM and NOx would be important in making the regulation affordable 

for some fleets (ARB, 2007e; ARB, 2008a). Early double PM credit was intended to 

give fleets the opportunity to spread out their annual compliance costs in the early years 

of the regulation over several years and to reduce otherwise potentially high initial 

compliance costs (ARB, 2007e; ARB, 2008a). If the double early credit deadline for PM 

VDECS is not extended, the forecasted economic benefits of the provision would not be 

as great. 

As shown in Figure 4 below, prior to mid-October, 2008, staff estimates that only 20 

percent of fleets affected by the regulation could retrofit 10 percent or more of their 

vehicle horsepower with available passive verified DECS. Thus, most fleets with a need 

or strong preference for passive systems could not take full advantage of the early 

credit provisions. Even if they had wanted to purchase retrofits for all of the vehicles in 

their fleet that could utilize retrofits, they would have been unable to accumulate even 

one year’s worth of retrofit credit in time to meet the November 1, 2008, date for 

guaranteed double credit. 

 

14 Consider, for example, a large fleet with total horsepower of 10,000 hp that applies highest 

level VDECS to 1,000 hp of its engines before March 1, 2009. Such a fleet can bank 2,000 

hp (1,000 hp times 2) in carryover retrofit credit. Then, on March 1, 2010, if the fleet does 

not meet the 2010 fleet average target for PM, it may choose not to meet the BACT 

requirements to retrofit 20 percent of 10,000 hp (i.e., 2,000 hp). Instead, the fleet may use 

its 2,000 hp of banked carryover retrofit credit and postpone any required retrofitting to the 

following year. 
33

Figure 4: Breadth of Passive Level 3 Verifications by Fleet Hp 200815 

As of Mid-October, 2008

Could 

Retrofit 

10% or 

More of 

Fleet

Could 

Retrofit < 

10% of 

Fleet 17%

83%

Prior to Mid-October, 2008

Could 

Retrofit < 

10% of 

Fleet

Could 

Retrofit 

10% or 

More of 

Fleet 20%

80%

However, as can also be seen in Figure 4, now that several more verified systems have 

recently become available, staff estimates that 83 percent of fleets affected by the 

regulation can currently retrofit more than 10 percent of their vehicle horsepower with 

passive VDECS. Thus, many more fleets can now take full advantage of double credit. 

Since the regulation was adopted, based on feedback and comments from affected 

fleets and other stakeholders, staff has also identified a number of other provisions of 

the regulation that require clarification or simplification. Specifically, staff is proposing to 

clarify the duration of the Tier 1 vehicle turnover exemption, the recordkeeping 

requirements for the disclosure of the regulation’s applicability, and the reporting 

requirements for VDECS. Staff is also proposing to simplify a minor provision in the 

changing of fleet size requirements. These clarifications are necessary for successful 

implementation of the regulation. 

D. Proposed Modifications 

Staff is proposing the following modifications to the regulation: 

• Extend the double credit for early PM retrofits deadline by 10 months from March 

1, 2009 to January 1, 2010; 

• Modify the changing fleet size requirements to not penalize fleets that change 

from small fleets to larger fleets, and then subsequently become a small fleet 

again; 

• Clarify that all sellers, and not just dealers, of off-road vehicles must maintain 

records of the disclosure of regulation applicability; 

• Clarify that the provision for delay of Tier 1 turnover exempts Tier 1 vehicles from 

turnover only until the March 1, 2012, compliance deadline; and 

 

15 The pie chart on the left shows the estimated percent of fleets that could have retrofit 10 

percent of more of their fleet hp with VDECS verified before mid-October 2008. The pie 

chart on the right shows the percent of fleets that could do so with VDECS verified as of 

mid-October 2008. 
34

• Clarify the reporting requirements for VDECS. 

In addition to the aforementioned modifications, two minor changes to the off-road 

regulation were proposed as part of the regulatory package for Proposed Regulation for 

In-Use On-Road Diesel Vehicles: (1) the clarification to the low-use provisions, and (2) 

the addition of all two engine cranes to the off-road regulation. These changes are 

scheduled to be considered by the Board at the December 11, 2008, Board hearing. 

For more information regarding these proposed changes, please see Chapter V. of the 

Staff Report for the Proposed Regulation for In-Use On-Road Diesel Vehicles (ARB, 

2008c). 

A more detailed discussion of the modifications staff is proposing is provided below. 

1. Change early double credit deadline 

This change would extend the deadline for earning double PM BACT credit in section 

2449.2(a)(2)(A)2.a.i. from March 1, 2009, to January 1, 2010. The change would also 

mean that VDECS ordered by September 1, 2009, would receive double credit even if 

manufacturer or installer delays cause installation of the VDECS to be delayed beyond 

January 1, 2010. Additionally, this change would allow fleets more time to accumulate 

early PM credit and take greater advantage of recently verified DECS. Utilizing early 

PM credit would provide fleets with more time to more effectively spread out the initially 

compliance costs of the regulation. Also, adding 10 months to the early double PM 

credit deadline would allow more time for additional off-road verifications to be 

completed. 

2. Requirements for fleet size changes 

Staff proposes to remove the provision in section 2449(d)(4)(A) that requires a small 

fleet that becomes a medium or large fleet, and then subsequently reverts to a small 

fleet, to keep meeting the medium or large fleet requirements for two years after its 

reduced total maximum horsepower once again reclassifies it as a small fleet. This 

provision was initially developed to prevent fleets from taking advantage of a potential 

loophole under the regulation by deliberately growing and shrinking a fleet’s size and 

being subject only to the small fleet requirements. However, after further review of this 

requirement, staff has determined that the possible complexity of this provision in 

practice, especially in situations where a fleet’s size changes frequently over time, far 

outweighs the potential for fleets to abuse the changing fleet size provisions. 

3. Recordkeeping requirements for disclosure of applicability 

The record retention requirements in section 2449(h)(8) currently provide that only 

dealers must maintain records of the disclosure of the regulation applicability required 

by section 2449(j). In contrast, section 2449(j) requires any person selling a vehicle 

with an engine subject to the regulation to include a disclosure that the vehicle sold 

might be subject to the regulation. The intent of section 2449(h)(8) was to parallel 

section 2449(j) and require the records of the disclosure to be retained by anyone 

required to issue a disclosure of regulation applicability. As such, staff proposes that 
35

the language in 2449(h)(8) be changed to clarify that all sellers, not just dealers, must 

maintain the records of the disclosure of regulation applicability. 

4. Tier 1 delay 

Section 2449.1(a)(2)(A)5. states that all vehicles with a Tier 1 or higher engine are 

exempt from the turnover requirement until March 1, 2013, provided that all Tier 0 

vehicles in the fleet owner’s fleet that do not qualify for exemption under section 

2449.1(a)(2)(A)4. have been turned over. The intent of this provision is to exempt Tier 1 

vehicles from the turnover requirements of the regulation until the fleet must meet their 

March 1, 2013, compliance deadline; that is a fleet may have to begin turning over their 

Tier 1 vehicles after March 1, 2012, to meet the fleet’s March 1, 2013, compliance 

requirements. Staff is proposing to clarify this language by stating that all vehicles with 

a Tier 1 or higher engine are exempt from the turnover requirement until March 1, 2012 

(instead of March 1, 2013), provided that all Tier 0 vehicles in the fleet owner’s fleet that 

do not qualify for exemption under section 2449.1(a)(2)(A)4. have been turned over. 

5. VDECS reporting 

The reporting requirements in section 2449(g)(1)(D) specify the information regarding 

VDECS that must be reported to ARB. Section 2449(g)(1)(D)2. requires reporting of the 

VDECS model. After further review of this requirement during development of the 

DOORS system, staff has determined that reporting of just the VDECS model does not 

provide specific enough information to determine if the device was verified for a 

particular engine at the time of installation. Instead, it was determined that reporting of 

the VDECS family name is necessary for this purpose. It was also determined that 

reporting of the VDECS serial number is also important so that ARB enforcement will be 

able to track a particular device should there be questions regarding the proper 

functioning of the device. Reporting of the VDECS serial number data in DOORS would 

also facilitate transferring of information to a buyer should a vehicle with a VDECS be 

sold. Therefore, staff is proposing to remove the requirement to report the VDECS 

model and replace it with a requirement to report the VDECS family name and serial 

number. The DOORS system has been built to request the VDECS family name and 

serial number, so this change in the regulation will not require any rework for fleets that 

have reported early. 

 

E. Staff Recommendation 

Staff recommends that the Board adopt the proposed amendments to title 13, CCR, 

sections 2449 through 2449.3, as set forth in Appendix A. 
36
37

V. ECONOMIC IMPACTS 

This chapter describes the potential economic impacts of staff’s proposal, and 

specifically the provision to extend the deadline for fleets to accrue early double PM 

credit for the installation of VDECS from March 1, 2009, to January 1, 2010. Staff’s 

other proposed modifications are clarifications to the regulation, and will not affect the 

compliance costs for the regulation. 

A. Legal Requirements 

Sections 11346.3 and 11346.5 of the Government Code require 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 

businesses to compete. 

State agencies are also required to estimate the cost or savings to any state or local 

agency and school districts in accordance with instruction adopted by the Department of 

Finance. This estimate is to include any nondiscretionary costs or savings to local 

agencies and the costs or savings in federal funding to the state. 

B. Methodology 

To examine the potential economic impacts of the proposed regulation modifications, 

staff evaluated the impact of the proposed changes on individual fleets, as well as on 

the total statewide cost of the regulation. 

1. Individual fleet analysis 

To estimate the compliance costs for fleets under the proposed modifications, staff 

reevaluated a previous analysis of an actual rental company fleet that shared its fleet 

information with staff during the development of the original rulemaking. Staff used 

average costs for repowers, vehicle replacements, and retrofits as outlined in that Staff 

Report and the TSD (ARB, 2007a; ARB 2007b). The results of this analysis are 

provided in Section C below. 

2. Statewide cost analysis 

To estimate the average statewide costs of the proposed modifications, staff used the 

ARB Off-Road Compliance Model (the model) previously used to estimate the statewide 

costs of the regulation. This model is described in detail in Chapter XI and Appendix H 

of the TSD (ARB, 2007b). As a bounding exercise, staff used the model to calculate the 

statewide costs of a scenario in which all large fleets took advantage of the proposed 

extended early PM VDECS credit. The results were then compared to the costs of a 

scenario where no early PM VDECS credit was utilized. The results of this analysis are 

provided in Section C below. 
38

C. Economic Impacts of Proposed Modifications 

1. Individual fleet analysis results 

In the Final Statement of Reasons (FSOR) prepared for the initial adoption of the 

regulation, and the 2007 Board Hearing presentation, staff stated that the installation of 

early PM VDECS and the receipt of credits would help fleets spread out early 

compliance costs (ARB, 2007e; ARB, 2008a). However, because there were fewer 

VDECS available than staff anticipated at that time, fleets have not been able to fully 

utilize this credit, making the regulation less affordable for many fleets. 

For example, for the rental fleet modeled, staff found that they could reduce their PM 

compliance requirements significantly in the beginning years of the regulation by taking 

early actions, and receiving early double PM credit (ARB, 2007e). In modeling the 

fleet’s costs, staff assumed that one advantageous compliance path that the fleet could 

take would be to repower seven percent of its horsepower with engines meeting the Tier 

1 standard and have these vehicles retrofitted with VDECS prior to March 1, 2009. 

Following this compliance path with early retrofits would enable this fleet to build up 

early retrofit credits and be able to limit the number of retrofits it would be required to do 

in subsequent years. If the fleet did not do early retrofits, it would otherwise have to 

retrofit 20 percent of its horsepower in each of the first three years after compliance 

becomes mandatory (2010-2012). On the other hand, taking advantage of the early 

credit provisions the fleet would have been able to reduce its compliance costs by over 

$110,000, or by about seven percent, in the year when the maximum compliance costs 

occurred16, when compared to the scenario where it did not utilize the early credit 

provisions. Additionally, this fleet was able to reduce its 2010 compliance costs by 

approximately $1,400,000, or 80 percent, by utilizing the early credit provisions. 

If the deadline for double early credit is not extended and this fleet cannot utilize the 

early credit provisions as initially envisioned by staff, it could experience up to seven 

percent higher maximum annual compliance costs as well as significantly higher 

compliance costs in 2010, and could find the regulation less affordable than staff 

estimated in the Staff Report and TSD (ARB, 2007a, ARB, 2007b). Staff believes that 

many fleets are in a situation similar to that faced by the modeled fleet. Although these 

fleets would have liked to utilize the early credit provisions to spread out their 

compliance costs and lower their maximum annual compliance costs, they have been 

unable to do so because of a lack of verified devices. Overall, the proposal to extend 

early credit for PM VDECS would allow compliance to be more affordable for such 

fleets, and would not increase individual fleet costs above the costs estimated in the 

initial 2007 TSD (ARB, 2007b). 

2. Statewide cost analysis 

The statewide cost analysis indicates that the proposed modification should help fleets 

spread out the initial costs of the regulation, without increasing the total cost of the 

 

16 For most fleets that do not utilize early credit, the maximum compliance costs will occur in 

2010. However, if early credits are utilized, the maximum compliance costs will occur later 

during a fleet’s compliance period. 
39

regulation, or the costs in any given year. Staff anticipates that the proposed change 

would lower compliance costs in 2010, the year maximum annual regulation costs are 

expected to occur (ARB, 2007a). 

The results of staff’s analysis are as follows: 

• If all large fleets (those fleets with a March 1, 2010, compliance date) utilized the 

early credit provisions and installed retrofits in time to get double PM credit, the 

statewide costs in 2010 would be approximately 40 percent less than if no fleets 

performed early retrofitting; and 

• The total cost of the regulation over the period 2009 to 2030 would be 

approximately the same in both scenarios (all large fleets doing early retrofitting 

versus none doing early retrofitting). 

D. Impacts on California Economy 

The proposed modification to extend early double PM credit will not impose additional 

impacts of the regulation on the economy, nor is it expected to adversely impact 

employment. The modification is intended to allow fleets to spread out their compliance 

costs, which is expected to make the regulation more affordable. If in turn, that leads 

fewer fleets to reduce employment as a result of the regulation, the modification could 

benefit total California employment. 

E. Potential Impacts on Small Businesses 

The proposed modification to extend early double credit will not impose any additional 

costs on small businesses. Instead, it will provide a benefit to them by providing fleets 

additional time to install early VDECS, and thereby accumulate PM credit that will 

enable them to spread out their compliance costs in later years. While staff believes 

most small businesses are small or medium fleets, which have a first compliance date in 

2015 or 2013, respectively, a few small businesses meet the regulation’s definition of 

large fleet, which have their first compliance date in 2010. The proposed modification 

will benefit large fleets, and in particular small businesses that are large fleets, the most 

because their initial compliance date means their need for early PM credit is more 

urgent. 

F. Potential Impacts on Public Agencies 

The proposed modification to extend early double PM credit will not impose any 

additional costs on public agencies. Instead, it will provide a benefit to them by enabling 

fleets additional time to install VDECS early, and thereby accumulate PM credit that will 

enable them to spread out their compliance costs in later years. 

The proposed modification will benefit the State, Federal, and larger municipal fleets 

whose first compliance date is March 1, 2010, more than local municipalities that are 

small or medium fleets, because their earlier first compliance dates mean their need for 

early PM credit is potentially more urgent. 
40
41

VI. ENVIRONMENTAL IMPACTS 

This chapter describes the potential environmental impacts of extending early double 

credit for PM VDECS to January 1, 2010. The other proposed modifications are 

clarifications only, and will not decrease the estimated emissions benefits of the 

regulation. Therefore, they were not included as part of the analysis. 

A. Legal Requirements 

The legal requirements applicable to the environmental impact analysis are the same as 

those presented in the original off-road TSD (ARB, 2007b). Please see Chapter IX.A. of 

the off-road TSD for a description of these requirements. 

The results of the environmental impact analysis for the proposed regulation 

modifications are discussed in the sections below. Alternatives to the proposed 

changes to the regulation are discussed in Chapter VII of this report. 

B. Air Quality Impacts of Proposed Modifications 

The proposed amendments will have no effect on the anticipated emission reductions of 

NOx, because the provisions of the regulation that will provide NOx reductions (through 

engine and vehicle turnover) are not proposed to be amended. Any potential change in 

the emission benefits of the regulation will be limited to PM. Because it is not possible 

to know exactly how many or which fleets will choose to take advantage of the proposed 

extension of the early credit provisions, it is impossible to estimate precisely the change 

in anticipated PM reductions. However, staff expects there to be little to no overall 

adverse impact on air quality. To the extent that the proposed change could cause 

some increased emissions, overriding considerations exist for ARB to adopt the 

proposed changes. 

If the proposed amendments cause significant numbers of fleets to perform PM VDECS 

installations earlier than they otherwise would have, the proposed amendments may 

have a positive effect (i.e., result in reduced health impact from PM emissions) because 

extending the early credit deadline so that it is usable by more fleets should encourage 

fleets of all sizes to retrofit earlier than they otherwise would, thereby achieving 

immediate reductions in diesel PM. The earlier diesel PM is reduced, the more health 

benefits are achieved. 

On the other hand, the change could also have a negative effect (slightly increase 

emissions) because if many large fleets take advantage of the double PM credit 

provisions, this could reduce the total number of retrofits that would otherwise be 

completed by March 1, 2010. 

This possible increase in emissions is tempered by the fact that activity and total vehicle 

horsepower, and therefore emissions, from off-road vehicles have likely been reduced 

to some extent due to the current economic slowdown. To date, staff has analyzed 

California off-road (non-taxable) diesel fuel consumption data for 2007 and 2008 from 
42

the California Board of Equalization (BOE). As shown in Figure 5, overall off-road 

diesel fuel consumption in California has dropped in 200817 from 2006 and 2007 

consumption levels (BOE, 2008). While off-road diesel fuel consumption can provide a 

useful surrogate for off-road vehicle activity when combined with other data, this data 

alone does not provide a complete perspective, as it also includes diesel fuel 

consumption from other off-road uses such as rail, stationary, marine, and agricultural 

(which are not subject to the regulation). 

0

200,000,000

400,000,000

600,000,000

800,000,000

1,000,000,000

2004 2005 2006 2007 2008

Calendar Year

Diesel Fuel Consumption 

(Millions of Gallons)

Figure 5: California Off-Road Diesel Vehicle Fuel Consumption 

While this data shows a decrease in overall diesel fuel consumption from all off-road 

sources, and is likely reflective of general trends from all users of off-road diesel fuel, 

the specific changes in fuel use by fleets affected by the regulation (for example, the 

construction industry) cannot be derived from this data. 

C. Future Evaluation of Current Economic Conditions on Emissions 

It is well understood that the United States economy is currently in an economic 

downturn (Regalia, 2008; La Monica, 2008). In response to this, staff has been 

investigating the effect of this downturn on the industries affected by the regulation, and 

in particular the effect of this on emissions from off-road vehicles subject to the 

regulation. As part of this analysis, staff is evaluating available data on vehicle activity, 

as well as attempting to evaluate whether fleets may have changed their turnover 

practices due to the poor economy or their inability to obtain financing to comply with 

the regulation or take early compliance actions. Staff will present its findings at the 

January 2009, Board meeting. 

D. Other Environmental Impacts 

Staff does not believe there will be any additional environmental impacts from the 

proposed modifications to the regulation. 

 

17 The 2008 fuel consumption total is an estimate based on the extrapolation of off-road fuel 

consumption data for the first three quarters of 2008. 
43

VII. ALTERNATIVES CONSIDERED 

This chapter discusses the alternatives to the proposed 10-month extension of the early 

double credit that staff considered and why they were rejected in favor of the proposal. 

Because the proposed modifications to the other minor provisions are clarifications, staff 

did not perform an alternatives analysis for them. 

A. Extend Early Credit Deadline, but for Less Time 

First, staff considered a shorter extension of the early PM VDECS credit. Staff, 

however, determined that providing a shorter extension (only a couple of months) to the 

early credit deadline would not adequately address the need of fleets for additional time 

to purchase and install newly verified DECS. The longer the early credit deadline can 

be extended, the more time fleets will have to locate the resources they need (such as 

access to credit) to buy retrofits. Finally, many construction vehicles covered by the 

regulation are used heavily in the summer months, and not as much during the rainy 

winter months. The optimal period for fleets to datalog their vehicles is over the 

summer, with orders for retrofits placed before the fall. Therefore, staff believes the 

proposal to extend the double credit deadline to January 1, 2010 and the double credit 

guarantee date to September 1, 2009, is preferable to other alternatives that would 

extend the deadlines by only a few months. 

B. Extend Early Credit Deadline by a Full Year 

Staff considered extending the early double credit for VDECS by a full year to March 1, 

2010, but did not propose that option for two reasons. First, extending the deadline by a 

full year could result in a loss in emissions benefits. If the deadline were extended to 

March 1, 2010, this would effectively be the same as cutting the PM BACT retrofit 

requirement for that year down from 20 percent to 10 percent18. If the requirement for 

PM BACT were changed to 10 percent per year for the 2010 compliance date only, the 

number of VDECS installed would effectively be cut in half.19 Second, extending the 

deadline a full year could disrupt the business plans of retrofit manufacturers that have 

invested significantly so that they may provide VDECS to fleets. If these manufacturers 

fail or pull out of the California market because of a delay, that could jeopardize the 

regulation’s future PM benefits. For these reasons, staff did not propose extending the 

early credit deadline beyond January 1, 2010. 

C. Give More or Less than Double Credit before March 1, 2010 

Staff also considered providing more than double PM credit for VDECS installed before 

March 1, 2009, or to give between single and double credit for VDECS installations 

completed between March 1, 2009, and March 1, 2010 (for example, to give one and a 

 

18 If all large fleets received double credit for early PM VDECS, they could potentially fulfill the 

PM BACT requirements in 2010 by only retrofitting half of the vehicles they would otherwise 

have; essentially cutting the retrofitting requirements from 20 percent to 10 percent. 

19 This emission benefit loss could be mitigated somewhat, but not completely, by the 

decreased off-road vehicle activity due to the current economic downturn. 
44

half credit). Staff believes such an approach would add significant additional 

recordkeeping and compliance complexity to the regulation, while providing no 

additional relief to fleets relative to staff’s proposal. 

D. No Change 

Staff also considered making no changes to the regulation. However, as discussed in 

this report, staff believes it is necessary to provide fleets with additional time to 

purchase and install VDECS to receive early PM BACT credit. As such, making no 

change to this provision would not address this issue. 
45

VIII. REFERENCES 

ARA, 2008. American Rental Association. Equipment Rental Industry October 2008 

Update. American Rental Association, October 2008. 

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

Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. California Air 

Resources Board, October 2000. http://www.arb.ca.gov/diesel/documents/rrpFinal.pdf

ARB, 2006. California Air Resources Board OFFROAD2007 model. Available at 

http://www.arb.ca.gov/msei/offroad/offroad.htm.

ARB, 2007a. California Air Resources Board. Staff Report: Initial Statement of Reasons 

for Proposed Rulemaking; Regulation for In-Use Off-Road Diesel Vehicles. California 

Air Resources Board, April 2007. http://www.arb.ca.gov/regact/2007/ordiesl07/isor.pdf

ARB, 2007b. California Air Resources Board. Technical Support Document: Regulation 

for In-Use Off-Road Diesel Vehicles. California Air Resources Board, April 2007. 

http://www.arb.ca.gov/regact/2007/ordiesl07/TSD.pdf

ARB, 2007c. California Air Resources Board. Air Resource’s Board Proposed State 

Strategy for California’s 2007 State Implementation Plan: Revised Draft. California Air 

Resources Board, April 26, 2007. 

http://arb.ca.gov/planning/sip/2007sip/apr07draft/covtoc.pdf

ARB, 2007d. California Air Resources Board. Resolution 07-19. California Air 

Resources Board, July 26, 2007. 

http://www.arb.ca.gov/regact/2007/ordiesl07/res0719.pdf

ARB, 2007e. California Air Resources Board. Board Hearing Presentation: In-Use OffRoad Diesel Vehicle Proposed Regulation. Presented by California Air Resources 

Board Staff on July 26, 2007. 

ARB, 2008a. California Air Resources Board. Final Statement of Reasons for 

Rulemaking: Public Hearing to Consider the Adoption of a Proposed Regulation for InUse Off-Road Diesel Vehicles. California Air Resources Board, April 2008. 

http://www.arb.ca.gov/regact/2007/ordiesl07/fsor.pdf

ARB, 2008b. California Air Resources Board. Carl Moyer Program Advisory: 08-006 – 

Off-Road Construction Contract Extension. California Air Resources Board, August 15, 

2008. http://www.arb.ca.gov/msprog/moyer/advisories_005/08-006_extension.pdf

ARB, 2008c. California Air Resources Board. Staff Report: Initial Statement of Reasons 

for Proposed Rulemaking; Regulation for In-Use On-Road Diesel Vehicles. California 

Air Resources Board, October 2008. 

http://www.arb.ca.gov/regact/2008/truckbus08/tbisor.pdf
46

ARB, 2008d. California Air Resources Board. Off-Road Certification Database. Last 

accessed on November 24, 2008. Available at 

http://www.arb.ca.gov/msprog/offroad/cert/cert.php

ARB, 2008e. California Air Resources Board. Executive Order DE-08-004. Verification 

of Caterpillar® Diesel Particulate Filter. California Air Resources Board, October 23, 

2008. 

http://www.arb.ca.gov/diesel/verdev/pdf/executive_orders/de-08-004.pdf

ATA, 2008. ATA, 2008. Air Transport Association. PowerPoint presentation entitled 

Commercial Aviation: The Brakes are On, John Heimlich, VP & Chief Economist - Air 

Transport Association, November 5, 2008. 

BOE, 2008. Email communication between Michael Baker, ARB, and Phillip Bishop of 

the State Board of Equalization, Fuel Taxes Division. November 7, 2008. 

Brown, 2008. Personal communication between Kevin Brown of Emission Control 

Systems, Newmarket, Canada, and Cory Parmer, ARB; October 20, 2006. 

Bruenke, 2007a. Letter from Peter Bruenke, Huss, LLC, to Mike Hulse, ARB. Nonfeasible Installation; Caterpillar machines. October 25, 2007. 

http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm

Bruenke, 2007b. Letter from Peter Bruenke, Huss, LLC, to Rob Cram, Holt of 

California. Non-feasible Installation; Cat 769 Haul truck. December 12, 2007. 

http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm

Bruenke, 2008a. Letter from Peter Bruenke, Huss, LLC, to Mike Hulse, Peterson 

Tractor Co. Non-feasible Installation; Caterpillar D6K dozer. April 11, 2008. 

http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm

Bruenke, 2008b. Letter from Peter Bruenke, Huss, LLC, to Johanna Levine, ARB. 

Revoking the previous HUSS exemption letters. May 5, 2008. 

http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm

Bruenke, 2008c. Letter from Peter Bruenke, Huss, LLC, to John Rubiales, Peterson 

Tractor Co. Non-feasible Installation; Caterpillar D8L dozer. May 21, 2008. 

http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm

Bruenke, 2008d. Letter from Peter Bruenke, Huss, LLC, to John Rubiales, Peterson 

Tractor Co. and Johanna Levine, ARB. Non-feasible Installation; Caterpillar 992C. June 

13, 2008. http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm

CARL, 2008. Retrieved on Sept. 25, 2008, from the Carl Moyer Program Project 

Database (CARL). 
47

CIRB, 2008. Construction Industry Research Board. California Public Works 

Construction; Public Buildings & Heavy Construction. Construction Industry Research 

Board, September 24, 2008. 

Cox, 2008. Personal communication between Charlie Cox of Ironman and Elizabeth 

Yura, ARB; September 23, 2008. 

Cram, 2008. Personal communication between Rob Cram of Holt of California, and Kim 

Heroy-Rogalski, ARB. September 25, 2008. 

Cross, 2008a. Letter from Robert Cross, CARB, to Joe Alexio, DCL International 

Incorporated. Conditional Verification of DCL Mine-X Sootfilter. January 24, 2008. 

http://www.arb.ca.gov/diesel/verdev/level3/dcl_verificationletter.pdf

Cross, 2008b. Letter from Robert Cross, CARB, to Kevin Brown, Engine Control 

Systems, Limited. Conditional Verification of ECS PurifilterTM. October 20, 2008. 

http://www.arb.ca.gov/diesel/verdev/pdf/conditional/08-661-379.pdf

Cross, 2008c. Letter from Robert Cross, CARB, to Glen Luksik, Caterpillar Emissions 

Solutions. Conditional Verification of Caterpillar Diesel Particulate Filter. March 7, 

2008. http://www.arb.ca.gov/diesel/verdev/pdf/conditional/08-661-096.pdf

DOF, 2008a. California Department of Finance. California Economic Indicators: March 

– April 2008; Housing Still Weighs. California Department of Finance. Last accessed 

November 4, 2008. 

http://www.dof.ca.gov/HTML/FS_DATA/INDICATR/2008_CEI/CEI%200804.pdf

DOF, 2008b. California Department of Finance. California Economic Indicators: 

July/Aug 2008. Microsoft Excel Spreadsheet. California Department of Finance. Last 

accessed November 4, 2008. 

http://www.dof.ca.gov/HTML/FS_DATA/INDICATR/Ei_home.htm

ET, 2008 The Economic Times. US puts $700 bn bailout plan on fast track. The 

Economic Times November 7 2008 

http://economictimes.indiatimes.com/News/International_Business/US_puts_700_bn_ba

ilout_plan_on_fast_track/rssarticleshow/3683697.cms 

Gamez, 2008. Gamez, Saul. San Joaquin Valley Unified Air Pollution Control District: 

Rule 9210 Staff Report. August 27, 2008. 

http://www.valleyair.org/Workshops/postings/2008/08-27-

08_9210/R9210_staffreport_W2.pdf

Gentile, 2008. Gentile, Ralph. Outlook 2008, Exclusive Report: California Construction 

Mid-Year Update. The McGraw-Hill Companies, Inc., June 2008. 

Halloran, 2008. Personal communication between James Halloran of Caterpillar, Inc., 

and Cory Parmer, ARB; October 16, 2008. 
48

Jerman, 2008. Personal communication between David Jerman of DCL International 

Inc., and Cory Parmer, ARB; October 17, 2008. 

La Monica, 2008. La Monica, Paul. Call it a recession, already. CNN Money. Last 

accessed November 14, 2008. 

http://money.cnn.com/2008/11/07/markets/thebuzz/index.htm

Luksik, 2008. Letter from Glenn M. Luksik, Caterpillar, Inc., to Rob Cram, Holt of 

California and Johanna Levine, ARB. DPF Exemption; Caterpillar Motor Graders. June 

30, 2008. http://www.arb.ca.gov/msprog/moyer/retrofit/exemptions.htm. 

Ostrander, 2008. Personal communication between Jeramy Ostrander of Diesel 

Exhaust and Emissions, LLC, and Elizabeth Yura, ARB; September 24, 2008. 

Pasek, 2008. Pasek, Randall. South Coast AQMD SOON and Moyer Incentive 

Programs. Presented at South Coast SOON Workshop. August 27, 2008. 

http://www.aqmd.gov/tao/implementation/SOONworkshop081408.pdf 

Porcher, 2008. Personal communication from Dave Porcher, Camarillo Engineering, 

Chair of Off-Road Implementation Advisory Group (ORIAG) Fleet Subcommittee, at 

ORIAG meeting in Sacramento, CA. September 26, 2008. 

Regalia, 2008. Regalia, Martin. Recession! US Chamber Magazine. Last accessed 

November 14, 2008. 

http://www.uschambermagazine.com/content/0811_econ.htm

SCAQMD, 2008. South Coast AQMD Program Announcement #2008-09. Last 

accessed on November 3, 2008. 

http://www.aqmd.gov/rfp/attachments/2008/PA2008-09.doc 

Surma, 2008. Personal communication between Phillip Surma of HUSS, LLC, and Cory 

Parmer, ARB; October 16, 2008. 

Swenson, 2008. Personal communication between Tom Swenson of Cleaire Advanced 

Emissions Controls, LLC, and Cory Parmer, ARB; October 16, 2008. 

U.S. EPA, 2008a. California Authorization Request for Emission Standards for Off-road 

Diesel-fueled fleets, Docket ID No. EPA-HQ- OAR-2008-0691, 73 Federal Register 

58585, October 7, 2008. 

U.S. EPA, 2008b. California Authorization Request for Emission Standards for Off-road 

Diesel-fueled fleets; Extension of Comment Period, Docket ID No. EPA-HQ- OAR-2008-

0691, 73 Federal Register 67509, November 14, 2008.

White, 2008. Letter from Erik White, ARB, to Samir Sheikh, South Coast Air Quality 

Management District. October 15, 2008. 
49

Yardemian, 2008. Email communication between Dinh Quach, ARB, and Vasken 

Yardemian of the South Coast Air Quality Management District. October 29, 2008. 

Yengst, 2005. Yengst Associates Machinery Market Research. Equipment Analysis 

North America. June, 2005. 
50
51

APPENDIX A: PROPOSED REGULATION ORDER FOR IN-USE OFF-ROAD 

DIESEL-FUELED FLEETS 

Note: Proposed modifications are shown in underline to indicate additions and 

strikeout to indicate deletions, compared to the preexisting regulatory language. 

The symbol “*****” indicates that regulatory language not being amended is not 

shown. 

Amend sections 2449, 2449.1, and 2449.2, title 13, California Code of Regulation to 

read as follows. 

§ 2449 General Requirements for In-Use Off-Road Diesel-Fueled Fleets 

***** 

(d) Performance Requirements - 

***** 

(4) Changing Fleet Size – 

(A) Small fleets that become medium or large fleets must meet the medium or 

large fleet requirements, respectively, on the reporting date two years 

subsequent to the year they became a medium or large fleet. If such fleets 

become small again, they must keep meeting the medium or large fleet 

requirements for two years after becoming a small fleet. 

(B) Large fleets that become medium fleets may meet either the medium or large 

fleet requirements on the next reporting date. Large fleets that become small 

fleets may meet either the small or large fleet requirements on the next 

reporting date. 

(C) Medium fleets that become small fleets may meet either the small or medium 

fleet requirements on the next reporting date. Medium fleets that become 

large fleets must meet the large fleet requirements on the reporting date two 

years subsequent to the year they became a large fleet. 

***** 

(g) Reporting – 

Reporting is required for each and every fleet. Large and medium fleets may report 

separately for different divisions or subsidiaries of a given company or agency. Fleet 

owners may submit reporting information using forms (paper or electronic) approved by 

the Executive Officer. 

(1) Initial reporting – All fleet owners must submit the information in section 

2449(g)(1)(A) through (G) to ARB by their initial reporting date. In the initial 

reporting, fleet owners must report information regarding each vehicle subject to 

this regulation that was in their fleet on March 1, 2009. Systems or non-diesel 
52

fueled vehicles that are used in place of a vehicle that would be subject to this 

regulation must also be reported. The initial reporting date for large fleets is April 

1, 2009. The initial reporting date for medium fleets is June 1, 2009. The initial 

reporting date for small fleets is August 1, 2009. Reports must include the 

following information: 

***** 

(D) Verified Diesel Emission Control Strategies - For each VDECS that is 

installed on an engine listed per section 2449(g)(1)(C) report the following 

information. 

1. VDECS Manufacturer; 

2. VDECS ModelFamily; 

3. Verification level; 

4. Verified percent NOx reduction (if any); 

5. Date installed; 

6. VDECS Serial Number.

***** 

(h) Record keeping – 

Fleet owners must maintain copies of the information reported under section 2449(g), 

as well as the records described in section 2449(h) below, and provide them to an agent 

or employee of the ARB within five business days upon request. Records must be kept 

at a location within the State of California. 

***** 

(8) Record Retention – Each fleet owner shall maintain the records for each vehicle 

subject to the regulation until it is retired and for the overall fleet as long as the 

owner has a fleet or March 1, 2030, whichever is earlier. If vehicle ownership is 

transferred, the seller shall convey the vehicle records including vehicle data per 

section 2449(g)(1)(B), engine data per section 2449(g)(1)(C), and VDECS data 

per section 2449(g)(1)(D) to the buyer. If fleet ownership is transferred, the 

seller shall convey the fleet records including fleet data per sections 

2449(g)(1)(A) through (G) to the buyer. Dealers Any person selling a vehicle 

with an engine subject to this regulation in California must maintain records of 

the disclosure of regulation applicability required by Section 2449(j) for three 

years after the sale. 

***** 

Note: Authority cited: Sections 39002, 39515, 39516, 39600, 39601, 39602, 39650, 

39656, 39658, 39659, 39665, 39667, 39674, 39675, 40000, 41511, 42400, 42400.1, 

42400.2, 42400.3.5, 42402, 42402.1, 42402.2, 42402.4, 42403, 43000, 43000.5, 43013, 

43016, and 43018, Health and Safety Code. Reference: Sections 39002, 39515, 39516, 

39600, 39601, 39602, 39650, 39656, 39657, 39658, 39659, 39665, 39667, 39674, 

39675, 40000, 41511, 42400, 42400.1, 42400.2, 42402.2, 43000, 43000.5, 43013, 

43016, and 43018, Health and Safety Code.
53

§ 2449.1 NOx Performance Requirements 

(a) Performance Requirements 

***** 

(2) BACT Requirements 

***** 

(A) Turnover Requirements for Fleets Not Meeting NOx Target Rate – A fleet 

may meet the turnover requirements by retiring a vehicle, designating a 

vehicle as a low-use vehicle, repowering a vehicle, rebuilding the engine to a 

more stringent emissions configuration, or applying a VDECS verified to 

achieve NOx reductions. If repowering a vehicle or rebuilding the engine to a 

more stringent emissions configuration, the new engine must be Tier 2 or 

higher and must be a higher tier than the engine replaced or rebuilt. The 

method for counting VDECS verified to achieve NOx reductions is specified in 

section 2449.1(a)(2)(A)8. 

***** 

5. Delay Tier 1 turnover - All vehicles with a Tier 1 or higher engine are 

exempt from the turnover requirement until the compliance year ending

March 1, 2013 (i.e., the first turnover of Tier 1 or higher engines would be 

required between March 2, 2012 and March 1, 2013), provided that all Tier 

0 vehicles in the fleet owner’s fleet that do not qualify for an exemption 

under section 2449.1(a)(2)(A)4. have been turned over. 

*****

Note: Authority cited: Sections 39002, 39515, 39516, 39600, 39601, 39602, 43000, 

43000.5, 43013, 43016, and 43018, Health and Safety Code. Reference: Sections 

39002, 39515, 39516, 39600, 39601, 39602, 39650, 39656, 39657, 39658, 39659, 

39665, 39667, 43000, 43000.5, 43013, 43016, and 43018, Health and Safety Code. 

§ 2449.2 PM Performance Requirements 

***** 

(a) Performance Requirements 

***** 

(2) BACT Requirements 

***** 

(A) PM Retrofit Requirements for Fleets Not Meeting Diesel PM Target Rate 

***** 

2. Carryover PM retrofit credit – 

a. Beginning - All fleets other than those meeting the criteria in (i) or (ii) 

below for vehicles remaining in their fleets begin with zero carryover 

retrofit credit on March 1, 2009. 

i. Double Credit for Early PM Retrofits – Fleets that have installed 

the highest level VDECS on their vehicles before January 1, 2010

March 1, 2009 begin with a carryover retrofit credit equal to: 2
54

multiplied by total maximum power of engines on which highest 

level VDECS was installed before January 1, 2010 March 1, 2009, 

unless the contract for funding the VDECS stipulates single credit 

for installation of the VDECS. 

ii. Single Credit for Other PM Retrofits Before Initial Compliance 

Date – Medium fleets that install highest level VDECS on their 

vehicles between January 1, 2010 March 1, 2009 and February 

29, 2012 accumulate carryover retrofit credit equal to total 

maximum power of engines on which highest level VDECS was 

installed. Small fleets that install highest level VDECS on their 

vehicles between January 1, 2010 March 1, 2009 and February 

28, 2014 accumulate carryover retrofit credit equal to total 

maximum power of engines on which highest level VDECS was 

installed. 

b. Accumulating carryover PM retrofit credit – Beginning March 1, 

2011 2010 for large fleets, March 1, 2013 for medium fleets, and 

March 1, 2015 for small fleets, a fleet accumulates carryover retrofit 

credit each year it retrofits more than 20 percent of its maximum 

power. The amount accumulated is the percent of maximum power 

retrofit in excess of 20 percent in the past 12 months prior to March 1. 

A large fleet also accumulates carryover retrofit credit on March 1, 

2010 if the sum of the double retrofit credit earned from March 1, 2009 

to January 1, 2010 plus the single retrofit credit earned from January 

1, 2010 to March 1, 2010 exceeds 20 percent of its maximum 

horsepower. The amount accumulated is the sum of double credit 

retrofit credit earned from March 1, 2009 to January 1, 2010 plus the 

single credit earned from January 1, 2010 to March 1, 2010 in excess 

of 20 percent of fleet’s maximum horsepower in the past 12 months.

***** 

Note: Authority cited: Sections 39002, 39515, 39516, 39600, 39601, 39602, 39650, 

39656, 39658, 39659, 39665, 39667, 39674, 39675, 40000, 41511, 42400, 42400.1, 

42400.2, 42400.3.5, 42402, 42402.1, 42402.2, 42402.4, 42403, 43000, 43000.5, 43013, 

43016, and 43018, Health and Safety Code. Reference: Sections 39002, 39515, 39516, 

39600, 39601, 39602, 39650, 39656, 39657, 39658, 39659, 39665, 39667, 39674, 

39675, 40000, 41511, 42400, 42400.1, 42400.2, 42402.2, 43000, 43000.5, 43013, 

43016, and 43018, Health and Safety Code. 
55

APPENDIX B: ASSUMPTIONS FOR STATEWIDE FLEET RETROFITTING 

ANALYSIS 

This appendix provides the assumptions and methodologies used to estimate Verified 

Diesel Emission Control System (VDECS) applicability. 

ARB estimated the in-use off-road diesel vehicle population that could have VDECS 

installed for three specific cases; (1) the percentage of vehicles that could have any of 

the current verified devices installed, (2) the percentage of vehicles that could have 

passively regenerated VDECS installed today, and (3) the percentage of vehicles that 

could have had passively regenerated VDECS installed more than two weeks prior to 

the deadline for guaranteed double retrofit credit as of mid-October 2008. 

To develop this estimate, staff used the following information: 

• The verification letters (also referred to as Executive Orders) for each off-road 

VDECS. The Executive Orders specify the horsepower, model year, emissions 

levels, and whether the device can be used with engines equipped with exhaust 

gas recirculation (EGR). 

• Letters from VDECS manufacturers exempting certain vehicle types or models 

from retrofitting under the Carl Moyer program (Bruenke, 2007a; Bruenke, 2007b; 

Bruenke, 2008a; Bruenke, 2008b; Bruenke, 2008c; Bruenke, 2008d; Luksik, 

2008). Staff’s analysis assumes that such exempted vehicle types or models 

cannot be retrofit. 

Staff based the estimate of VDECS applicability on horsepower (hp), particulate matter 

(PM) emissions limit, and engine model years. Staff chose these parameters because 

these are the most important factors limiting verifications and because this data is 

available in the ARB emissions inventory model (the OFFROAD model). Each VDECS 

has a number of other requirements which would prevent it from being applied to a 

particular engine/vehicle combination, including but not limited to: 

• specific exemptions or inclusions by engine family name, 

• use of fuel additives, 

• poor engine conditions with excessive emissions, 

• insufficient exhaust pressure for the device, 

• no appropriate or safe means of installing the device on the vehicle 

infrastructure, 

• exclusion due to the use tracks instead of rubber tires, 

• lack of available electrical power for actively regenerated VDECS, and 

• inadequate exhaust temperature for passive VDECS. 

These factors would need to be considered for each engine not initially ruled out based 

on hp, PM emissions, and model year. The factors listed above are not included in the 

ARB emissions inventory model (the OFFROAD model), nor does staff have access to 

other vehicle or engine population data that would allow the factors above to be factored 

into an overall estimate of VDECS applicability. An estimation on the effect of these 

factors on the breadth of VDECS applicability is unlikely to be accurate without an in-
56

depth inspection, including data logging, of a sizeable portion of California’s inventory of 

off-road equipment. Therefore, it is important to note that the estimations of VDECS 

applicability below refer only to the engines which are not initially ruled out by the age, 

PM emissions, and size of the engine. The estimates should be considered upper 

bounds on the fraction of vehicle horsepower to which retrofits could be applied. 

Passive and Active Retrofits 

To determine the percentage of vehicles which could have any currently verified or 

conditionally verified device installed, staff reviewed the breadth of the VDECS 

verifications for all verified devices. Staff concluded that the HUSS Umwelttechnik 

GmbHFS-MK Series Diesel Particulate Filter (Huss DPF), which is a level 3 actively 

regenerated device, is the device with the widest applicability. In fact, the Huss device 

is verified for virtually any engine, regardless of age, horsepower or emission levels, 

with the exception of engines using exhaust gas recirculation and vehicles exempted 

specifically from retrofitting under the Carl Moyer program. The engines specifically 

exempted from the Huss verification can in most cases be retrofit by an alternative 

device, hence the only engines which can be entirely ruled out from receiving any of the 

currently verified retrofit devices are those using exhaust gas recirculation. 

Based on staff’s analysis, the only manufacturer with a substantive market share of the 

applicable engines in California using exhaust gas recirculation in all or most of their 

equipment in any given year was Volvo, in 2006 and later model year engines. 

Although other manufacturers have used exhaust gas recirculation, they did not do so in 

quantities which would justify removing all of their engine lines from the engines which 

could be retrofit. 

The market share of Volvo in off-road construction application was determined by 

industry reports from the Yengst Associates (Yengst, 2005). The model years for Volvo 

engines using EGR were accounted for based on the estimated useful life of the 

equipment types using Volvo engines (ARB, 2007b). 

Staff estimate that exhaust gas recirculation engines comprise 0.4 percent of the offroad diesel inventory, and are the only category that can be absolutely excluded when 

considering any of the available retrofits. ARB staff acknowledges that many other 

vehicles and engines are not suited to be retrofit, however as stated above, most the 

additional exemptions would need to be identified on a case by case basis. 

Passively Regenerated Retrofits 

To determine the percentage of vehicles which could have one of the passively 

regenerated VDECS installed, staff considered the Caterpillar DPF, DCL MINE-X 

Sootfilter, and the ECS Purifilter verifications on November 1, 2008 (ARB, 2008d; 

Cross, 2008a; Cross, 2008b). The restrictions on engine applicability are listed in Table 

1 below. 
57

Table 1: Passively Regenerated Retrofit Requirements 

Caterpillar DPF DCL MINE-X 

Sootfilter ECS Purifilter 

Horsepower Range 175 - 600 hp 175 - 300 hp 50 - 750 hp 

PM Emissions 

Limit 0.2 g/bhp-hr 0.15 g/bhp-hr 0.2 g/bhp-hr 

Engine Model 

Years 1996 - 2008 1996 - 2008 1996 - 2008 

The PM emissions limits are applied to the engine’s certification level , not the 

certification standard. Although the standards did not require engines to meet a limit of 

0.2 g/bhp-hr for PM until 2001 at the earliest, many engines tested at or below 0.2 

g/bhp-hr as early as 1996 (ARB, 2008e), and could have one of the passive devices list 

above installed. Although many engines test above these standards, no specific model 

year of 1996 or later, or horsepower category, can be excluded, as each category has 

at least a few engines which meet the standard. 

Comparing the applicability requirements, staff filtered the off-road inventory (ARB, 

2006) for all vehicles between 50 and 750 horsepower, for Tier 1 or newer engine 

models. Engines using exhaust gas recirculation were also discounted, using the 

method described previously for active and passive retrofits. 

Staff estimate that 41 percent of the off-road diesel horsepower covered by the 

regulation could not have a passive device installed currently due to restriction on hp, 

model year and emissions. As stated previously, of the remaining 59 percent of 

California’s horsepower, staff expect that the factors such as engine condition, 

installation issues, and duty cycle would further reduce the amount of vehicles that 

could be retrofit with a passive device, however the engine would need to be evaluated 

on an individual basis. 

Passively Regenerated Retrofits Available Mid-October 2008 for Double Retrofit Credit 

Staff also wanted to determine the percentage of vehicles that could have had a 

passively regenerated retrofit installed at least two weeks prior to the deadline to 

guarantee double retrofit credit, November 1, 2008. This entailed removing the ECS 

Purifilter which was verified on October 20, 2008 and the extension of the Caterpillar 

DPF, which had the verification expanded on October 24, 2008. Table 2 below shows 

the applicability requirements for the Caterpillar DPF and DCL MINE-X Sootfilter prior to 

the expansion of verification (Cross, 2008a; Cross, 2008c). 
58

Table 2: Limited Caterpillar DPF and DCL Sootfilter Requirements 

Caterpillar DPF DCL MINE-X 

Sootfilter 

Horsepower Range 175 - 300 hp 175 - 300 hp 

PM Emissions 

Limit 0.2 g/bhp-hr 0.15 g/bhp-hr 

Engine Model 

Years 1996 - 2008 1996 - 2008 

Additionally, both retrofits were only verified for rubber-tired applications. Although 

many vehicle categories are comprised of both rubber tired and track vehicles, only the 

crawler tractor category can be assumed to be comprised solely of track vehicles and 

can be completely ruled out. 

Comparing the applicability requirements, staff filtered the off-road inventory (ARB, 

2006) for all vehicles between 175 and 300 horsepower, for Tier 1 or newer engines, 

and excluded crawler tractors. Engines that used exhaust gas recirculation were also 

discounted, using the method described above for active and passive retrofits. 

Staff estimate that 89 percent of the off-road diesel horsepower covered by the 

regulation could not be retrofit with one of the passively regenerated devices installed 

prior to mid-October, 2008, based on horsepower, model year, and emissions. As with 

the previous analysis, the remaining 11 percent would need to be evaluated on 

individual basis. 

HUSS Exemptions by Vehicle Model 

The effect of HUSS exemptions (Bruenke, 2007a; Bruenke, 2007b; Bruenke, 2008a; 

Bruenke, 2008b; Bruenke, 2008c; Bruenke, 2008d; Luksik, 2008) on the statewide fleet 

was estimated using information from the Machinery Trader auction site 

(www.machinerytrader.com). The market share of applicable engine models was 

estimated by comparing the number of specific vehicle models for sale against the total 

number of vehicles for sale in that vehicle category (for example, Cat 769 off-road 

trucks were 3.5 percent of the total off-road trucks for sale on Machinery Trader on 

November 24, 2008. These market share estimates were applied to the total vehicle 

type populations in ARB’s off-road inventory (ARB, 2007) to estimate the number of 

vehicles and horsepower currently used in California that would fall under the HUSS 

exemptions. The total horsepower of exempted vehicles was compared against the 

total statewide horsepower (ARB, 2006) to determine the percent of statewide 

horsepower affected by the HUSS exemptions.

References 

All references for this appendix can be found in Chapter VIII. 
59

APPENDIX C: SHOWCASE AND SEP 

Table 1: Showcase Retrofits Installed as of November 2008

Year HP Tier Vehicle Type Installed Device Type of 

Device 

1995 275 0 Rubber Tired Loader CAT - EUG/DPF Passive 

2003 255 2 Crawler Tractor DCL MINE-X Passive 

1997 400 1 Scraper DCL MINE-X Passive 

1997 559 1 Scraper DCL MINE-X Passive 

1997 400 1 Scraper DCL MINE-X Passive 

1997 559 1 Scraper DCL MINE-X Passive 

2004 95 2 Tractor/Loader/Backhoe JM-CRT Passive 

1994 168 0 Excavator Sud Chemie 

ENVICAT Passive 

1999 222 1 Excavator Sud Chemie 

ENVICAT Passive 

Table 2: Showcase Retrofits Planned for Installation 

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

2006 405 3 Crawler Tractor CDT PermitFBC Passive FBC 

1997 67 0 Tractor/Loader/Backhoe Dinex DiNox Passive+NOx 

Control 

2002 73 1 Tractor/Loader/Backhoe Dinex-Dipex Passive 

1992 134 0 Rubber Tired Loader Dinex DiNox Passive+NOx 

Control 

2001 62 1 Rubber Tired Loader Dinex-Dipex Passive 

1992 375 0 Rubber Tired Loader Mann Hummel 

FBC Passive FBC 

2001 107 1 Rough Terrain Forklift Nett Tech - 

Active SCR 

Active+NOx 

Control 

2001 109 1 Rough Terrain Forklift Nett Tech - 

Active SCR 

Active+NOx 

Control 

2002 123 1 Rough Terrain Forklift Nett Tech - 

Active SCR 

Active+NOx 

Control 

1998 312 1 Excavator Nett Tech - 

Passive SCR 

Passive+NOx 

Control 

1990 270 0 Wheel Loader Nett Tech - 

Active SCR 

Active+NOx 

Control 

2000 178 1 Excavator Nett Tech - 

Active SCR 

Active+NOx 

Control 

2000 222 1 Excavator Nett Tech - 

Passive SCR 

Passive+NOx 

Control 
60

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

1991 375 0 Excavator Extengine 

ADECII 

Active+NOx 

Control 

1991 250 0 Excavator Recat-ESW 

DC-100 Active+FBC 

1984 350 0 Excavator Sud Chemie 

ENVICAT Passive 

2002 692 1 Excavator Sud Chemie 

ENVICAT Passive 

1986 552 0 Rubber Tired Dozer Extengine 

ADECII 

Active+NOx 

Control 

1997 400 1 Scraper, Rear Extengine 

ADECII 

Active+NOx 

Control 

1986 400 0 Scraper, Rear Extengine 

ADECII 

Active+NOx 

Control 

1997 552 1 Scraper, Front Extengine 

ADECII 

Active+NOx 

Control 

1986 596 0 Scraper, Front Extengine 

ADECII 

Active+NOx 

Control 

1997 275 1 Motor Grader Nett TechPassive SCR 

Passive+NOx 

Control 

1996 177 1 Crawler Tractor CDT FBCDPF Passive+FBC 

1998 75 1 Off-Highway Tractors CDT FBCDPF Passive+FBC 

1998 75 1 Off-Highway Tractors CDT FBCDPF Passive+FBC 

2006 120 2 Off-Highway Tractors CDT FBCDPF Passive+FBC 

1997 120 1 Off-Highway Tractors CDT FBCDPF Passive+FBC 

1996 177 1 Crawler Tractor CDT PermitFBC Passive+FBC 

1997 95 0 Off-Highway Tractors CDT PermitFBC Passive+FBC 

1993 136 0 Rubber Tired Loader CDT PermitFBC Passive+FBC 

1996 170 0 Rubber Tired Loader CDT PermitFBC Passive+FBC 

2006 91 2 Tractor/Loader/Backhoe

s 

CDT PermitFBC Passive+FBC 

1998 75 1 Off-Highway Tractors 

CDT Platinum 

Plus Purifilter 

Filter 

Passive+FBC 

1998 75 1 Off-Highway Tractors CDT Platinum Passive+FBC 
61

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

Plus Purifilter 

Filter 

1999 109 1 Off-Highway Tractors 

CDT Platinum 

Plus Purifilter 

Filter 

Passive+FBC 

1996 145 0 Rubber Tired Loader 

CDT Platinum 

Plus Purifilter 

Filter 

Passive+FBC 

1993 120 0 Off-Highway Tractors DCL Mine-X Passive 

1995 120 0 Off-Highway Tractors DCL Mine-X Passive 

1993 136 0 Rubber Tired Loader DCL Mine-X Passive 

1992 136 0 Rubber Tired Loader DCL Mine-X Passive 

1995 190 0 Rubber Tired Loader DCL Mine-X Passive 

2006 75 2 Tractor/Loader/Backhoe DCL Mine-X Passive

2006 75 2 Tractor/Loader/Backhoe DCL Mine-X Passive

1992 170 0 Rubber Tired Loader Dinex-Dipex Passive 

2001 108 1 Off-Highway Tractors Donaldson 

Passive DPF Passive 

2001 110 1 Off-Highway Tractors Donaldson 

Passive DPF Passive 

2004 129 2 Rubber Tired Loader Donaldson 

Passive DPF Passive 

2004 170 2 Rubber Tired Loader Donaldson 

Passive DPF Passive 

1995 120 0 Paver ECS Assisted 

Purifilter Active+Electric

1993 81 0 Rubber Tired Loader ECS Assisted 

Purifilter Active+Electric

1993 136 0 Rubber Tired Loader ECS Assisted 

Purifilter Active+Electric

1992 136 0 Rubber Tired Loader ECS Assisted 

Purifilter Active+Electric

1993 75 0 Tractor/Loader/Backhoe ECS Assisted 

Purifilter Active+Electric

1999 89 1 Off-Highway Tractors ECS Purifilter Passive 

1999 89 1 Off-Highway Tractors ECS Purifilter Passive 

1995 120 0 Off-Highway Tractors ECS Purifilter Passive 

1995 120 0 Off-Highway Tractors ECS Purifilter Passive 

1992 136 0 Rubber Tired Loader ECS Purifilter Passive 

2004 173 2 Rubber Tired Loader ECS Purifilter Passive 

2003 205 2 Rubber Tired Loader ECS Purifilter Passive 

1993 75 0 Tractor/Loader/Backhoe ECS Purifilter Passive 

1995 105 0 Crawler Tractor Huss FS-MD Active 

2002 75 1 Off-Highway Tractors Huss FS-MD Active 
62

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

1995 76 0 Other Mobile Off-Road 

Vehicle Huss FS-MD Active 

1992 136 0 Rubber Tired Loader Huss FS-MD Active 

1993 190 0 Rubber Tired Loader Mann-Hummel 

FBC Passive+FBC 

2006 75 2 Off-Highway Tractors Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

1998 83 1 Off-Highway Tractors Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

1999 95 1 Off-Highway Tractors Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

2001 75 1 Tractor/Loader/Backhoe Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

1993 120 0 Off-Highway Tractors Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

1998 75 1 Off-Highway Tractors Nett TechActive SCR 

Active+NOx 

Control 

2000 105 1 Off-Highway Tractors Nett TechActive SCR 

Active+NOx 

Control 

1996 150 0 Rubber Tired Loader Nett TechActive SCR 

Active+NOx 

Control 

2004 194 2 Rubber Tired Loader Nett TechActive SCR 

Active+NOx 

Control 

2004 194 2 Rubber Tired Loader Nett TechActive SCR 

Active+NOx 

Control 

1997 120 1 Off-Highway Tractors Nett TechPassive SCR 

Passive+NOx 

Control 

1996 150 0 Rubber Tired Loader Nett TechPassive SCR 

Passive+NOx 

Control 

1999 109 1 Off-Highway Tractors Rypos 

HDPF/C Active+Electric

2003 116 2 Off-Highway Tractors Rypos 

HDPF/C Active+Electric

1999 89 1 Off-Highway Tractors Sud Chemie 

ENVICAT Passive 

1999 89 1 Off-Highway Tractors Sud Chemie 

ENVICAT Passive 

1992 136 0 Rubber Tired Loader Sud Chemie 

ENVICAT Passive 

2004 128 2 Rubber Tired Loader Sud Chemie 

ENVICAT Passive 

1993 136 0 Rubber Tired Loader Sud Chemie 

ENVICAT Passive 

1996 170 0 Wheel Loader ECS Assisted Active+Electric
63

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

Purifilter 

1993 220 0 Rubber Tired Loader DCL Mine-X Passive 

2006 211 3 Rubber Tired Loader CAT - DPF Passive 

2000 114 1 Rubber Tired Loader Nett TechActive SCR 

Active+NOx 

Control 

2004 170 2 Rubber Tired Loader CDT FBCDPF Passive+FBC 

2005 260 2 Rubber Tired Loader CDT PermitFBC Passive+FBC 

2001 145 1 Tractor Wheel Loader DCL MINE-X Passive 

2004 170 2 Rubber Tired Loader Donaldson 

Passive DPF Passive 

2006 160 2 Tractor Wheel Loader Extengine 

ADECII 

Active+NOx 

Control 

2004 90 2 Tractor Wheel Loader Huss FS-MD Active 

2005 98 2 Tractor Recat - ESW 

DC-100 Active+FBC 

2002 188 1 Excavator CDT PermitFBC Passive+FBC 

2001 315 2 Rubber Tired Loader Dinex DiNox Passive+NOx 

Control 

1998 240 1 Excavator Donaldson 

Active DPF Active+Electric

1999 235 1 Rubber Tired Loader Donaldson 

Active DPF Active+Electric

2003 66 1 Rough Terrain Forklift ECS Purifilter Passive 

1994 200 0 Rubber Tired Loader Extengine 

ADECII 

Active+NOx 

Control 

1994 200 0 Rubber Tired Loader Extengine 

ADECII 

Active+NOx 

Control 

1994 128 0 Excavator Extengine 

ADECII 

Active+NOx 

Control 

1997 54 0 Excavator Huss FS-MD Active 

1994 168 0 Excavator Mann-Hummel 

GMBH CRT Passive 

2003 66 1 Rough Terrain Forklift Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

2003 247 2 Excavator Nett TechPassive SCR 

Passive+NOx 

Control 

1992 256 0 Rubber Tired Loader Nett TechPassive SCR 

Passive+NOx 

Control 

1994 200 0 Rubber Tired Loader Sud Chemie 

ENVICAT Passive 

2006 418 3 Scraper, Rear CAT - DPF Passive 
64

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

2006 577 3 Scraper, Front CAT - DPF Passive 

1996 285 1 Motor Grader CDT PermitFBC Passive+FBC 

2006 418 3 Scraper, Rear CDT PermitFBC Passive+FBC 

2006 577 3 Scraper, Front CDT PermitFBC Passive+FBC 

2006 418 3 Scraper, Rear 

CDT Platinum 

Plus Purifilter 

Filter 

Passive+FBC 

2006 577 3 Scraper, Front 

CDT Platinum 

Plus Purifilter 

Filter 

Passive+FBC 

2007 405 3 Crawler Tractor DCL MINE-X Passive 

1998 514 1 Excavator Recat-ESW 

DC-100 Active+FBC 

2007 405 3 Crawler Tractor Sud Chemie 

ENVICAT Passive 

2007 405 3 Crawler Tractor Sud Chemie 

ENVICAT Passive 

2006 405 3 Crawler Tractor Sud Chemie 

ENVICAT Passive 

1989 375 0 Rubber Tired Loader Rypos 

HDPF/C Active+Electric

1995 400 0 Rubber Tired Loader Sud Chemie 

ENVICAT Passive 

1996 400 0 Rubber Tired Loader Sud Chemie 

ENVICAT Passive 

1997 290 1 Excavator CAT-DPF Passive 

1990 310 0 Rubber Tired Dozer CATEUG/DPF 

Passive+NOx 

Control 

2002 128 1 Excavator CDT PermitFBC Passive+FBC 

1998 305 1 Crawler Tractor DCL Mine-X Passive 

1997 168 1 Excavator ECS Assisted 

Purifilter Active+Electric

1995 365 0 Scraper ECS Assisted 

Purifilter Active+Electric

1997 358 1 Off-Highway Truck ECS Purifilter Passive

1997 305 1 Crawler Tractor Nett TechActive SCR 

Active+NOx 

Control 

1997 165 1 Grader Recat-ESW 

DC-100 Active+FBC 

2004 185 2 Grader CAT - DPF Passive 
65

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

2005 185 2 Grader CAT - DPF Passive 

2001 201 1 Rubber Tired Loader Donaldson 

DPF-SCR 

Passive+NOx 

Control 

1998 165 1 Grader ECS Assisted 

Purifilter Active+Electric

2001 102 1 Tractor/Loader/Backhoe ECS Assisted 

Purifilter Active+Electric

1999 106 1 Rough Terrain Forklift ECS Purifilter Passive 

2006 111 2 Tractor/Loader/Backhoe Huss FS-MD Active

1995 170 0 Rubber Tired Loader Mann-Hummel 

FBC Passive+FBC 

2007 440 3 Scraper Donaldson 

Passive DPF Passive 

2006 404 3 Excavator Dinex DiNox Passive+NOx 

Control 

2006 120 2 Mobile Jumbo Screen 

Plant Dinex DiNox Passive+NOx Control 

2007 385 3 Retek Startrack Mobile 

Recycling Plant (Impact) 

Extengine 

ADECII 

Active+NOx 

Control 

2006 343 3 Rubber Tired Loader Extengine 

ADECII 

Active+NOx 

Control 

2007 440 3 Retek Startrack Mobile 

Recycling Plant (Cone) 

Nett TechPassive SCR Passive+NOx 

Control 

1996 310 1 Crawler Tractor ECS Assisted 

Purifilter Active+Electric

1997 62 0 Tractor/Loader/Backhoe ECS Assisted 

Purifilter Active+Electric

1994 220 0 Rubber Tired Loader Extengine 

ADECII 

Active+NOx 

Control 

1999 175 1 Rubber Tired Loader Extengine 

ADECII 

Active+NOx 

Control 

1981 255 0 Rubber Tired Dozer Huss FS-MD Active 

1997 215 1 Grader Huss FS-MD Active 

1989 450 0 Rubber Tired Dozer Huss FS-MD Active 

1994 175 0 Scraper Huss FS-MD Active 

2003 73 1 Tractor/Loader/Backhoe Huss FS-MD Active 

1982 255 0 Rubber Tired Dozer Mann-Hummel 

GMBH CRT Passive 

1979 330 0 Scraper Mann-Hummel 

GMBH CRT Passive 

2004 115 2 Crawler Tractor Nett TechActive SCR 

Active+NOx 

Control 

1995 335 0 Crawler Tractor Nett TechActive SCR 

Active+NOx 

Control 
66

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

2002 110 1 Rubber Tired Loader Nett TechPassive SCR 

Passive+NOx 

Control 

2004 230 2 Rubber Tired Loader Nett TechPassive SCR 

Passive+NOx 

Control 

1980 310 0 Rubber Tired Dozer Recat-ESW 

DC-100 Active+FBC 

1984 330 0 Scraper Recat-ESW 

DC-101 Active+FBC 

2003 150 2 Crawler Tractor Sud Chemie 

ENVICAT Passive 

1993 275 0 Rubber Tire Loader CATEUG/DPF 

Passive+NOx 

Control 

2004 247 2 Excavator Mann-Hummel 

FBC Passive+FBC 

2002 116 1 Rough Terrain Forklift Nett TechActive SCR 

Active+NOx 

Control 

2005 371 2 Excavator CAT-DPF Passive 

2006 469 3 Articulated Truck CAT-DPF Passive 

2005 433 2 Excavator CAT-DPF Passive 

1990 525 0 Crawler Tractor Extengine 

ADECII 

Active+NOx 

Control 

1984 315 0 Rubber Tired Dozer Extengine 

ADECII 

Active+NOx 

Control 

1988 550 0 Waterpull Extengine 

ADECII 

Active+NOx 

Control 

2006 187 3 Rubber Tire Loader CAT - DPF Passive 

1985 45 0 Off-Highway Tractors Dinex-Dipex Passive 

2004 75 2 Tractor/Loader/Backhoe Donaldson 

Passive DPF Passive 

1985 45 0 Off-Highway Tractors ECS Purifilter Passive 

1985 188 0 Scraper ECS Purifilter Passive 

2006 73 2 Rubber Tire Loader ECS Purifilter Passive

2003 17 1 Tractor/Loader/Backhoe

s 

Huss FS-MD Active 

2006 24 2 Tractor/Loader/Backhoe Huss FS-MD Active 

1987 45 0 Off-Highway Tractors Huss FS-MD Active 

2000 62 1 Rubber Tire Loader Huss FS-MD Active 

2006 95 2 Tractor/Loader/Backhoe Huss FS-MD Active 

1985 188 0 Scraper Mann-Hummel 

FBC Passive+FBC 

1975 125 0 Off-Highway Tractors Mann-Hummel 

SMF-AR 

Active+FBC+ 

Electric 

1987 153 0 Off-Highway Tractors Sud Chemie 

ENVICAT Passive 
67

Year HP Tier Vehicle Type Installed 

Device 

Type of 

Device 

1993 134 0 Rubber Tire Loader Sud Chemie 

ENVICAT Passive 

1996 166 0 Rubber Tire Loader Sud Chemie 

ENVICAT Passive 

1996 166 0 Rubber Tire Loader Sud Chemie 

ENVICAT Passive 

Table 3: Private and Public Fleets in Showcase 

Private Fleet Public Fleet 

Community Recycling & Resource 

Recovery Inc. 

CALTRANS Division of Equipment 

(Invited) 

Albert W. Davies, Inc. City of Burbank Public Works Department 

Recycled Materials Company of CA City of Los Angeles, General Services 

Department 

Dan Copp Crushing County Sanitation Districts of L.A. County 

ECCO Equipment Corp. City of Culver City Transportation 

Department 

Griffith Company 

PEED Equipment Company 

Altfillisch Contractors, Inc. 

Reed Thomas Company, Inc. 

Shimmick Construction Co. 

Skanska USA Civil West California District 

Inc. 

Tiger 4 Equipment Leasing 

Sukut Equipment Inc 

Table 4: List of Manufacturers Participating in Showcase 

Participating Manufacturers

Aaqius Huss 

Caterpillar Johnson Matthey 

CDT Mann-Hummel 

DCL Nett Tech 

Dinex Purem 

Donaldson Recat-ESW/ETI 

ECS Rypos 

Extengine Sud Chemie 
68

Figure 1: Example of Data Logging Results (Vehicle # W93518, City of Los 

Angeles) 

Figure 2: Example of Data Logging Results (Vehicle # W93518, City of Los 

Angeles)
69

Table 5: SEP I Retrofits Installed 

Year HP Tier Vehicle Type Installed Device 

Passive/ 

Active/NOx 

Control 

2000 315 1 Wheel Loader Extengine ADECII Active/ Nox 

1999 230 1 Excavator Rypos HDP Active 

550 2-Engine 

2003

400

2 

Scraper 

DCL Mine X Passive 

1998 105 1 Wheel Loader Nett Tech Passive/ Nox

2007 125 3 John Deere ECS Assisted Active 

2007 125 3 John Deere ECS Assisted Active 

2000 185 1 Motorgrader Recat- ESW DC Active 

2006 125 2 Tractor Sud Chemie Passive 

2006 125 2 Tractor Recat ESW Active 

2000 89 1 Wheel Loader Mann Hummel Active 

1999 80 1 Wheel Loader Mann Hummel Active 

1995 105 0 Wheel Loader Huss FS-MD Active 

2007 125 3 John Deere Tractor Sud Chemie Passive 

2007 125 3 John Deere Tractor Sud Chemie Passive 
70

Table 6: SEP II Retrofits 

Year HP Tier Vehicle Type Installed or 

Proposed Device 

Passive/ 

Active/NOx 

Control 

2000 86 1 Backhoe Mann Hummel 

SMF-AR Active 

2007 150 3 Tractor Huss FS-MC Passive 

2007 150 3 Tractor ECS Purifilter Passive 

2005 224 2 Wheel Loader CAT – DPF Passive 

2007 150 3 Tractor Tehag Passive 

2002 180 0 Wheel Loader Econix DPF-A Active 

2000 108 1 Wheel Loader CDT Platinum Plus 

Purifilter (Proposed) Passive 

2004 95 2 Wheel Loader CAT – DPF Passive 

2002 439 2 Excavator CAT – DPF 

(Proposed) Passive 

2005 142 2 Fork Lift Truck Nett Tech Active 

DPF (Proposed) Active 

1999 185 1 Side Handler 6 

High 

Extengine MaxTrap 

(Proposed) Active/Nox 

Table 7: SEP III Retrofits Proposed to be Installed

Year HP Tier Vehicle Type Proposed 

Device 

Passive/ 

Active/NOx 

Control 

2006 80 2 Broom CDT Passive 

2004 119 2 Wheel Loader CDT Passive 

1999 240 1 Excavator CAT Passive 

2005 55 2 Tractor ECS Passive 

2005 81 2 Mower ECS Passive 

2004 82 2 Mower Mann Hummel Passive 

2001 95 1 Backhoe Mann Hummel Active 

2006 75 2 Tractor Loader HUSS Active 

1998 75 1 Wheel Loader Nett Tech Active 

1997 1 Motor Grader Nett Tech Active 

1999 225 1 Motor Grader DCL Passive 

2004 113 2 Mower HUSS Active 
71

Table 8: Fleets in Participating in SEP 

SEP Fleet 

LA County Sanitation District 

LA County Dept of Beaches and 

Harbors SEP I 

City of Burbank Dept of Public Works 

City of Long Beach 

SEP II City of Los Angeles 

Fast Lane (private company) 

City of Benicia 

Alameda County 

Contra Costa County SEP III 

Solano County 

Table 9: Manufacturers Participating in SEP 

Participating Manufacturers 

Caterpillar Mann-Hummel 

CDT Nett Tech 

DCL Recat 

ECS Rypos 

Econix Sud Chemie 

Extengine Tehag 

HUSS 
72

Table 10: Number of Vehicles in Showcase and SEP by Vehicle Type and 

Horsepower 

Vehicle Type <175 HP 175<HP>500 >500 HP 

Bore/Drill Rigs 0 0 0 

Cranes 0 0 0 

Crawler Tractor 3 12 1 

Excavator 6 19 1 

Graders 2 7 0 

Off-Highway Tractor 35 1 0 

Off-Highway Truck 1 2 0 

Other Mobile Off-road 5 1 1 

Paver 2 0 0 

Roller 0 0 0 

Rough Terrain Forklift 7 0 0 

Rubber Tired Dozer 0 6 1 

Rubber Tired Loader 31 25 0 

Scraper 0 16 8 

Skid Steer Loader 0 0 0 

Tractor/Loader/Backhoe 42 5 0 

Trencher 0 0 0 
73

APPENDIX D: OUTREACH SUMMARY 

Table 1: ARB Training Sessions 

Date Location # of people in attendance 

7/31/2008 San Luis Obispo, CA 92 

8/5/2008 Bakersfield, CA 77 

8/7/2008 Redding, CA 77 

8/11/2008 Nevada City, CA 65 

8/14/2008 Fresno, CA 81 

8/19/2008 Riverside, CA 142 

8/20/2008 San Diego, CA 123 

8/27/2008 El Monte, CA 142 

8/29/2008 Sacramento, CA 190 

9/3/2008 San Jose, CA 83 

9/9/2008 Ventura, CA 75 

9/12/2008 Oakland, CA 126 

11/19/08 South Lake Tahoe, CA 27 

Table 2: Presentations to Groups 

Date Meeting/Group City # of people in 

attendance 

10/16-17/2007 Clean Vehicle Expo Ontario, CA 50 

11/1/2007 

San Luis Obispo 

County Builders 

Exchange 

San Luis Obisbo, 

CA 50 

11/7/2007 

National 

Association of 

Demolition 

Contractors 

Anaheim, CA 70 

12/6/2007 

CalCIMA 

(represents 

Construction 

Aggregate and 

Industrial Mineral 

producers 

statewide) 

Sacramento, CA 50 

12/13/2007 

Municipal 

Employees 

Maintenance 

Association 

(MEMA) 

Irvine, CA 20 

2/21/2008 

Presentation for 

Quinn Company 

customers 

Santa Maria, CA 40 
74

Date Meeting/Group City # of people in 

attendance 

5/22/2008 

Solid Waste 

Association of 

North America 

(SWANA) 

Seaside, CA 25 

6/25/2008 

The Air and Waste 

Management 

Association 

(AWMA) Annual 

Conference and 

Exhibition 

Portland, OR 12 

8/21/2008 

Building Industry 

Association of 

Central California 

Modesto, CA 20 

8/27/2008 

Maintenance 

Superintendents 

Association 

Rohnert Park, CA 40 

9/10/2008 

TEC Equipment & 

AGC (American 

General 

Contractors) Event 

Oakland, CA 40 

10/3/2008 Tractoberfest Newark, CA 150 

10/13/2008 South Coast AQMD 

Clean Vehicle Expo Ontario, CA 13 

10/14/2008 

CMCA (Concrete 

Modification 

Contractor's 

Assoc.) 

Livermore, CA 15 

10/21/2008 

Industrial 

Environmental 

Association 

San Diego, CA 75 

10/23/2008 DGS fleet asset 

mgmt unit Sacramento, CA 25 

11/10/2008 

CA Golf Course 

Superintendents 

Assoc 

Cabazon, CA 150 
75

Table 3: Meetings with Individual Fleets or Stakeholders 

Date Meeting/Group City 

11/27/2007 

ARB Implementation 

Seminar/training for 

Sequoia equipment 

company (CASE dealer) 

Fresno, CA 

12/10/2007 Municipal Fleet of Yolo 

County Woodland, CA 

12/13/2007 Cattrac Fontana, CA 

1/4/2007 Iron Man Corona, CA 

1/7/2007 CASE Tractor Equipment 

Sales Hayward, CA 

3/26-28/2008 Quinn company City of Industry, CA 

3/27/2008 Stevens Creek Quarry, 

Inc. Sacramento, CA 

4/7/2008 

Monterey Regional 

Waste Management 

District 

Sacramento, CA 

4/9/2008 CASE Tractor Equipment 

Sales Hayward, CA 

4/10/2008 Mountain Cascade Inc Livermore, CA 

4/16/2008 Tutor Saliba Corp. Sacramento, CA 

4/21/2008 C & C Construction Sacramento, CA 

5/6/2008 Pape Machinery (John 

Deere) Sacramento, CA 

5/14/2008 Neff Rentals Sacramento, CA 

5/21/2008 Nissan Sacramento, CA 

5/28/2008 Pape Materials Handling 

Group Sacramento, CA 

5/29/2008 Western Power and 

Equipment Sacramento, CA 

6/12/2008 CAT dealership San Diego, CA 

6/17/2008 Johnson-Lift/HYSTER 

dealership City of Industry, CA 

6/20/2008 

NAACO Materials 

Handling Group (Yale 

division) 

Sacramento, CA 

6/20/2008 

NAACO Materials 

Handling Group 

(HYSTER division 

Sacramento, CA 

7/8/2008 Sugar Bowl Sacramento, CA 

7/22/2008 Diamond D Engineering 

and Associates Sacramento, CA 

8/28/2008 Tahoe Truckee Sierra 

Disposal Sacramento, CA 

9/10/2008 Rush Enterprises Fontana, CA 
76

Date Meeting/Group City 

10/10/2008 Western Stabilization Sacramento, CA 

10/27/2008 Appian Engineering Milpitas, CA 

11/5/2008 PAR Electrical 

Contractors Sacramento, CA 

Table 4: Attendance at Conferences and Workshops 

Date Meeting/Group Location 

10/16-17/2007 Clean Vehicle Expo Ontario, CA 

9/17/2008 Public Works Event - 

AGC Emeryville, CA 

9/25-26/2008 

League of California 

Cities 2008 Annual 

Conference & Expo 

Long Beach, CA 

10/3/2008 Tractoberfest Newark, CA 

10/13/2008 South Coast AQMD 

Clean Vehicle Expo Ontario CA 

10/21-22/2008 Industrial Environmental 

Association San Diego, CA 

10/23/2008 DGS fleet asset mgmt 

unit Sacramento, CA 

10/29/2008 

AGC Southern California 

Construction Technology 

Event 

San Diego, CA 

11/13-11/14/2008 

Far West Equipment 

Dealers Association 

Annual Conference 

Phoenix, AZ 
77

APPENDIX E: DOORS ON-LINE USER-GUIDES 

The Diesel Off-road On-line Reporting System (DOORS) is available for fleets which 

choose to report early. Staff have been assisting fleet representatives personally, and 

have also created a number of user guides and explanations of the reporting 

information required by the regulation. These guides are available from the reporting 

homepage (https://secure.arb.ca.gov/ssldoors/doors_reporting/reporting.php) and are 

listed below in Table 1. 

Table 1: DOORS User Guides 

General DOORS Guides 

Reporting Using Online Screens 

Reporting Using Excel Spreadsheets 

How to Report with Missing Information 

How to Report Duplicate Serial Numbers 

Reporting Multiple Fleets or Subfleets 

Importing Data to Excel Spreadsheets 

Definitions and Explanations 

Owner Information 

Vehicle Information 

Engine Information 

VDECS Information 

The “Reporting Using Online Screens” guide is presented on the following pages as an 

example of the method and format used in the DOORS guides. 
78

 

Online Forms for Initial Reporting 

Introduction 

The Diesel Off-Road On-Line Reporting System (DOORS) is an online tool 

designed to help fleet owners report their off-road diesel vehicle inventories and 

actions taken to reduce vehicle emissions to the Air Resources Board (ARB), as 

required by the In-Use Off-Road Diesel Regulation. 

Both the DOORS reporting tool and the DOORS User manual were created to help 

fleet owners comply with the regulation, but they are not a substitute for reading 

and comprehending the regulation. Many portions of the DOORS system will 

require fleet owners to understand terms and conditions defined in regulation, and 

to know which portions of the regulations apply to their vehicles, and where they 

are eligible for full or partial exemptions. It is strongly recommended that, prior to 

using the DOORS system, fleet owners determine how the regulation applies to 

their fleets. 

The regulation, fact sheets, additional user guides, and compliance examples can 

be found at: 

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

User Guide – Online Forms for Initial Reporting 

This guide was created to assist fleet owners using Online Screens to report fleet 

information during the initial reporting period. The guide contains instructions on 

how to create an online account with ARB in DOORS, navigate to the online 

screens, enter the data, receive a review from ARB and receive Equipment 

Identification Numbers (EINs). 

Steps to Report Fleet Data Using Online Forms

This guide provides detailed instructions on how to complete the following steps to 

report you fleet using our online forms: 

A. Create a DOORS account with ARB 

B. Determine applicable vehicles 

C. Log in to DOORS, and open the online forms 

D. Complete the owner information form 

E. Enter the vehicle information 

F. Enter the engine information, and if necessary, the VDECS information 

G. Review the data, and make changes if necessary 

H. Request a review from ARB and receive EINs 

Initial Reporting DOORS User Guide (Revised September 5, 2008) 
79

A. Create a DOORS Account with ARB 

• Go to https://secure.arb.ca.gov/ssldoors/doors_reporting/reporting.php 

• Request an account 

If you do not have an account, you will be asked to create one, and the 

account information will be sent to an email address you supply within a few 

minutes. If you do not see the email, check your “Spam” or “Trash” folders to 

ensure the email was not blocked by your email server. If you do not receive 

your email within 15 minutes, re-apply for one on the DOORS homepage. If 

this does not work, contact ARB for assistance by emailing 

doors@arb.ca.gov. 

B. Determine applicable vehicles 

Prior to reporting vehicle information to ARB, fleet owners will need to 

determine which of their off-road diesel vehicles are covered by the 

regulation. Some vehicles will likely be fully subject to the regulation, 

however some vehicles will be exempt from all requirements except 

labeling and reporting, and some will be fully exempt from the 

regulation. 

• Create a complete list of vehicles subject to the regulation, including those 

which are only required to be reported and labeled 

Early Credit: If you wish to claim early credit, report each vehicle that 

was included in the fleet from March 1, 2006, to the present, including 

vehicles you have retired or sold. You will be able to designate which 

vehicles you have retired or replaced to receive credit in the on-line 

screens after future updates. 

Non-diesel or electric: You will be able to report vehicles using 

alternative fuels or electric vehicles that have replaced diesel vehicles 

in your fleet in the on-line screens after updates, for now please 

include information on the diesel vehicle that was replaced. 

C. Log in to DOORS, open the online forms 

• Return to the DOORS login screen, and log in to the system using the login 

name and password emailed to you 

Do not hit “Enter”; you must click on the Login button directly. If 

DOORS does not accept your password, copy the password from the 

email, and paste it into the DOORS login screen. 

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• Once you have logged in to DOORS, go the first dropdown, and select 

“enter a fleet”. In the second dropdown, select “Enter Fleet Data On-Line” 

and then click on the [Take Action] button to the right. 

D. Complete the owner Information form 

• The first screen you will be taken to is the Owner 

Information screen. Complete this form, and then select 

[Enter Data]. 

If you have questions about what information is requested, please refer to our 

explanation for each spreadsheet, available on the reporting page 

https://secure.arb.ca.gov/ssldoors/doors_reporting/reporting.php under the User 

Guide menus. For the Owner information, select “Owner Information Dictionary”. 

• If DOORS rejects any of your information, it will supply an error message and 

reason at the top of the screen. Attempt to fix the cause of the error, and 

resubmit the data. 

E. Enter vehicle information 

• Once your owner information has been successfully entered, select the option 

to [Add / Edit Vehicle] at the top or the bottom of the screen. 

• This will take you to the screen where you may add, delete or edit vehicle 

information. 

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• Enter the vehicle information required, then select [Enter Data] 

If you have questions about what information is requested, please refer to our 

explanation for each spreadsheet, available on the reporting page 

https://secure.arb.ca.gov/ssldoors/doors_reporting/reporting.php

under the Explanation of Terms. 

For missing or partial information, refer to the attachment on the last page of the 

guide. 

• After the information on the previous vehicle is entered into a table, continue to 

use the form to add additional vehicles until your entire inventory is reported. 

For each successive vehicle, enter the vehicle information required, then 

select [Enter Data] 

F. Enter engine information, and if necessary, VDECS information 

• After entering information on all of the vehicles you wish to report, select the 

option to [Add / Edit Engine] at the top or the bottom of the screen. 

• For each vehicle you have entered, select “Edit” at the left side of the screen, 

and input the engine information. Then select [Enter Data]. You will only be 

able to add engine information to vehicles you have already added, and you 

will only be able to add VDECS information if you have already entered the 

engine information. 

• Complete the same steps to enter VDECS information, if you have any VDECS 

installed on your vehicles. 

G. Review the data, and make changes if necessary 

Before continuing, it is recommended that you review the data you have 

entered. On the Reporting Home page (the first page in DOORS), the 

following options are available for fleets you have entered into the system: 

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• Select the fleet you have entered and wish to review 

• Select “View Owner” and click on “Take Action”. DOORS will display the fleet 

owner information you have uploaded. Ensure the data shown is correct, and 

then return to the Reporting Home page. 

• If it is not correct, return to the reporting homepage, select the fleet, and 

the choose “Enter Fleet Data On-line”. You will be able to edit, delete, 

and add owner, vehicle, engine, and vdecs information. 

• Select “View Fleet” and click on “Take Action”. DOORS will display the vehicle, 

engine, and VDECS information you have uploaded. Ensure the data shown is 

correct, and then return to the Reporting Home page. 

• If it is not correct, return to the reporting homepage, select the fleet, and 

the choose “Enter Fleet Data On-line”. 

H. Request a review from ARB and receive EINs 

 The information you have entered so far will be saved, and you can 

access it again and make changes at a later time before submitting it to 

ARB for review. After ARB reviews the information you will be able to edit 

and add to your vehicle inventory, and will receive your ARB-designated 

Equipment Identification Numbers, which must be displayed on your 

vehicles. The information will not be reviewed by ARB staff, or assigned 

EINs, until you choose to submit it to ARB for review. To access the fleet 

information you have entered at a later date, log back in to the DOORS 

system. 

Where you previously selected “Enter a fleet”, the fleet (or fleets) you have 

entered will now be available. 

To edit a fleet, select it, and then choose 

“Upload Fleet Data” and the press the 

“Take Action” button. You may resubmit 

the appropriate .prn files and view your 

updated information. 

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Once you are satisfied with the information and are prepared to send it to 

ARB for review and receive EIN assignments for your vehicles, return to 

the Reporting Home page in the DOORS system. 

• Select the Fleet you wish to submit to ARB 

 in the drop down menu 

• Select “Request Review” from the drop down 

menu below, and click on “Take Action” 

 After the fleet information has been approved by ARB, the fleet will be 

available for further review and modification, using the following menu on 

the bottom of the Reporting Home page of the DOORS system after you 

log in. Not all features will be available when DOORS first comes online 

in July, 2008. 

For more information on reporting with missing or partial information, or 

how to report multiple fleets or subfleets, refer to our guides, which are 

available from our reporting homepage at: 

https://secure.arb.ca.gov/ssldoors/doors_reporting/reporting.php

If you require additional assistance or information, please email us at: 

doors@arb.ca.gov

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APPENDIX F: LIST OF ACRONYMS 

ARB --- Air Resources Board 

BACT --- Best Available Control Technology 

BOE --- California Board of Equalization 

CAA --- Clean Air Act 

Cal/OSHA --- California Occupational Safety and Health Administration 

CCR --- California Code of Regulations 

CSLB --- Contractors State License Board 

DECS --- Diesel Emission Control Strategies 

DOCs --- Diesel Oxidation Catalysts 

DOF --- Department of Finance 

DOORS --- Diesel Off-Road On-Line Reporting System 

DMV --- Department of Motor Vehicles 

DPF --- Diesel Particulate Filter 

EIN --- Equipment Identification Number 

EGR --- Exhaust Gas Recirculation 

G/BHP-HR --- Grams per Brake-Horsepower Hour 

HP --- Horsepower 

MSHA --- Mining Safety and Health Administration 

MSRC --- Mobile Source Air Pollution Reduction Review Committee 

NOX --- Oxides of Nitrogen 

ORIAG --- Off-Road Implementation Advisory Group 

PM --- Particulate Matter 

SCAQMD --- South Coast Air Quality Management District 

SEP --- Supplemental Environmental Project 

SJVAPCD --- San Joaquin Valley Air Pollution Control District 

SOON --- Surplus Off-Road Opt-In for NOx 

TSD --- Technical Support Document 

U.S. EPA --- United States Environmental Protection Agency 

VDECS --- Verified Diesel Emission Control System