Public Hearing to ConsiderProposed Amendments toTransport Refrigeration Unit (TRU)Airborne Toxic Control Measure (ATCM)Sacramento, CaliforniaOctober 21, 20112Overview•Background•Emissions Inventory Update•Proposed Amendments•Economic Impacts•Emissions Impacts•Health Impacts•Recommendation23Background•Diesel PM identified as TAC in 1998•TRU’s congregate in large numbers atdistribution centers–Very high near-source risk (> 100/million common)•TRU ATCM adopted 2004•U.S. EPA approved waiverJanuary 16, 2009•2010 Amendments–Board direction34TRU Applications•What is a TRU?–Refrigeration systems powered by integral dieselengines–Used to control the environment of temperaturesensitive products that are transported in trucks,semi-trailers, railcars, and shipping containers45Primary Requirementsof Current Regulation•Web-based registration–Voluntary for TRUs based outside California•Submit Operator Reports–California terminals where TRUs are assigned•Meet in-use performance standards–Affects all TRUs that operate in California–Phased compliance schedule based on 7-yearoperational life56In-UsePerformance Standards•Two levels of stringency–Low-Emission TRU (LETRU)•>50 percent PM emission reduction–Ultra-Low-Emission TRU (ULETRU)•>85 percent PM emission reduction•Compliance options available now–Repower - engine replacement–Retrofit with verified diesel particulate filter–Use alternative technology - hybrid electric–Available now for model year 200467In-Use Performance StandardCompliance Schedule•Engine model year (MY) 2003 and older–Step 1: Meet LETRU when 7 years old–Step 2: Meet ULETRU when 14 years old•Engine MY 2004 and newer–Skip LETRU–Meet ULETRU when 7 years old78Implementation Status•Outreach training, compliance assistance•Stakeholder issue meetings•Regulatory advisories•Compliance technology development andverification•Technology forums•Web-based TRU registration system•Toll-free helpline89Implementation Status(Cont.)•Enforcement–Registration and in-use requirements–Inspections at:•Border crossings • Distribution centers•Scales • Ag inspection stations•Ports • Carrier terminals•Intermodal facilities910Implementation Status(Cont.)•Compliance Assistance–Letters to owners registered in ARBER–Emails to TRU List Serve–Developing a List of “100% Compliant Fleets”10112010 Amendments•Board approved three amendments needed bythe end of 2010–Added compliance options for MY 2003 engines–Addressed flexibility engines–Enhanced OEM Reporting•Board directed staff to:–Evaluate request for longer operational life•Emissions inventory update•Cost of compliance – economic impacts update•Health risk assessment update1112Evaluate Longer Operational LifeMY 2004 and Newer Engines•Impact of extending operational life to 8, 9, or 10years–Public health risk at existing 7 years is too high–Potential public health impacts from delay•Increasing operational life to 8-10 years erodes cancer riskreductions by about 10-40 percent•Staff recommends maintaining existing 7-yearoperational lifetime requirement1213Evaluate Longer Operational LifeHealth Riskat TRU Facilities•Estimated off-site potential cancer risk from a“typical” facility with current 7-year operational life:•Activity at “large” distribution centers is higher–Average is about 2,000 hours per week–Highest reported: >8,000 hours per week13Activity(Engine Hours Per Week)Loads Per Week Near-SourceCancer Health Risks100 40 >10 per million1000 400 >100 per million14Evaluate Longer Operational LifeHealth Riskat TRU Facilities (Cont.)•At least 500 facilities with a potential cancerrisk above 10/million•At least 50% of these located near residences,off-site workplaces, and sensitive receptors1415TRU Emission Inventory Update•New input data collected since 2003 andapplied to current inventory includes:Input Data SourceIn-state population 2011 ARBERDaily out-of-state population 2010 Truck and Bus RuleEngine load factors Manufacturer input, engine performance dataAnnual engine activity, overall 2006 Facility Survey, 2010 Truck and BusRuleAnnual engine activity, in-state 2006 Facility SurveyEmission Factors Tier 4 final StandardsGrowth Rate 1990-2010 national engine sales16TRU Emission Inventory Update(Cont.)Input 2011 Compared to 2003In-state population 20 percent lowerDaily out-of-state population 10 percent lowerEngine load factors 13 percent lowerAnnual engine activity, overall 15 percent higher, per unitAnnual engine activity, in-state 8 percent lowerEmission Factors Future emission factors lower to reflectstandardGrowth Rate 50 percent lower17TRU Emission Inventory UpdateStatewide PM Emissions18TRU Emission Inventory UpdateStatewide PM Emissions19Economic Impacts UpdateActual Compared to 2003 Staff Report•Actual capital costs increased•Operating and maintenance costs refined•Compliance methods actually used–VDECS retrofits (20%)–Engine repowers (70%)–Unit replacements (10%)–Alternative Technologies (< 1%)•Cost-Effectiveness changed–$83 per pound PM(originally estimated $10 to $20 perpound)1920Proposed Amendments•Extension of ULETRU compliance date forsome MY 2003 and older engines•Provide flexibility•Improve enforceability•Improve compliance rates•Clarify existing requirements2021Proposed AmendmentsExtension for MY 2003 and Older Engines•Model year 2003 and older, if met LETRU–Extend ULETRU compliance date 1 year–MY 2001 and older, if met LETRU by 12-31-08,results in 2 year ULETRU extension•Extends operational life•Restores competitive fairness for emissionreduction actions taken•Negligible emissions and risk impacts2122Proposed AmendmentsAdministrative Extensions•Up to one-year extension if complyingtechnology is not available–Application required before deadline–Demonstrates no suitable filter or engine available•Up to four-month extension if delivery orinstallation are delayed•Case-by-case consideration2223Proposed AmendmentsProvide Flexibility•Use of unit manufacture year instead ofengine model year - extends operational life•Use of unique equipment identificationnumbers instead of ARB’s•Exemptions–Obviously nonoperational equipment–Non-diesel-powered refrigeration systems–TRUs used during certain emergencies2324Proposed AmendmentsImprove Enforceability•Clarify recordkeeping requirements for hybridelectric TRUs–TRU engine operation eliminated at nonretail facilities(distribution centers)–Electric power plugs must be available–TRU engine operation limited to less than 30 minutes at retaildelivery points•Automated electronic tracking and reportingphased in, starting 2013–Small initial capital cost–Significant labor savings – expected payback less than 1 year2425Proposed AmendmentsImprove Compliance Rates•Hired or contracted carriers must dispatchcompliant TRUs–Brokers, shippers, and receivers must demonstratedue diligence–Contract with carrier must specify use of ARB-compliant equipment•Minimizes unfair competition created bynoncompliant equipment2526Proposed AmendmentsImprove Compliance Rates (Cont.)•TRU manufacturers and engine rebuilders–Provide registration information documents andsupplemental engine labels•Dealers and repair shops–Pass registration information documents to nextparty in chain (ultimately to the end-user)•TRU manufacturers that use flexibility engines–Notify ARB–Provide supplemental labels and written disclosure2627Proposed AmendmentsClarifications•Repowering with a new replacement or a rebuiltengine–Effective model year determines when it must meetthe in-use standards•Noncompliant equipment–Flexibility for dealers to possess, sell, and movenoncompliant units–Seller must disclose noncompliant status to buyer•Requirements for lessors and lessees•Engine rebuilders–Rebuild to a cleaner configuration2728Economic Impacts2011 AmendmentsProposed AmendmentStatewide RegulatoryCost or (Savings)ULETRU Extension for < MY 2003 Timely LETRUCompliance($350,000)Electronic Recordkeeping for Hybrid Electric/ElectricStandby($3.9 million)Compliance Verification for Responsible Parties $11millionExemption of TRUs Used During Emergencies ($340,000)Use of TRU Manufacture Year($21 million)Supplemental Labels and Registration Information $1.6 millionNet Total Cost or (Savings) ($13 million)29Emissions ImpactsProposed Amendments30Health ImpactsProposed Amendments•Small annual reductions deferred severalyears–Combined emissions impacts for all proposedamendments totals 0.21 tpd (2009 to 2018)•Emission reductions continue•Public health risk reductions at distributioncenters continues3031Compliance Options•Several options for complying with standards•Engine or unit replacement–Chosen for 80% of units, readily available•Retrofits–Chosen for 20% of units–Availability of Level 3 retrofit (>25 hp MY 2004)•One fully verified Level 3 retrofit available now•2ndexpected to be verified and available fall 2011–Amendments allow Executive Officer to extend compliancedeadline for availability, delivery, and installation delays3132Staff’s Suggested Modificationsto Proposed Amendments•OEMs provide disclosure document with unitsthat are equipped with a flexibility engine•Dealers notify the end-user that unit is equippedwith a flexibility engine and provide the OEM’swritten disclosure•Provide OEM the flexibility to developalternatives to providing registrationinformation documents with each unit3233Recommendation•Adopt the proposed amendments•Direct staff to:–Continue outreach efforts–Continue working with brokers, shippers, andreceivers on compliance assistance tools–Administratively implement the Executive Officerextension authority for MY 2004, if necessary–Continue to work with electronic trackingsystem suppliers–Evaluate alternatives to enableTRUs rated at less than 25 hpto comply with ULETRU