CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY 

AIR RESOURCES BOARD 

STAFF REPORT: NEW EMISSION STANDARDS, FLEET REQUIREMENTS, AND 

TEST PROCEDURES FOR FORKLIFTS AND OTHER INDUSTRIAL EQUIPMENT 

This report has been reviewed by the staff of the California Air Resources Board and 

approved for publication. Approval does not signify that the contents necessarily reflect 

the views and policies of the Air Resources Board, nor does the mention of trade names 

or commercial products constitute endorsement or recommendation for use. 

 Date of Release: March 3, 2006 

 Scheduled for Consideration: April 20, 2006
 i

EXECUTIVE SUMMARY 

Air quality in California has improved dramatically over the past 30 years, due in large 

part to the continued progress in controlling pollution from mobile sources. Despite the 

achievements to date, the vast majority of Californians live in areas of the state that still 

do not meet State or federal health-based ambient air quality standards. Clearly, ozone 

– or smog – continues to be a serious health problem throughout much of our state. 

The California Air Resources Board (ARB or Board) pursues emissions reductions from 

all feasible sources in order to continue our progress toward clean air and to meet and 

sustain our air quality goals. 

In 1998, the ARB first adopted emission standards for new spark-ignited engines used 

in propane forklifts and other similar industrial equipment. These engines are referred 

to as large spark-ignition (LSI) engines. In addition to forklifts, the LSI category includes 

airport ground support equipment (GSE), sweepers and scrubbers, generator sets, 

small irrigation pumps, and a variety of other similar equipment. The full implementation 

of these first emissions standards in 2004 required engine manufacturers to achieve 

approximately a 75 percent reduction in smog-forming pollutants. This was done with 

the incorporation of basic emissions control technology that had been successfully used 

in passenger cars for more than 20 years. 

The 75 percent reduction was an important step, but still left the level of control for 

these new engines relatively basic. Building on this success, the United States 

Environmental Protection Agency (U.S. EPA) harmonized with California’s standards 

and adopted more stringent requirements for new engines produced for the 2007 and 

later model years. The federal program demonstrated that additional reductions from 

new engines were technically feasible and cost-effective. 

In developing the ARB’s 2003 State Implementation Plan (SIP) for Ozone, it became 

clear that additional emissions reductions were possible from not only new LSI engines, 

but also in-use LSI equipment. The regulation of in-use LSI equipment represents an 

enormous opportunity since each uncontrolled forklift has the same emissions per day 

as over 700 clean passenger cars. Currently, there are over 30,000 uncontrolled 

forklifts in California. The Board-adopted SIP included a commitment to achieve 

additional reductions from the LSI category of between 6.1 and 13.0 tons per day of 

hydrocarbons (HC) and oxides of nitrogen (NOx) statewide by 2010. This proposal is 

designed to meet that 2003 obligation. 

In June 2005, the ARB presented an initial LSI proposal to the Board. At that time, 

questions arose about the economic impact of the in-use portion of the proposal on 

forklift dealers and agricultural-related businesses that could not be fully answered. In 

addition, several stakeholders asked for more time to work with staff on its regulatory 

proposal. Accordingly, the Board listened to staff’s presentation and to public testimony 

but deferred action to a later date. Subsequent to the June 2005 hearing, ARB staff has 

had numerous meetings and telephone conversations with dealer and agricultural 
 ii

business representatives in order to better understand their business practices and the 

economic impacts of the proposal. 

The current proposal is similar to the June 2005 proposal, but revises several key 

modifications based on these meetings and ARB staff’s subsequent analysis. The 

modifications are designed to reduce the economic impacts on agricultural businesses 

and address the unique business practices of forklift dealers. The main elements of this 

proposal are highlighted below, along with the key revisions to the previous proposal. 

In late 2002, air carriers operating in the South Coast air basin signed a memorandum 

or understanding (MOU) with ARB committing to reduce HC and NOx emissions from 

new and in-use GSE used in airport operations. The MOU was intended to address the 

air carriers’ contributions to the air basin’s extreme ozone nonattainment classification. 

The airlines terminated the MOU on October 28, 2005. To retain those benefits, staff is 

proposing that GSE fleets in the South Coast air basin meet the same fleet average 

emission requirements as other fleets, and meet the zero-emission requirement of the 

MOU applied to the LSI fleet.

Proposed Requirements 

Requirements for Engine Manufacturers

 Alignment with the engine certification standards adopted by the U.S. EPA 

beginning in 2007. 

 Alignment with additional requirements of the federal rule including more rigorous 

test procedures and on-board diagnostics. 

 More stringent emissions standards for 2010 and later model-year engines. 

 Optional lower-emission standards to give manufacturers more flexibility. 

Requirements for Fleet Users 

 Fleet average emission limits for operators of specific LSI equipment (forklifts, 

sweeper/scrubbers, industrial tow tractors, and airport ground support equipment) 

beginning in 2009. 

 An alternative compliance option for agricultural fleets to address issues specific to 

the agricultural industry. 

Verification Procedure for Manufacturers of Retrofit Control Systems

 A new procedure for verifying LSI retrofit emission control systems. 
 iii

Key Modifications to the June 2005 Proposal 

For Equipment Dealers

Small fleets (one to three units) are no longer covered by the proposal. This 

modification reduces the in-use emissions benefit of staff’s earlier proposal by less than 

20 percent (roughly one ton per day of HC+NOx in 2010) while exempting an estimated 

60 percent of fleets (the very smallest ones) from the fleet rules. This change not only 

eases the burden on small users, but also provides an ongoing purchaser pool for 

dealers that have uncontrolled equipment coming off existing leases. The primary 

concern with staff’s 2005 proposal was that it was believed to impose unreasonably 

high control costs on relatively low-value equipment coming off lease. The proposed 

exemption for small fleets solves that problem while still controlling the majority of in-use 

engines. 

For Agriculture

The alternative agricultural proposal would require control of only those owned forklifts 

for which a verified retrofit system is commercially available (40 percent of current 

agricultural forklifts). In addition, the timeframe for compliance provides an opportunity 

for 80 percent of this equipment to be eligible for Carl Moyer Program incentive funds if 

the owners act quickly to install retrofits. The proposal would allow those forklifts for 

which retrofit systems are not available to continue to operate, avoiding the cost of 

replacement. With full use of incentive funds, the modification reduces the cost by 

approximately 90 percent while retaining over one ton per day HC+NOx benefit during 

the summer ozone season. 

For Air Carriers

Special requirements applicable to commercial airlines operating airport GSE in the 

South Coast air basin that implement provisions of a recently terminated MOU. 

Economic and Environmental Impacts 

The proposed 2007 new engine emission standards are not expected to create 

significant economic impacts because engine manufacturers are already developing 

engines to comply with the federal 2007 standards. The proposed California standards 

for 2010 and later can be met by optimizing emission controls used to meet U.S. EPA’s 

2007 standards, and thus provide extremely cost effective emission reductions 

estimated at $0.13 per pound. 

In general, in-use fleet rules provide significant opportunities for emissions reductions 

but also require careful consideration due to their possible economic impacts on owners 

and users of the equipment. In many ways, the LSI category is well-positioned to 

achieve in-use emissions reductions. Available retrofit technology reduces emissions 

by 75 to 90 percent and is cost-effective. Because emission standards for new engines 
 iv

have been in effect only for the past few years, a significant number of high-emitting, 

uncontrolled equipment is still in operation and available for retrofit. Operators can 

meet the proposed in-use fleet-average emission standards by procuring low- and 

zero-emission equipment and by retrofitting uncontrolled equipment in their fleets. The 

use of new controlled engines and the retrofit of existing engines can reduce fuel use 

and improve engine life, creating cost savings that offset a portion of the additional 

equipment cost. As a result, the fleet requirements are cost-effective and range from 

$0.13 per pound for lower-emission equipment to $1.40 per pound for electric 

equipment. 

The proposed in-use fleet-average emission standards will result in additional costs for 

some dealers of LSI engines. The costs depend on the number and age of the 

uncontrolled equipment in their possession, the rate at which they currently turn-over 

old equipment, the extent to which additional costs can be passed along, and the ability 

to sell equipment to small fleets that are exempt from the proposed regulations. This 

latter provision significantly reduces the economic impact of the proposal on dealers. 

The ARB staff proposal will reduce statewide HC and NOx emissions by 5.7 tons per 

day in 2010 and 6.2 tons per day in 2020. These reductions are near or within the 

range of the commitment established within the 2003 SIP. 

Staff Recommendation 

The ARB staff recommends that the Board adopt the amendments as set forth in the 

proposed Regulation Order in Appendices A, B, and C and as described in this Initial 

Statement of Reasons. 
 

TABLE OF CONTENTS 

1 INTRODUCTION.................................................................................................. 1

1.1 Regulatory Authority .................................................................................. 1

1.2 Applicability................................................................................................ 2

1.3 Outreach.................................................................................................... 2

2 CURRENT REGULATIONS AND INVENTORY................................................... 3

2.1 California LSI Regulation ........................................................................... 3

2.2 Federal LSI Regulation .............................................................................. 3

2.3 2003 State Implementation Plan for Ozone ............................................... 4

2.4 Airport Ground Support Equipment Memorandum of Understanding ........ 4

2.5 LSI Inventory.............................................................................................. 5

3 REGULATORY PROPOSAL ................................................................................ 6

3.1 More Stringent Emission Standards for New Engines ............................... 6

3.2 In-Use Emission Standards ....................................................................... 8

3.3 Proposed Verification Procedures for Retrofits ........................................ 10

3.4 Alternative Compliance Option for Fleets used in Agricultural CropPreparation Services................................................................................ 11

4 TECHNOLOGY REVIEW ................................................................................... 12

4.1 Emission Control Strategies..................................................................... 12

4.2 Emission Controls for LSI Engines .......................................................... 13

4.3 Impact of Transient Testing ..................................................................... 13

4.4 Lead Time................................................................................................ 14

4.5 Fuel Quality.............................................................................................. 14

5 ENVIRONMENTAL IMPACTS............................................................................ 15

5.1 Air Quality Impacts................................................................................... 15

5.2 Other Impacts .......................................................................................... 17

6 ECONOMIC IMPACTS – COST AND COST-EFFECTIVENESS....................... 18

6.1 Incentive Programs.................................................................................. 18

6.2 Potential Impact on Manufacturers .......................................................... 19

6.3 Potential Impact on Distributors and Dealers........................................... 21

6.4 Potential Impact on Equipment Operators ............................................... 23

6.5 Potential Impact on Agriculture ................................................................ 25

6.6 Cost-Effectiveness................................................................................... 26

6.7 Potential Impact on Business Competitiveness, Employment, and 

Business Creation and Elimination .......................................................... 27

7 ALTERNATIVES AND RECOMMENDATION .................................................... 27

7.1 Alternatives Considered........................................................................... 27

7.2 Conclusion............................................................................................... 28

REFERENCES.............................................................................................................. 29

APPENDIX A: MANUFACTURER STANDARDS AND TEST PROCEDURES................ i

APPENDIX B: FLEET AVERAGE EMISSION LEVEL REQUIREMENTS........................ i

APPENDIX C: VERIFICATION PROCEDURE................................................................. i
1 

1 INTRODUCTION 

The California Clean Air Act, adopted in 1988, grants the Air Resources Board (ARB) 

the authority to regulate a wide variety of off-road mobile engines and equipment. 

These sources include, but are not limited to marine vessels, locomotives, utility 

engines, off-road motorcycles, and off-highway vehicles. Forklifts, and other off-road 

large spark-ignition (LSI) equipment, are a subcategory of off-road mobile equipment 

subject to ARB regulation. Approximately 88,000 pieces of LSI equipment exist in 

California, with current hydrocarbon (HC) and oxides of nitrogen (NOx) emissions of 

approximately 15 and 54 tons per day, respectively. 

In addition to forklifts, off-road LSI equipment includes portable generators, large turf 

care equipment, irrigation pumps, welders, air compressors, scrubber/sweepers, airport 

service vehicles, and a wide array of other agricultural, construction, and general 

industrial equipment. Forklifts comprise roughly half of the LSI inventory and contribute 

more than 85 percent of the category’s emissions. The basic engines used in off-road 

equipment are similar to, and typically derived from, automobile engines, although they 

have significantly fewer emissions controls. They are most commonly fueled by 

gasoline or liquefied petroleum gas (LPG). 

The ARB first adopted emission standards for off-road LSI equipment over 

25 horsepower (19 kilowatts) in 1998, with implementation beginning in the 2001 model 

year, and fully implemented in 2004. The proposed amendments in this rulemaking 

continue ARB’s efforts to achieve additional cost-effective reductions from the category. 

Requirements are proposed that would provide significant near- and mid-term 

reductions by addressing the remaining high-emitting uncontrolled equipment in-use. 

The proposal would also provide significant mid- and long-term reductions by 

establishing more stringent new engine HC and NOx emission standards in 2007 and 

2010. Finally, the proposal would allow engine manufacturers to certify to optional 

lower-emission standards, and provide retrofit equipment manufacturers a test 

procedure for certifying retrofit systems. 

In late 2002, the ARB signed a memorandum of understanding (MOU) with air carriers 

to reduce HC and NOx emissions from ground support equipment (GSE) in the South 

Coast air basin. The MOU included provisions for the early introduction of clean units, 

with a requirement for an average 2.65 grams per brake-horsepower hour HC+NOx 

fleet. The MOU also called for a specified percentage of zero-emission equipment and 

the use of diesel oxidation catalysts and diesel particulate filters to significantly reduce 

particulate matter emissions from the diesel portion of the fleet. 

1.1 Regulatory Authority 

As noted above, the ARB has been granted the authority to regulate emissions from offroad mobile sources. The authority, however, does not extend to new equipment under 

175 horsepower used primarily in construction or farm equipment or vehicles. The 

United States Environmental Protection Agency (U.S. EPA) has sole authority to control 
2 

emissions from this equipment, i.e., California is preempted from regulating this 

equipment. In the LSI category, the preempted equipment includes welders, air 

compressors, and irrigation pumps. Because of this preemption, some emissions from 

the subject engine category are beyond ARB's authority to regulate. However, the ARB 

staff works closely with the U.S. EPA in their development of federal rules to cover all 

engines in this category. It should be noted that the preemption does not prohibit the 

ARB from regulating a piece of equipment under 175 horsepower that is used in 

construction or farming; instead, it prohibits the ARB from regulating categories of 

equipment that are primarily used in construction and farming. The ARB has 

established a list of the types of equipment that are not primarily used in construction or 

farming. All equipment over 25 horsepower but less than 175 horsepower is considered 

to be construction or farm equipment except for the 11 categories listed below. 

 Airport Ground Power 

 Baggage Handling 

 Forklifts that are neither rough terrain nor powered by diesel engines 

 Generator Sets 

 Mining Equipment not otherwise primarily used in the construction industry 

 Off-highway Recreational Vehicles 

 Other Industrial Equipment 

 Refrigeration Units less than 50 hp 

 Scrubbers/Sweepers 

 Tow/Push Equipment 

 Turf Care Equipment 

1.2 Applicability 

The new engine emission standards discussed in Section 3 apply to engines greater 

than 19 kilowatts (25 horsepower) used in the 11 categories of equipment listed above. 

The in-use requirements apply only to users of forklifts, sweeper/scrubbers, industrial 

tow tractors and GSE. Examples of GSE include forklifts, tugs, belt loaders, bobtails, 

cargo loaders, lifts, air conditioners, service trucks, de-icers, fuel delivery trucks, and 

ground power units. 

Diesel equipment is not subject to the requirements of this proposal. Instead, separate 

requirements for in-use diesel forklifts are being developed and are expected to be 

proposed in late 2006. 

1.3 Outreach 

Outreach and public participation are important components of ARB’s regulatory 

development process. In preparing the proposed regulations, ARB staff developed an 

outreach program to engage LSI engine and equipment manufacturers and distributors, 

emission control system manufacturers, propane fuel refiners and distributors, end-user 

facility operators, agricultural interests, federal regulatory agencies, environmental 

organizations, public health advocates, and other interested parties. 
3 

Through these efforts, ARB staff has been able to obtain detailed information on the use 

of, and emissions from, LSI equipment. Additionally, these entities participated in the 

development and review of the manufacturers advisory correspondence (MAC) for 

voluntary early certification of lower-emission engines and the interim retrofit verification 

procedure for retrofit emission control systems. 

As part of the outreach efforts, ARB staff made extensive personal contacts with 

industry and facility representatives as well as other affected parties through meetings, 

telephone calls, and mail-outs. These activities included holding five public workshops, 

forming an LSI regulatory working group and holding 20 conference calls with the 

working group, more than 100 telephone conversations with the working group and 

facility operators, and visiting more than 15 facilities. 

In June 2005, ARB presented a similar LSI proposal to the Board. At that time, 

questions arose about the impact of the proposal on forklift dealers and agriculturerelated businesses that could not be fully answered and the Board took no action. In 

response, the ARB staff has conducted a series of meetings with both stakeholder 

groups, focusing on better understanding their business operations. This more detailed 

analysis has allowed staff to better understand the potential economic impacts to these 

two stakeholder groups. The current proposal is similar in structure to the previous 

proposal, but revises several key provisions in response to these discussions and 

analyses. 

2 CURRENT REGULATIONS AND INVENTORY 

2.1 California LSI Regulation 

In 1998, ARB adopted LSI regulations in collaboration with U.S. EPA. The regulations 

phased-in an emission standard for new engines of 3.0 grams per brake-horsepowerhour (g/bhp-hr) of HC and NOx beginning in 2001. 

2.2 Federal LSI Regulation 

Federal law preempts California from regulating engines less than 175 horsepower 

used primarily in farm and construction equipment. To address these engines, the ARB 

staff worked closely with U.S. EPA in its development of a nationwide federal rule to 

cover all new engines in this category. The federal rule, adopted in 2002, established 

nationwide emission standards for new LSI engines, including those used in farm and 

construction equipment. The U.S. EPA regulation requires that LSI engines nationwide 

meet the same 3.0 g/bhp-hr standard beginning in 2004 as required in California. The 

federal regulation also includes a more stringent standard: beginning in 2007, new LSI 

engines must meet a 2.0 g/bhp-hr standard using a more rigorous transient testing 

procedure. It additionally contains evaporative emission and in-use requirements that 

were not included in the 1998 California regulation. As a result of the State and federal 
4 

regulations, new LSI engines are now 75 percent cleaner than uncontrolled LSI engines 

and will become even cleaner beginning in 2007. 

2.3 2003 State Implementation Plan for Ozone 

LSI equipment accounted for approximately six percent of all off-road emissions in 2000 

and this percentage is increasing (ARB, 2003). There are large numbers of 

uncontrolled LSI engines still in use. These engines can emit 12 g/bhp-hr or more of 

HC+NOx, contributing significantly to the smog problems in California. To put this in 

perspective, one uncontrolled LSI engine can emit as much pollution in three 8-hour 

shifts as a passenger car certified to California’s cleanest standard emits during its 

entire life. Yet, LSI engines are generally based on automotive engine technology and 

can thus incorporate advanced automotive-inspired emission control technologies to 

dramatically reduce emissions while still meeting operational requirements. Finally, 

zero-emission forklifts are available to provide even greater emission benefits while in 

many cases reducing overall life-cycle costs. 

In recognition of these opportunities, the 2003 SIP included two measures for LSI 

engines. The first measure proposed that California harmonize with the 2007 U.S. EPA 

2.0 g/bhp-hr new engine emission standard. The second measure proposed that 

emissions from existing or in-use LSI engines be reduced by 80 percent or to a 3.0 

g/bhp-hr verification level. The proposed verification protocol provides a range of 

percentage reductions from 75 percent to more than 90 percent based on the state of 

technology. The latter measure also proposed that new standards be developed that 

reflected the availability of zero- and near-zero-emission technologies. 

2.4 Airport Ground Support Equipment Memorandum of Understanding 

In late 2002, air carriers operating in the South Coast air basin signed a MOU with ARB 

committing to reduce HC and NOx emissions from new and in-use GSE used in airport 

operations. The GSE performs a variety of functions, including: starting aircraft, aircraft 

maintenance, aircraft fueling, transporting cargo and passengers to and from aircraft, 

loading cargo, baggage handling, lavatory service, and food service. 

The GSE MOU was developed in cooperation with the Air Transport Association (ATA; 

representing the major South Coast air basin’s air carriers), the Federal Aviation 

Administration, U.S. EPA, and the South Coast Air Quality Management District. It was 

intended to address the air carriers’ contributions to the air basin’s extreme ozone 

nonattainment classification. The MOU included provisions for the early introduction of 

clean units, with requirements for a 2.65 grams per brake-horsepower hour HC+NOx 

fleet average at the five major airports in the South Coast air basin by December 31, 

2010, and the use of diesel oxidation catalysts and diesel particulate filters to 

significantly reduce particulate matter emissions from the diesel portion of the fleet. The 

MOU also included a requirement to have electric or zero-emission vehicles represent 

at least thirty percent of the 1997 existing fleet, in aggregate, by December 31, 2010. 

The signatory airlines terminated the MOU on October 28, 2005 stating that the 
5 

adoption of the Portable Engine Air Toxic Control Measure and other pending 

rulemaking that affects GSE is generally statewide in approach and largely inconsistent 

with the MOU, which is applicable only in the South Coast. 

The staff proposal presented in Section 3 is intended to retain the benefits of the original 

MOU through 2010 and achieve slightly greater benefits by 2013. 

2.5 LSI Inventory 

The ARB’s OFFROAD emission inventory model (ARB, 1998b), adopted in 1998 and 

updated regularly, was used in the development of this rulemaking. The annual 

average statewide emissions from off-road LSI engines are shown in Table 2.0. Offroad LSI equipment emitted about 70 tons per day of HC and NOx in 2004. By 2010, 

the emissions of these pollutants will be reduced to about 35 tons per day. This 

decrease is due to the new engine emission standards implemented in 2001. The 

trend, while positive, does not produce the same degree of reduction achieved from 

some other off-road categories. 

Table 2.0: Off-Road LSI Equipment Emissions 

Statewide Annual Average1

(tons per day) 

Year Population HC NOx 

2004 87,687 15.4 54.8 

2010 92,104 7.5 28.3 

2020 96,964 4.4 19.0 

1

 The inventory shown in Table 2.0 includes engines preempted by federal regulations. The 

emissions estimates do not reflect the impact of U.S. EPA’s 2007 new engine emission standard. 

The three equipment categories in Table 2.1 contribute the majority of off-road LSI 

emissions and are the focus of the regulatory proposal to reduce emissions from in-use 

fleets. As calculated from Table 2.1, emissions from these three categories account for 

greater than 80 percent of the total statewide LSI emissions in 2004. In terms of 

population, in 2004, the categories account for 60 percent of all off-road LSI equipment. 

Table 2.1: Off-Road LSI Equipment Emissions 

Top Three Equipment Categories (tons per day) 

Equipment 2004 2010 2020 

Category HC NOx HC NOx HC NOx 

Industrial Forklifts 11.8 40.4 5.3 19.9 3.4 15.6 

Airport GSE 0.6 3.3 0.3 1.5 0.2 1.0 

Sweeper/Scrubbers 0.2 0.8 0.1 0.3 0.1 0.2 
6 

3 REGULATORY PROPOSAL 

Staff has worked with LSI engine and equipment manufacturers and distributors, 

emission control system manufacturers, propane fuel refiners and distributors, end-user 

facility operators, federal regulatory agencies, air carriers, environmental groups, and 

other interested parties since January 2004 to identify approaches that would reduce 

emissions from new and in-use LSI engines and equipment. The most promising 

options involved lower-emissions standards for new engines, and fleet emission limits 

applicable to in-use fleets. Staff conducted workshops in May and August 2004 on 

these approaches. A proposal combining both approaches was discussed at two 

workshops held in March 2005 and presented to the Board in June 2005. Pursuant to 

the Board’s direction, additional information was sought and the proposal was further 

revised. 

A central element of the proposed regulation is a fleet-average emission standard 

applicable to equipment operators. The requirement would reduce emissions from 

uncontrolled equipment through retrofit and/or replacement with newer, lower-emission 

or electric equipment. More stringent emission standards for new engines ensure that 

cleaner LSI equipment would be available for purchase. The elements of the proposal 

are discussed below. 

3.1 More Stringent Emission Standards for New Engines 

The proposed emission standards for new engines include the following components: 

adoption of U.S. EPA’s 2007 model-year emission standard, a more stringent 2010 

model-year emission standard, optional certification standards and more rigorous test 

procedures. 

3.1.1 2007 Standard

Beginning with the 2007 model year, U.S. EPA’s tailpipe emission standards for new 

LSI engines are more stringent than ARB’s adopted standards. Staff proposes to adopt 

the U.S. EPA standards so that they can be enforced by California. Engine 

manufacturers would be required to meet a 2.0 g/bhp-hr (2.7 g/kW-hr) HC+NOx and 

3.3 g/bhp-hr (4.4 g/kW-hr) carbon monoxide (CO) emission standards. Alternatively, a 

manufacturer could certify to the following formula: 

(HC+NOx) x (CO)0.784 ≤ 8.57 

This formula, established by U.S. EPA, is represented by the curve shown in Figure 3.0. 

The alternative certification standard provides manufacturers with the flexibility to certify 

engines with higher CO emissions if they achieve lower HC+NOx levels. Staff believes 

such a tradeoff is protective of public health. 
7 

Figure 3.0: Alternative Federal Certification 

3.1.2 2010 Standard

Staff proposes a more stringent emission standard for new 2010 and subsequent 

model-year engines of 0.6 g/bhp-hr (0.8 g/kW-hr) HC+NOx and 15.4 g/bhp-hr (20.6 

g/kW-hr) CO. The proposed standards lie on the alternative compliance curve, as show 

by the arrow in Figure 3.0. Stated another way, the proposed 2010 standard limits the 

calibration flexibility of the engine manufacturer to achieve the lowest feasible HC+NOx 

emission level. For the 2005 model year, eight engine families used in industrial 

applications emitted at levels at or below the proposed 2010 standards. 

3.1.3 Optional Certification Standards

The staff also proposes to establish optional emission standards that are numerically 

lower than the 2007 and 2010 mandatory standards. During model years 2007 through 

2009, engines could be certified to the optional new engine standards of 0.1, 0.2, 0.4, 

0.6, 1.0, or 1.5 g/bhp-hr HC+NOx. For model year 2010 and beyond, engines could be 

certified to optional standards of 0.1, 0.2, or 0.4 g/bhp-hr HC+NOx. A January 20, 2005, 

Manufacturers Advisory Correspondence already allows manufacturers to certify their 

current engines to these interim lower-emission standards.

The optional standards provide manufacturers that produce cleaner engines an 

opportunity to certify at a lower standard. This may translate into a product that is 

available for Carl Moyer Program incentives. It may also be a more desirable product 

for the fleet owner that must meet an in-use fleet-average requirement. 

3.1.4 Enhanced Test Procedures and Other Manufacturer Requirements

The U.S. EPA emissions standards that take effect in 2007 also include more rigorous 

certification requirements and test procedures. This proposal adopts by reference the 

U.S. EPA certification and testing requirements for the 2007 to 2009 model years, and, 

0.8 g/kW-hr standard 
8 

with minor revisions, those requirements that begin in the 2010 model-year, as 

described in Appendix A, parts 4 through 7. The revisions include production line 

testing and in-use compliance procedures. 

The ARB staff also proposes to adopt the new U.S. EPA requirements for evaporative 

emissions and for engine-diagnostics systems. 

3.2 In-Use Emission Standards 

The ARB staff is proposing that operators of large and mid-size fleets of forklifts, 

sweeper/scrubbers,1

 GSE and industrial tow tractors meet an average emission 

standard for their in-use fleet. Fleet size is determined by aggregating an operator’s 

equipment in the State of California. Large LSI fleets as proposed are those with more 

than 25 pieces of equipment while mid-size LSI fleets would be those with 4 to 25 

pieces of equipment. The requirements would begin January 1, 2009. 

Under the proposal, large fleets would have to meet a more stringent fleet average than 

mid-size fleets due to their greater flexibility in incorporating combinations of 

emission-reduction strategies. Likewise, the fleet average would be more stringent for 

the forklift portion of the fleet than for the non-forklift portion of the fleet reflecting the 

greater availability of zero- and low-emission technologies. 

The fleet average would be determined using the certification levels of 2001 and newer 

LSI engines and the retrofit verification levels of engines with retrofit kits. To make the 

proposal less complex and less intrusive for the typical fleet operator while maintaining 

cost effective emission benefits, the fleet average will not incorporate load factors, 

horsepower, or hours of use. 

The proposal provides the LSI fleet operator with the flexibility to use any combination of 

retrofits, lower-emission purchases, and zero-emission electric purchases to meet the 

fleet-average emission level, which becomes progressively more stringent over time. A 

detailed discussion of the various compliance scenarios identified by ARB staff can be 

found in Appendix B.2. The following table summarizes the proposed fleet average 

emission levels for forklift and non-forklift LSI fleets. 

 

1

 With engine displacement greater than one liter. Of the engines certified in the 2004 model year for

sweeper/ scrubbers, 46 percent had a displacement of one liter or less (ARB, 2005). Engines with less

than one liter displacement are not subject to the LSI proposal and the equipment containing them is not 

subject to the fleet average requirement. 
9 

Table 3.0: In-Use Fleet Average Emission Requirements 

[g/bhp-hr (g/kW-hr) of HC+NOx] 

LSI Fleet Type Number of units By 1/1/2009 By 1/1/2011 By 1/1/2013

Large fleet – forklift 

component 26 + 2.4 (3.2) 1.7 (2.3) 1.1 (1.5) 

Mid-size fleet – forklift 

component 4-25 2.6 (3.5) 2.0 (2.7) 1.4 (1.9) 

Non-forklift fleet N/A 3.0 (4.0) 2.7 (3.4) 2.5 (3.6) 

Small fleet 1-3 Exempt from Fleet Requirements 

The fleet average proposal provides additional flexibility to the fleet operator that 

increases its fleet size enough to jump from one category to the other by instituting twoyear transition periods that correspond with the fleet average compliance dates. For 

example, on January 1, 2009, a mid-size fleet would have to meet a 2.6 g/bhp-hr 

standard. If that same fleet, through growth, becomes a large fleet, they would not have 

to meet the 2.4 g/bhp-hr requirement. However, they would have to meet the 1.7 g/bhphr requirement for large fleets, beginning on January 1, 2011, as that is the next fleet 

requirement. 

3.2.1 Special Fleet Requirement for GSE in the South Coast Air Basin

 

On October 28, 2005, ATA notified ARB that the air carriers who had signed the MOU 

were terminating the GSE MOU. The termination became effective 60 days later, 

December 27, 2005. The terminated MOU included a 2.65 g/bhp-hr HC+NOx fleetaverage standard for the LSI and diesel fleets, and a requirement that 30 percent of the 

baseline fleet be zero-emitting. Staff is proposing that GSE fleets in the South Coast air 

basin meet the same fleet-average emission requirements as other LSI fleets, and meet 

the MOU’s zero-emission requirement for their current fleet. 

3.2.2 Small Fleet Exemption

The ARB staff recognizes that small fleets, with one to three pieces of equipment, are 

least able to absorb the costs of an in-use proposal. In addition, it is believed that these 

users, in general, use their equipment fewer hours per year than the large- or mid-size 

fleets. Initially in considering these factors, the staff proposed that small fleets meet a 

relaxed requirement, consisting of two additional years to comply, relative to other 

fleets, and a less stringent fleet-average requirement. This was part of the proposal 

presented to the Board in June 2005. 

Staff has since revised its proposal to exempt fleet operators of three or fewer LSI 

engines. The exemption reduces the number of fleets subject to the rule by as much as 

60 percent while reducing the emission benefit by less than 20 percent. As discussed in 

Section 6.3, a substantial portion of the inventory of some forklift dealers is uncontrolled. 
10 

The cost of retrofit or disposal of a large number of forklifts imposes a large cost on 

these dealers compared to other fleet operators whose cost of operating forklifts is only 

a small portion of revenues. Thus, the small fleet exemption reduces the cost of 

compliance for forklift dealers by providing a sales outlet for some uncontrolled forklifts 

currently in their inventory. 

3.2.3 Hours of Use Exemption

Low-use equipment may be temporarily exempted from the fleet-average emission level 

requirements if it meets the following provisions: 

• The equipment is used, on average over any three year period, 250 hours per year 

or less, 

• The equipment is equipped with an operational hours-of-use meter, 

• The fleet operator maintains hours-of-use records for the piece of equipment, and 

• The fleet operator addresses any uncontrolled emissions by January 1, 2011, by 

either retrofitting or repowering the equipment to meet at least Level 2 verification as 

described in Section 3.3.1 below or by replacing the equipment with a new or used 

piece of equipment certified to a 3.0 g/bhp-hr HC+NOx emission standard or better. 

3.2.4 Specialty Equipment Exemption

Specialty equipment is defined as equipment that has unique or specialized 

performance capabilities that perform prescribed tasks. Specialty equipment used in 

large- and mid-size fleets is permanently exempted from the fleet average requirements 

provided that: 

• The Executive Officer approves the listing of the piece of equipment as specialty 

equipment, 

• The cost of replacing or retrofitting the equipment is deemed by the Executive 

Officer to be excessive, and 

• The equipment meets the first three provisions of the hours of use exemption (see 

Section 3.2.3 above). 

3.3 Proposed Verification Procedures for Retrofits 

The ARB staff is proposing a procedure to verify the in-use emission performance of 

retrofit control systems that can be used to help meet the proposed fleet-average 

emission requirements. The proposed verification procedures (contained and described 

in Appendix C) would apply to manufacturers of retrofit systems sold in California. 

These systems include but are not limited to, closed-loop fuel-control systems, fuelinjection systems, and three-way catalysts. 
11 

3.3.1 Retrofit Emission Verification Levels

Table 3.1 presents the LSI retrofit system verification levels that a manufacturer could 

choose. Depending on the level selected, a system could be verified on the basis of a 

percentage reduction or on the basis of an absolute emission level. In addition, the 

proposed procedures allow retrofit technologies that reduce emissions from either 

uncontrolled engines or certified engines. These options provide flexibility for 

manufacturers to develop a variety of control systems and determine the appropriate 

level of emission control for each. 

Table 3.1: Proposed LSI Engine Retrofit System Verification Levels 

Classification Percentage 

Reduction 

Absolute Emission Level 

(g/bhp-hr HC+NOx)

LSI Level 11 > 25%2 Not Applicable 

LSI Level 2 1 > 75% 3 3.0 

LSI Level 3a 1 > 85%4 0.5, 1.0, 1.5, 2.0, 2.5 

LSI Level 3b 5 Not Applicable 0.5, 1.0, 1.5, 2.0 

1 Applicable to uncontrolled engines only 

2 The verified emissions reduction is 25 percent regardless of actual emission test values 

3 The verified percentage reduction for LSI Level 2 is 75% or 3.0 g/bhp-hr regardless of actual 

emission test values 

4 Verified in five percent increments, applicable to LSI Level 3a classifications only 

5 Applicable to emission-controlled engines only 

At the time of the June 2005 hearing, ARB staff believed that the majority of retrofit 

systems would be verified to Level 2, providing a 75 percent reduction from 12 g/bhp-hr 

to 3.0 g/bhp-hr. Comments from manufacturers indicated that the applicability of the 

system would likely be limited to equipment that was approximately 1996 or newer. 

Since then, however, the ARB has verified a retrofit system that brings uncontrolled 

12 g/bhp-hr equipment to a level that is cleaner than current new equipment – down to 

1.0 g/bhp-hr. In addition, this system is applicable to the majority of all forklifts as old as 

1990. Two additional retrofit systems are now in the process of being verified. The 

verified system is now available for many pieces of uncontrolled equipment. 

3.4 Alternative Compliance Option for Fleets used in Agricultural CropPreparation Services 

Recognizing that forklift fleets owned and used in agricultural crop-preparation services 

are often significantly older than other fleets, and that these businesses are often not in 

a position to fully recover costs, ARB staff is proposing an alternative compliance option 

for these fleets. 

In June 2005, staff presented an option for fleets owned by agricultural crop-preparation 

businesses that was less stringent than the basic fleet requirement and allowed 
12 

additional time for compliance. Nonetheless, concern has continued regarding the cost 

of the proposal, especially the costs related to replacing equipment that could not be 

retrofitted. Staff has revised its proposal to further reduce costs by only requiring 

compliance of owned forklifts for which retrofit kits are available, thus avoiding the 

higher cost of replacing or retiring forklifts. 

About 40 percent of the forklifts owned by agricultural-related business are expected to 

have retrofits commercially available and be subject to retrofit; the remaining forklifts 

would not be affected by the proposal. Specifically, owners of agricultural-related fleets 

would be required to reduce emissions (to a 3.0 g/bhp-hr level or less) of 20 percent of 

their equipment for which retrofits are available by January 1, 2009, and the remaining 

80 percent by January 1, 2012. In addition, the agricultural proposal includes a low 

hours-of-use exemption and specialty equipment exemption, similar to those in the 

basic fleet average requirement. However, the low hours-of-use equipment exemption 

is permanent. 

The economic impact of this alternative proposal is described in Section 6.5 and the 

emissions benefits achieved (and foregone) from this proposal are detailed in Section 5. 

In summary, the proposal will result in substantially reduced costs to operators of 

agricultural forklifts, and provide an opportunity to receive incentive funds. The 

agricultural summer ozone season emission benefit of the proposal is approximately 

one ton per day of HC+NOx by 2012, which is 1.5 tons per day less than if full 

applicability were sought. 

4 TECHNOLOGY REVIEW 

Off-road LSI engines are similar to automotive engines, but have traditionally lacked 

some of the automotive-style emission controls that have been in use for more than 

25 years. While off-road LSI engines are exposed to duty cycles that can be more 

strenuous than those of their automotive cousins, they are suitable candidates for 

control, and manufacturers are now applying automotive-style emission control 

technologies to LSI engines to reduce emissions. These technologies include 

closed-loop fuel controls, fuel injection, and three-way catalytic converters. 

4.1 Emission Control Strategies 

Since 1980 automotive emission control systems have used a closed-loop fuel control 

system to help reduce emissions. These systems use sensors to monitor exhaust gas 

oxygen concentrations, and feed this information back to an electronic control module, 

which in turn keeps the air-to-fuel mixture at an optimum level. To help ensure more 

precise metering of fuel and optimum combustion, carburetors have been replaced by 

fuel injection. Today's advanced systems maintain an extremely tight stoichiometric airto-fuel balance during nearly all engine operations. This is important because 

fluctuations from stoichiometric result in reduced efficiency in controlling HC, NOx, and 

CO emissions. 
13 

Central to automotive emission control systems is the three-way catalytic converter. 

Automotive manufacturers have installed tens of millions of them each year for more 

than 25 years. They are an integral component of automotive emission-control systems 

that have allowed the automotive fleet to meet progressively lower emission standards, 

effectively reducing emissions by more than 95 percent. 

4.2 Emission Controls for LSI Engines 

Current LSI engines use closed-loop fuel-control systems with three-way catalysts to 

meet State and federal emission standards. The components used, however, are 

generally cheaper and less effective than versions found in passenger cars. Even so, 

close to 50 percent of all LSI engines certified in 2004 emitted at 1.0 gram or less which 

is well below the 2007 2.0 grams per brake-horsepower-hour standard. In addition, 

several current LSI engines already emit at 0.5 grams or less, demonstrating the 

feasibility of the more stringent 2010 standards. Engines tested and evaluated by U.S. 

EPA were used to establish the curve shown in Figure 3.0, which has an endpoint of 

0.8 g/kW-hr. Many of the engines being certified to meet the 2007 standard are 

expected to also be able to meet the 2010 standard through calibration changes alone. 

For others, modest improvements in precious metal loading, higher cell densities, 

and/or more effective washcoats may be needed. These technologies are readily 

available from the automotive sector. 

4.3 Impact of Transient Testing 

Some manufacturers have expressed concerns about the impact of the 2007 transient 

test cycle on the feasibility of achieving the proposed new engine standards. To date, 

information provided by the Southwest Research Institute indicates that, under the 

transient test cycle, hydrocarbon emissions from an LPG engine increased by about 30 

percent, but NOx emissions remained relatively constant. In a review of 13 forklift 

engine families (of 19 total) in our 2004 certification test database, NOx constituted 

approximately 50 percent of the HC+NOx emissions.2

 At 50 percent HC, the new test 

cycle could lead to a potential emissions increase of 15 percent over emissions from the 

steady state test cycle. However, all but one of the 13 engine families would still have 

an HC+NOx certification level of less than 1.0 g/bhp-hr because in instances where the 

HC emissions were high, the corresponding NOx emissions were low. Clearly, the new 

test cycle does not prevent compliance with the proposed 2007 standard. 

Test results from emission control device manufacturers using new catalysts and other 

emission control technologies, while not performed under the transient test cycle, show 

that emissions can be reduced by more than 90 percent when compared to the 

proposed 2007 standard (SwRI, 2004). The proposed 2010 standard requires a 70 

percent emission reduction. Given that several current production LSI engines emit well 

below the proposed standard and the exceptionally low emission levels demonstrated 

on modern passenger cars, meeting the proposed 2010 LSI standard is feasible. 

 

2

 Historically, NOx emissions constituted 80 percent of the total LSI emissions (September 1998, LSI Staff 

Report). 
14 

4.4 Lead Time 

When U.S. EPA promulgated the federal LSI standards, the Agency stated that the 

three-year period between the 2004 Tier 1 and 2007 Tier 2 emission standards (3.0 and 

2.0 g/bhp-hr, respectively) allowed manufacturers sufficient lead time to meet the more 

stringent standard. The U.S. EPA went on to state the expectation that the emissioncontrol technologies for the 2004 emission standard would be able to meet the 2007 

standard with additional optimization and testing. The ARB’s staff expects that three 

years will also be sufficient time for manufacturers to further optimize the emissioncontrol technologies needed to meet the 2010 ARB 0.6 g/bhp-hr requirement. It also 

provides sufficient time to incorporate hardware changes, should they be necessary. 

4.5 Fuel Quality 

Liquefied petroleum gas is a mixture of various hydrocarbons produced from crude oil 

refining or the processing of natural gas. Propane is the predominant component of 

LPG. The LPG used for motor vehicles must meet a quality specification to ensure 

proper operation of motor vehicles and to achieve and maintain exhaust emission 

standards. LPG fuel that does not meet these motor vehicle specifications can harm 

engine fueling systems and components and may prevent an engine from complying 

with existing and future emissions standards. 

In 1992, ARB established motor vehicle fuel specifications for LPG limiting the propene 

content to 10 percent by volume. Other heavier hydrocarbons are also limited. Not all 

LPG produced meets the LPG motor vehicle specifications. The LPG not meeting the 

motor vehicle specification is considered commercial grade propane and is used mostly 

for space heating and recreational purposes. 

There are two separate concerns about LPG motor vehicle fuel quality - fuel 

contamination and high olefin content. Contaminated fuel can have an immediate and 

sometimes damaging impact on the fuel delivery system and the emissions control 

system. Contamination typically occurs downstream of production during storage and 

distribution. For example, contamination can occur from fuel-hose degradation. 

There is information to suggest that LPG containing high olefins, such as propene, can 

accumulate on fueling components and can adversely affect the fuel-delivery and 

emission-control systems. This accumulation is often the result of using commercial 

grade fuel in motor vehicles. Commercial grade fuel is intended primarily for heating 

and has a higher olefin content than motor vehicle grade LPG. Olefins react to create a 

plastic-like coating in the vaporizers, carburetors, and injectors. This coating gums up 

these engine components, reducing the effectiveness of heat transfer and ultimately 

causing poor delivery of the fuel and inaccurate fuel-to-air ratios. Heavy hydrocarbon 

residue may also cause similar problems. 

The ARB is committed to working with industry to determine if the existing specifications 

are adequate to support more stringent emission standards. The ARB is executing a 
15 

contract to analyze 150 LPG samples from various sites statewide. The ARB is also 

following activities of the control device manufacturers, refiners, and LPG distributors to 

make low olefin LPG fuel, advanced fuel filters, and fuel additives available to fleets, 

leading to reduced emissions and vehicle maintenance and improved fuel efficiency. 

5 ENVIRONMENTAL IMPACTS 

5.1 Air Quality Impacts 

Staff used the ARB’s OFFROAD model to estimate emissions from LSI engines. The 

key assumptions for population and activity are shown in Table 5.0. 

Table 5.0: OFFROAD Model Input Factors 

Input Unit All LSI Equipment1

Horsepower hp 63 

load factor unitless 0.47 

activity hours/year 905 

2010 population unitless 92,507 

2020 population unitless 96,963 

life years 10.8 

1 Population-weighted 

Staff calculated the emission benefit from the introduction of the 0.6 g/bhp-hr low 

emission standard using the difference between that standard and the federal 

2.0 g/bhp-hr standard, new equipment sales volume, and the above input standards. 

Staff calculated the emission benefit from the fleet-average requirements by taking the 

difference between an established baseline fleet-average emission level and the 

proposed fleet-average emission levels for all affected fleets. The baseline takes into 

consideration the current use of electric equipment in many fleets. 

Table 5.1 lists the 2010 and 2020 emission benefits of the proposed regulation. The inuse benefits are roughly 20 percent lower than those presented at the June 2005 Board 

hearing. The reasons for the decrease in emission benefit are shown in Table 5.3. 
16 

Table 5.1: Statewide Emissions Benefits 

HC+NOx Reductions (tons per day) Staff Proposal Element 

Year 2010 Year 2020 

Fleet Average Emission Requirements1 4.5 < 1.02

New Engine Standards 1.2 6.2 

Total 5.7 6.2 

1 These requirements apply to fleets with 4 or more pieces of off-road LSI equipment. 

2 The benefits from the in-use standards are expected to be minimal in 2020 as the vast majority of the 

equipment will have been retired. 

Table 5.2 shows the estimated 2010 and 2020 benefits of the staff’s proposal for the 

South Coast relative to the SIP emission reduction commitment for that region. The 

benefits in the South Coast are expected to decrease in proportion to the statewide 

decrease, but will still represent 46 percent of the statewide total. As shown in Table 

5.2, the emission benefits of staff’s revised proposal are just below the 2003 SIP 

commitment for 2010 and well within the range for 2020. 

Table 5.2: South Coast Air Basin Emissions Benefits 

1 6.1 to 13.0 tons per day on statewide basis. 

The staff’s revised proposal contains provisions to reduce the costs to small fleets and 

agricultural-related businesses. The effect of these revisions is to reduce the emission 

benefit achieved in the post-2010 time-frame. The reduced benefits of the small fleet 

exemption does not impact the 2003 SIP commitment for 2010 because small fleets 

were not originally required to have their equipment comply with prescribed standards 

until 2011. It additionally is not reflected in the 2003 SIP commitment for 2020 because 

it is assumed all uncontrolled forklifts (except agricultural forklifts), will have been retired 

by that time. 

The proposal for agricultural-related businesses is estimated to achieve 1.3 tons per 

day for the summer ozone season by 2012. The substantial portion of the previous and 

current agricultural proposal occurred after 2010, therefore the 2010 benefits are not 

significantly impacted by this revision. By 2020, staff assumes that 40 percent of the 

agricultural-related forklifts will have been retired, reducing the emissions loss to about 

1.0 ton per day. Table 5.3 shows the impacts from these revisions. 

HC+NOx Reductions (tons per day) 

Year 2010 Year 2020 

2003 SIP Commitment 2.8 -6.01 1.5 – 5.1 

Staff’s Proposal 2.6 2.9 
17 

Table 5.3: Impact of Revised In-Use Proposal 

(tons per day HC+NOx) 

Agriculture Retrofit Only1

 (2.2) 

Small Fleet Exemption (1.0) 

1 The agricultural benefits are for the summer ozone season, assuming that 75% of 

 annual hours occur during this period. 

It should be noted that dealers have questioned whether the existing LSI regulations 

have already achieved emission benefits not reflected in staff’s inventory because a 

significant number of LSI engines are certifying well below the standards. The emission 

benefits attributable to the LSI regulations already in effect were determined using the 

applicable certification standards consistent with the methodology for most other mobile 

source regulations. The ARB staff will continue, nonetheless, to assess and improve 

the LSI emissions inventory, including in-use emissions, and other factors such as 

hours of use, emissions deterioration, and equipment life. 

5.2 Other Impacts 

The ARB staff has also assessed the impacts from the use of electric forklifts. An 

increase in their use would result in a corresponding increase in the electrical energy 

required to recharge the batteries on a regular basis and in turn, would create a greater 

demand for electricity supplied at generating facilities. 

To determine the relative impact from the use of electric forklifts, staff assumed that the 

population of Class 1 electric rider-forklift trucks grew by 25 to 50 percent as a result of 

the regulation. Staff assumed that these electric forklifts had an average of 50 

horsepower (37.3kW) and would be operated at a 30 percent load factor for 1,900 hours 

per year. Under these assumptions, the increased energy demand from the additional 

entire electric forklift fleet would be approximately 0.05 to 0.10 percent of the projected 

total energy demand in 2010. This increased demand, which includes losses 

associated with the distribution of electricity, will not have a significant impact on the 

overall system. 

The use of electric forklifts will increase electricity demand and consequent upstream 

emissions, primarily NOx, from power plants. The NOx emissions from power plants 

attributed to the increased energy demand of electric forklifts will be small in comparison 

to the NOx emissions from the LSI forklifts that are being replaced. Additionally, air 

district permitting programs are in place to minimize these emission increases and 

previous estimates have determined these upstream emissions to be extremely small 

compared to the benefits achieved. 

While electrification of forklifts will result in the increased production and use of 

batteries, lead-acid batteries are well regulated and banned from municipal solid waste 

landfills. Additionally, California has an established recycling infrastructure, and the 
18 

recycle rate for lead-acid batteries is currently over 95 percent. With these mitigation 

measures in place, battery disposal impacts should not be significant. 

6 ECONOMIC IMPACTS – COST AND COST-EFFECTIVENESS 

Section 11346.3 of the Government Code requires 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 

business to compete. 

State agencies are also required to estimate the costs or savings to any state or local 

agency and school district in accordance with instructions adopted by the Department of 

Finance. The estimate shall include any non-discretionary costs or savings to local 

agencies and costs or savings in federal funding to the state. 

Any business involved in the production or use of LSI engines would potentially be 

affected by the proposed regulation. Also potentially affected are manufacturers that 

supply components for engines and industrial equipment, and distributors and retailers 

that sell such equipment. 

6.1 Incentive Programs 

Incentive programs have the ability to prompt emissions benefits early or beyond those 

required by regulations. California has the largest incentive program in the nation, with 

over $140 million available each year through State and local funds. Even so, this level 

of funding is far from sufficient to pay for all the reductions needed to provide clean air. 

Reductions required by regulations, and funded by owners of the affected equipment, 

will still provide the majority of emission reductions. 

Currently, incentive programs, such as the Carl Moyer Program, provide modest funding 

for forklift projects. In some cases, the incremental cost of electric forklifts can be 

funded (about $5,000) if the applicant can demonstrate he or she is not in an occupation 

where electric forklifts are the norm. Purchase of low-emission forklifts has not 

previously been an eligible category because no low-emission standards existed (“lowemission standards” refers to optional standards more stringent than otherwise required 

of all LSI engines). With the adoption of the proposed optional low-emission standards, 

manufacturers could be eligible for the incremental cost of the low-emission equipment. 

Recently, retrofit systems for forklifts have become an eligible project category, with the 

full retrofit cost eligible for funding. 

With the adoption of the proposed regulation, most of the incentive projects would no 

longer be eligible for funding. Several exceptions would remain: 
19 

Small Fleets 

Small fleets, from one to three units, are exempt from the regulatory proposal. As such, 

they would continue to be eligible for incentive funding. Eligible projects include the 

incremental cost to purchase electric forklifts, low-emission forklifts, and retrofits. 

Agricultural-Related Fleets 

The alternative proposal for agricultural-related businesses would not require 

implementation of the retrofit requirements until January 1, 2012, for 80 percent of these 

fleets. As such, that portion of the fleet would be eligible for incentive funds to pay the 

full cost of the retrofit through January 1, 2009. After that point, the project could not 

demonstrate a three-year project life, as required by the Carl Moyer Program. 

Complying Fleets 

Fleets that demonstrate full compliance with their fleet-average requirements would be 

eligible for incentive funds to further reduce emissions. Eligible projects would include 

electric forklifts, low-emission forklifts, and retrofits. 

6.2 Potential Impact on Manufacturers 

The proposed engine standards will impact manufacturers of off-road LSI engines and 

original equipment using such engines. Engine manufacturers are located mostly 

outside of California. As manufacturers are already developing engines to comply with 

the federal 2.0 g/bhp-hr standard for 2007, the proposed adoption of California 

standards for 2007 to 2009 is not expected to result in significant additional work or 

costs. For reference, the U.S. EPA estimates that the additional cost to manufacturers 

of meeting the 2007 standards is approximately $50 per engine. 

Most engines meeting the 2.0 g/bhp-hr standard are expected to use the same basic 

hardware to also meet the 2010 requirement of 0.6 g/bhp-hr, although calibration 

changes will be needed. To provide a conservative cost analysis, ARB staff assumed 

that 25 percent of all engines would need improvements to the catalyst system 

(increased volume and/or precious metal loading) resulting in an average hardware cost 

increase of 40 percent. This cost is shown in Table 6.0. U.S. EPA’s rulemaking for 

2007 is the source for the base catalyst cost. 
20 

Table 6.0: Incremental Hardware Cost 

 2010 Emission Standard 

per engine 

Base catalyst/muffler (2 gram 

standard) $295

Improved catalyst/muffler (0.6 

gram standard) $415 

Incremental cost (for the 25 percent of 

engines needing improvements) $120 

Average incremental cost $30 

Spreading the cost of the catalyst upgrade across all engines sold in California results in 

an average incremental per engine cost of $30. 

The U.S. EPA analysis determined the fixed and variable costs for manufacturers 

producing LPG, CNG, and gasoline engines to meet the 2.0 g/bhp-hr standard. The 

ARB staff used the compliance costs from this analysis to determine the engineering 

and compliance costs for engines designed to meet the 0.6 gram standard. The 

incremental hardware costs noted above were then included to determine the overall 

cost presented in Table 6.1. As shown, the proposed new standards for 2010 are 

expected to add less than $100 to the cost of a new engine. This cost will be passed 

onto the fleet operator and is small enough to not significantly impact California 

competitiveness, employment, or business status. 

Table 6.1: Incremental Retail Price Equivalent Costs 

To Meet 2010 Standard 

per engine 

Research and development $20

In-Use Testing $10 

Certification $20 

Hardware improvements (from Table 6.0) $30 

Total Incremental Cost $80 

The compliance costs in Table 6.1 assume that manufacturers will produce and sell 

most 0.6 g/bhp-hr engines nationwide (the 75 percent that do not require extra 

hardware to comply) and, thus, will be able to spread the fixed costs over a larger 

volume of engines. The ARB staff believes that this is reasonable given that the 

engines expected to be in production in 2010 are essentially the same as those that will 

be produced to meet the federal regulations. ARB staff did not, however, assume that 
21 

the 25 percent of engines with more expensive and robust catalysts would be sold 

nationwide. Therefore, the per engine certification cost considers that these engines 

are only sold in California and, thus, the cost is greater than the per engine estimates 

presented by U.S. EPA. 

The research and development costs in Table 6.1 reflect the calibration changes 

needed to meet the 2010 standards. A portion of the in-use testing cost derived by 

U.S. EPA is due to facility upgrades for transient testing to meet the federal 2007 

standards. As these improvements will occur regardless of this proposed rulemaking, 

the in-use testing cost used by ARB staff is conservative. 

6.3 Potential Impact on Distributors and Dealers 

Most engine and equipment manufacturers sell their products through distributors and 

dealers. While distributors and dealers are not directly affected by the proposed 

standards, the proposed standards may affect them indirectly. Dealers earn income 

through the sale and lease of new forklifts, parts and service for in-use forklifts, forklift 

rental, and the sale of used forklifts. In the June 2005 proposal, staff believed that 

forklift dealers would be able to pass through the vast majority of all costs associated 

with the proposal to the operators of the equipment. Since that time, staff has learned 

that the business model for forklift dealers is more complex. The following discussion 

assesses how the various elements of the staff proposal may affect dealers. 

Regarding the sale or lease of new forklifts, this proposal is not expected to have a 

significant positive or negative impact on dealers. An increase in price could potentially 

reduce sales. However, the projected increase in cost is modest (less than 1 percent) 

and it is expected that it will be passed on to end-users since all competing equipment 

will increase in price. It is more likely that an impact of the proposal will be that fleets 

will turn over equipment more quickly in order to comply with the fleet-average 

requirements. This would result in the increased sale and lease of new equipment. 

In the sale of parts and service for in-use equipment, the proposal is likely to have a 

slightly positive impact since the proposal would result in increased business to install 

retrofit systems in order to comply with the fleet-average requirement. 

With regard to rental forklifts, the proposal would require that forklifts rented for less 

than one year meet a 3.0 g/bhp-hr emission standard by 2009. The impact on the 

dealers would depend on several factors, including when the dealers began purchasing 

controlled equipment, the average turn-over rate of their rental fleet, and the ability to 

pass along any increased rental costs due to more expensive equipment. A dealer that 

was receiving controlled equipment since 2003 and is on a five-year lease turn-over 

cycle would not have any significant impact. A number of dealers are in this position. 

Most dealers, however, will have a small percentage of uncontrolled equipment still 

within their rental fleet by 2009. A few dealers were still receiving uncontrolled 

equipment in 2004 and if they are on a longer turn-over cycle may have to address a 

larger percentage of their fleet. 
22 

A dealer may employ several options to address the uncontrolled fleet. A 

straightforward option is to install a retrofit system. The cost of the retrofit system to the 

dealer and its installation are estimated to be $3,500. The extent to which these costs 

may be passed along to the rental customer is unknown. Dealers have stated that they 

do not believe any increase in costs could be passed along because they have not been 

able to increase rental costs for many years. However, in the new dynamic of a fleet 

rule, it seems reasonable to assume that some increase in costs could be 

accommodated. Staff does not believe the full cost could be recouped. 

A second option for the dealer would be to slightly accelerate the turn-over of the rental 

fleet to incorporate new or used equipment that is controlled. Again, this would require 

added costs on the part of the dealership for a portion of the fleet, and it is unclear what 

percentage of that cost could be passed along. A related option is for dealers to adjust 

the make-up of their rental fleets. The revised staff proposal would allow uncontrolled 

equipment to be sold to small fleets. Therefore, dealers could guide uncontrolled 

equipment to small business sales and ensure more controlled equipment is moved into 

the rental fleet. A third ption is for dealers to utilize the low-hours exemption. As 

discussed, equipment that is used less than 250 hours per year would have two 

additional years to comply. 

None of these solutions fits all the situations or provides the entire solution. Those 

dealers with some uncontrolled equipment remaining in their rental fleet will likely need 

to incorporate several of the options in order to comply with the regulations in the most 

cost-effective way. In addition, dealers will need to be prepared to make adjustments to 

how they currently conduct business in order to maintain a fleet of controlled equipment 

available to rent. 

The final income source for dealers is used forklift sales. A number of dealers have 

portrayed this source of income as providing the largest profit for the dealership. In 

order for dealers to have an ample supply of used forklifts coming back to them for 

resale, dealers often guarantee the value of any new lease that they enter. 

Consequently, the fleet rule, as structured in the June 2005 proposal, could have had a 

significant economic impact on some dealers, since it would have devalued the 

uncontrolled equipment for which they had guaranteed a specific value. Staff believes 

the current proposal significantly reduces, although does not eliminate this impact. The 

proposed exemption of small fleets from the in-use fleet requirement will provide a 

continuing market for uncontrolled forklifts. However, not all used dealer forklifts are 

sold to small fleets. 

Table 6.2 provides a range of potential costs to dealers. The total number impacted is 

based on information from industry and is largely affected by normal turnover and 

placement of equipment in small fleets. The cost range assumes that a large portion of 

the equipment procured in 2004 was uncontrolled, that all equipment impacted will be 

retrofit at a cost of $3,500 per unit, and that none of the cost is passed along to the 

consumer. These assumptions provide a worst-case analysis for the industry as a 
23 

whole. As shown in the table, staff estimates the total cost to be between roughly $2 

million to $5 million. Rather than retrofitting the forklifts, dealers may avoid this cost by 

limiting their sales of uncontrolled equipment to small fleets and selling the equipment 

over a longer period of time. 

Staff’s June 2005 proposal did not include the small fleet exemption and would have 

impacted this segment of uncontrolled forklifts. Since a large percentage of equipment 

is ultimately sold into small fleets, the June 2005 proposal would have represented two 

to three times the estimated costs presented in Table 6.2 below. 

Table 6.2: Potential Costs to Dealers1

Revised Staff Proposal 

Total Impacted - low estimate 250 units 

 - high estimate 1,400 units 

Cost per Retrofit $3,500 

Total Cost to Equipment Dealers $875,000 to $4,900,000 

1 Dealers estimated a total of approximately 12,000 forklifts statewide. Based on a typical lease 

life of 5 years and typical rental life of 5-8 years, and an estimate of 85 percent of forklifts sold to 

small fleets, the low and high estimates were derived for the number of uncontrolled forklifts. 

6.4 Potential Impact on Equipment Operators 

Under the staff proposal, fleets would have the flexibility to decide the mix of options to 

achieve the required fleet average emission levels. The fleet average approach will 

allow LSI fleet users to choose the lowest cost option for their particular application. 

Among the possible options are retrofit equipment, purchase of certified cleaner 

equipment or purchase of zero-emission electric equipment. To determine a range of 

potential cost, staff analyzed the potential impact to end users of the requirements 

applicable to fleets of different sizes. 

6.4.1 Lower-Emission Engines

Fleet operators can purchase new engines as necessary to meet the fleet standards. 

Incremental costs for engines in the 2007 to 2009 timeframe are attributable to federal 

regulations that will require equipment to meet the 2.0 g/bhp-hr standard. For engines 

purchased in 2010 and beyond, staff expects that the incremental cost will be minimal, 

less than $100. Fleet operators may also be able to buy optional, lower emission 

engines. The incremental costs for these engines is not known, but these costs are not 

expected to be significant as some engines already being sold emit at these low levels. 

 

6.4.2 Zero-Emission

An electric forklift typically costs from $1,500 to $5,000 more than a comparable LSI 

forklift (EPRI, 2001). However, since an electric forklift has a longer useful life and 

reduced fuel and maintenance costs, the electric forklift can reduce life-cycle costs 

compared to a LSI forklift. 
24 

Electric forklifts can provide reductions from 2.0 g/bhp-hr to 12.0 g/bhp-hr depending on 

the emissions rate of the equipment they replace. Assuming an average emissions-rate 

reduction of 7.0 g/bhp-hr (combined with horsepower, hours of use, and load factor, as 

noted above) yields an average emissions reduction of 500 pounds per year per forklift. 

6.4.3 Retrofit

Retrofit systems reduce emissions from older, uncontrolled forklifts, which produce 

12 g/bhp-hr HC+NOx, to a level of 3.0 g/bhp-hr HC+NOx or lower. The cost of a retrofit 

system is estimated to be $3,500 as installed (Lubrizol, 2005). These systems provide 

an average benefit of approximately 690 pounds of HC+NOx reductions per forklift per 

year. It should also be noted that many of the 2001 through 2003 engines that were 

certified as uncontrolled during the phase-in of the 3.0 g/bhp-hr standard are already 

equipped with some of the emission-control components. Lower cost retrofit systems 

could be available for these engines. 

The installation of a retrofit system will improve engine operation and reduce fuel use. 

Closed-loop fuel systems generally operate close to stoichiometry, improving the 

engine’s efficiency. Information from retrofit control-system manufacturers and data 

from U.S. EPA indicate an estimated 10- to 20-percent reduction in fuel consumption 

with engines employing closed-loop systems (U.S. EPA, 2002). For a typical LPG or 

gasoline forklift, the annual fuel savings from a retrofit system used in California is 

estimated at $600 as shown in Table 6.3. Thus, the retrofitting of existing uncontrolled 

engines can provide net savings over the equipment’s life. 

Table 6.3: Estimated Fuel Savings

Input LPG 

Horsepower (hp) 66 

Load factor (unit-less) 0.30 

Use (hours)11,200 

Improved brake-specific fuel 

consumption (pound/hp-hour) 0.075 

Fuel density (pounds per gallon) 4.2 

Fuel cost (dollars per gallon) 1.50 

Annual savings (dollars) 600 

1 The fuel savings estimate is based on an annual usage of 1,200 hours as opposed to the average 

use-rate of 1,800 hours to reflect the fact that older equipment is used less than the average. 

6.4.4 Incremental Capital Cost

Table 6.4 summarizes the estimated initial costs of each option available to fleet 

operators. These values were used to generate the estimated cost effectiveness 
25 

presented below. Staff did not include in its calculation the reduced fuel and 

maintenance costs resulting from use of retrofitted and zero-emission equipment, which 

over the equipments’ life may exceed the incremental capital cost. 

Table 6.4: Incremental Capital Cost 

Compliance Option 

Retrofit $3,500 

Lower-Emission $30 - $80 

Zero-Emission $1,500 - $5,000

6.5 Potential Impact on Agriculture 

The proposed regulations include an alternative compliance option for forklifts owned by 

agricultural fleets to address issues specific to that industry. This option reduces costs 

to agricultural businesses to a minimal level. 

Applying the fleet average proposal to agricultural-related fleets results in a total cost to 

industry of over $30 million. Staff identified this as a concern, and prior to the June 

2005 Board hearing staff developed a proposal that significantly reduced the cost and 

spread it over 10 years. Staff estimated that the June 2005 proposal would have a cost 

of between $5 million and $6 million. At that time, industry estimated the cost to be 

significantly higher. The main differences were that staff assumed a modest level of 

turnover and industry assumed no turnover. In addition, staff assumed industry would 

purchase used forklifts when replacing an old forklift, and industry assumed new forklifts 

would be purchased. 

Staff has revised its proposal for agricultural-related fleets. Equipment for which a 

retrofit system is available must be retrofit. Equipment for which no retrofit system is 

available may continue to be used. This avoids the higher cost of replacing this typically 

older equipment, which would have been required under staff’s June 2005 proposal. 

Based on the information provided by the agricultural industry, uncontrolled forklifts that 

can be retrofitted and thus would be impacted by staff’s revised proposal account for 40 

percent of their total owned forklifts. Assuming a conservative 10 percent of the 

affected forklifts will take advantage of one of the two exemptions proposed (low-use, 

specialized equipment), only 830 forklifts will be required to be retrofitted. Table 6.5 

presents the total costs, and the estimated cost to industry if the fleets take full 

advantage of the incentive monies that are available under the revised proposal. 
26 

Table 6.5: Potential Costs to Agriculture

1 As estimated by industry, 40 percent of the fleet is model-year 1990 or newer and 

can be controlled. 10 percent of this portion of the fleet is assumed to meet the low 

usage or specialty equipment exemption. 

On a per fleet basis, a typical business such as a packinghouse might have between 10 

and 20 owned forklifts potentially impacted by this proposal. Of those, between four 

and eight would be required to have a retrofit. Incentive funding could be available for 

up to 80 percent of these. If the typical packinghouse takes advantage of maximum 

incentive funding and only needs to fund two retrofit systems, the cost to the 

packinghouse could be as low as $6,000 to $8,000. If incentive funding is not utilized, 

maximum cost would be in the range of $32,000. For simplicity, the cost estimates do 

not incorporate fuel savings that the retrofit systems provide. 

6.6 Cost-Effectiveness 

The incremental capital cost estimates in Section 6.4.4 were amortized over the 

expected life of the equipment3 with an interest rate of five percent. The amortization 

formula yields a capital recovery factor, which when multiplied with the initial capital 

cost, gives the annual cost of the compliance option over its expected lifetime. Dividing 

the annual cost of the compliance option by the emissions benefit in pounds for that 

option yields the cost-effectiveness. For both retrofitted and electric forklifts, the costeffectiveness is presented as a range to reflect both the full incremental capital costs 

and the overall life-cycle costs. 

For those businesses that can incorporate electric equipment without the need for 

battery-swapping or fast-charging, staff believes electric equipment provides a life-cycle 

saving. However, as many businesses are sensitive to the initial capital costs, the costeffectiveness is also listed with the full capital cost. Staff did not estimate the full lifecycle cost of electric equipment if fast-charging or battery-swapping were necessary. 

Because the proposed fleet-average requirement provides flexibility, staff assumed that 

an operator would not choose to convert to electric equipment unless the operator could 

reasonably and cost-effectively incorporate such equipment within the fleet or had other 

reasons for doing so. 

 

3

 Conservatively, the expected life of a retrofitted forklift is five years, while that of a lower-emission forklift 

is seven years and an electric forklift is nine years. 

Equipment 2,300 units 

Equipment Impacted1 830 units 

Cost per Retrofit $3,000 - $4,000 

Total Capital Cost $2.5-$3.3 million 

Eligible for Financial Assistance 80 percent 

Potential Net Cost $500,000-$660,000 
27 

Table 6.6: Cost-Effectiveness 

Compliance Option Dollars per pound 

Retrofit 0 – 1.20 

Lower-emission 0.13 

Zero-Emission 0 – 1.401 

1 Cost-effectiveness based on replacement of both controlled and 

uncontrolled equipment. 

Thus, as illustrated in Table 6.6 above, fleet operators have several cost-effective 

options to comply with the fleet standards. The cost-effectiveness for all options 

compares favorably with other regulatory programs adopted by ARB. 

6.7 Potential Impact on Business Competitiveness, Employment, and Business 

Creation and Elimination 

The proposed regulation is not expected to have a significant impact on the ability of 

California businesses to compete with businesses in other states. Requirements for the 

end users are not expected to be significant as new engines, electric equipment, and 

retrofit kits all provide performance and cost benefits. The resale value of existing 

uncontrolled equipment that is not retrofitted will be reduced. 

The proposed regulation is not expected to cause a noticeable change in California 

employment. California accounts for only a small share of the manufacturing 

employment in industrial equipment and components. 

The proposed regulations are not expected to cause any significant change in the status 

of California businesses. The regulation would potentially increase the retail price of 

LSI equipment. However, these costs are expected to be minor. The regulation will 

stimulate demand for fuel-system components and retrofit systems, resulting in an 

increase in business for some California manufacturers. 

7 ALTERNATIVES AND RECOMMENDATION 

7.1 Alternatives Considered 

In June 2005, ARB staff presented a proposal that was similar in structure to the current 

proposal, except that it retained a fleet average requirement for small fleets and a more 

aggressive alternative option for agricultural-related businesses. The June proposal 

achieved greater reductions; however, staff believes the economic impact of that 

proposal was too high. The current proposal provides a more appropriate balance 

between technical feasibility and cost to affected industries. 

During the regulatory development process, ARB staff evaluated various strategies for 

reducing emissions from LSI engines including: 
28 

 Lowering Manufacturer Emission Standards 

 Manufacturer-based Fleet-Average Standards 

 Owner or User Fleet-Average Standards 

 Near-Zero Emission Requirements 

 Zero-Emission Requirements 

 In-Use Retrofit Requirements 

Each of the elements noted was considered both independently and in combination. At 

one point, ARB staff actively pursued a requirement for electric purchase. This concept 

would have required medium and large fleets to meet a 10 percent electric component 

in 2007, 20 percent in 2008, 30 percent in 2009, and 40 percent in the years 2010 

through 2015. ARB staff decided this concept would not provide the necessary 

flexibility to industry, and might force the use of a specific technology in applications 

where it would be unsuitable. 

ARB staff also considered requiring that medium and large fleets reduce emissions from 

their existing uncontrolled LSI engines by the end of 2008 through the use of retrofit 

emission-control systems. Small fleets of one to three units would have had additional 

time to retrofit their equipment, and would have been exempt from the electric purchase 

requirement. Again, staff rejected these concepts and instead developed a fleet 

average concept to allow fleets greater flexibility in reducing their emissions. 

7.2 Conclusion 

The proposal described herein would reduce HC+NOx emissions in a cost-effective 

manner. No alternative considered by the agency would be more effective in carrying 

out the purpose for which the regulation is proposed or would be as effective as or less 

burdensome to affected private persons than the proposed regulation. 
29 

REFERENCES 

ARB, 1998a. "Public Hearing to Consider Adoption of Emission Standards and Test 

Procedures for New 2001 and Later Off-Road Large Spark-Ignition Engines," California 

Air Resources Board, September 4, 1998. 

ARB, 1998b. "Notice of Public Meeting to Consider the Approval of California's 

Off-Road Large Spark-Ignited Engine Emissions Inventory,” California Air Resources 

Board, October 22, 1998. 

ARB, 1998c. “Notice of Public Meeting to Consider the Approval of California's 

Off-Road Large Spark-Ignited Engine Emissions Inventory," Attachment 1, Input 

Factors, California Air Resources Board, October 22, 1998. 

ARB, 2001. "Policies and Actions for Environmental Justice. "Sacramento, California. 

California Air Resources Board, December 13, 2001. 

ARB, 2003. "Proposed 2003 State and Federal Strategy for California State 

Implementation Plan," Section II Mobile Sources, Introduction and Chapter D, California 

Air Resources Board, August 25, 2003. 

ARB, 2005a. California Air Resources Board, Large Spark-Ignition Off-Road Summary, 

2005 Model Year Certified Large Spark-Ignition Engine List: 

http://www.arb.ca.gov/msprog/offroad/cert/search_result.php , undated web page. 

ARB, 2005b. Cost-Effectiveness Calculations Spreadsheet, Air Resources Board, 

April 2005 

 

ARB, 2006a. Criteria Pollutant Emission Benefits Spreadsheet, Air Resources Board, 

February 2006 

ARB, 2006b. Agricultural-Related Emissions Analysis, Air Resources Board, February 

2006 

ARB, 2006c. Dealer Costs Spreadsheet, Air Resources Board, February 2006 

EPRI, 2001. “Increasing Profits with Electric Industrial Vehicles: A Case Study on the 

Alabama Power Company Electric Forklift Incentive Program,” Electric Power Research 

Institute Inc., 2001. 

GRI, 1995. "Industrial Truck Market Analysis," Final Report (GRI-95/0422), page 12, 

Gas Research Institute, October 1995. 

GSE MOU, 2002. “South Coast Ground Service Equipment Memorandum of 

Understanding,” An agreement between the California Air Resources Board and 17 

airlines, November 27, 2002 
30 

ITA, 2005. Regular Member Products (by Class and Lift Code), 

http://www.indtrk.org/products.asp?id=rmp , April 25, 2005. 

Lubrizol, 2006. Email from Cesar Baumann of Lubrizol Engine Control Systems, 

February 2, 2006. 

MECA, 2003. "Emission Control Systems for Spark Ignited Vehicles & Engines: From 

PZEVs to Clean Lawn Mowers," Manufacturers of Emission Controls Association 

presentation, May 2003. 

MECA, 2004. “MECA Responses to ARB Questions Regarding Three Way Catalyst 

(TWC) Technology for LSI Applications,” Manufacturers of Emission Controls 

Association, prepared by Dr. Joseph Kubsh, MECA Deputy Director, June 30, 2004. 

Nett Technologies, 2006. Email from Wayne Borean, of Nett Technologies, February 2, 

2006. 

SwRI, 2004. “Investigation of LPG Fuel System Technologies and Fuel Composition 

Effects on Emissions,” Presentation to the Industrial Truck Association Spring Meeting, 

Southwest Research Institute, March 23, 2004. 

U.S. EPA, 2002. “Control of Emissions from Nonroad Large Spark-Ignition Engines, and 

Recreational Engines (Marine and Land Based); Final Rule,” Federal Register, Volume 

67, Number 217, pages 68242 - 68447, November 8, 2002. 
 

APPENDIX A: MANUFACTURER STANDARDS AND TEST PROCEDURES 

1. Proposed Regulation Order, Part 1: Amend California Code of Regulations, Title 

13, Sections 2430, 2433, and 2434 for Off-Road Large Spark-Ignition Engines. 

2. Proposed Regulation Order Part 2: Amendments to the incorporated “California 

Exhaust Emission Standards and Test Procedures for New 2001 and Later OffRoad Large Spark-Ignition Engines” (40 CFR, Part 86, Subpart A) 

3. Proposed Regulation Order Part 3: Amendments to the incorporated “California 

Exhaust Emission Standards and Test Procedures for New 2001 and Later OffRoad Large Spark-Ignition Engines” (ISO 8178) 

4. Proposed Regulation Order Part 4: Adoption of incorporated “California Exhaust 

Emission Standards and Test Procedures for New 2007 through 2009 ModelYear Off-Road Large Spark-Ignition Engines” (40 CFR, Part 1048) 

5. Proposed Regulation Order Part 5: Adoption of incorporated “California Exhaust 

Emission Standards and Test Procedures for New 2010 Model-Year and Later 

Off-Road Large Spark-Ignition Engines” (40 CFR, Part 1048) 

6. Proposed Regulation Order Part 6: Adoption of incorporated “California Exhaust 

Emission Standards and Test Procedures for New 2007 Model-Year and Later 

Off-Road Large Spark-Ignition Engines” (40 CFR, Parts 1065 and 1068) 

APPENDIX B: FLEET AVERAGE EMISSION LEVEL REQUIREMENTS 

1. Proposed Regulation Order Part 8: Adopt California Code of Regulations, Title 

13, Sections 2775, 2775.1, and 2775.2 for Large Spark-Ignition (LSI) Engine 

Fleet Requirements. 

2. Fleet Average Compliance Scenarios 

APPENDIX C: VERIFICATION PROCEDURE 

1. Proposed Regulation Order Part 9: Adopt California Code of Regulations, Title 

13, Sections 2780, 2781, 2782, 2783, 2784, 2785, 2786, 2787, 2788, and 2789 

for Verification Procedures for Retrofit Systems Verification Procedure, Warranty, 

and In-Use Compliance Requirements for Retrofits to Control Emissions from 

Off-Road Large Spark-Ignition Engines. 

2. Description of the Proposed Verification Procedures for Retrofit Emission Control 

Systems for Off-Road Industrial Engines