Tuesday, February 10, 2015

NOx, Ozone and Soot! Oh My!

The industry is headed back down the regulatory road, whether we know it or not.
In California, a good portion of the industry is still recovering from the first round of CARB imposed truck turnover requirements. With recent developments it is likely that more is still to come. In fact, portions of the industry are going to be facing down a whole new set of requirements within the next 10-12 years, maybe sooner.
With the imminent lowering of the Federal Ozone standard and most recently the SCAQMD estimating that it will not be able to meet 2015 PM standards, the industry is going to again be brought into the discussion for additional emissions reductions to help meet state, federal and local standards. In all honesty and speaking frankly, they never left the discussion or in other words, no rest for the weary.

The on-road sector has had its share of regulations thrown at it, but no one can stop the revolving dunk tank that has become the suite of diesel rules. Just when the industry is drying out, a whole new set of technologies are lining up. Both CARB and the SCAMD have made no secret about offering a lower optional NOx standard to engine manufacturers in order to allow access to incentives for Natural Gas engines that meet a tighter NOx standard. Not to mention efforts in the ports of LA and Long Beach to electrify or hybridize truck movements in and around the port.

Distribution centers in California are also being looked at to help further define new mediums for accelerated truck turnover in California. Facility caps are currently being considered in the “back to the drawing board” freight efficiency measure coming from CARB.  South Coast is also pushing for facility caps, and in fact has been for many years due to immediate and overdue needs for NOx and PM reductions. CARB’s facility cap requirement would limit the amount of emissions (including GHG) that could be generated by activities at covered locations throughout the SCAQMD region and eventually throughout the state.
The engine platform of the vehicles entering the facility will have usage calculated and emissions will be given weight. Each vehicle will contribute to an overall level that CARB will seek to cap; the cleaner the engine, the smaller the contribution. Facilities will need to monitor truck traffic and quite possibly limit trips, unless a cleaner engine platform is utilized.

Driving these requirements are interim dates for achieving emissions standards set by the federal government (See  “You Want NOx With That” Click Here ) that need to be met in the SCAQMD in 2020. The more recent 2015 deadline for PM in SCAQMD, may possibly be missed, which will force the District to look for additional reductions. This may include more burn limitations and an aggressive enforcement effort, but time will tell.

Lucky (if you want to call it that) for the private on-road trucking fleet, the SCAQMD has no authority for regulating mobile source emissions from the private sector. There are some limited exceptions; however, SCAQMD can’t propose an in-use truck rule. They can go after the ports and they may be able to go after distribution centers under a facility cap, especially if the diesel magnet source argument holds. But, as always, time will tell.
In the meantime the EPA will tighten the standards for Ozone across the country, as the agency is under court order to adopt a plan by October 2015.  Under this new Ozone plan, California will have until 2037 to attain the new 70-65 ppb standard. The rest of the country will need to meet the standards in 2025.

The 2037 date, although well into the future, will no doubt push California to look for more NOx reductions from the trucking fleet. NOx is a precursor to Ozone, so if you reduce NOx, Ozone should follow. For Heavy Duty trucking, that means low NOx alternative fuel platforms or quite possibly a mandate for the Heavy Duty electric hybrids of myth and legend.

Make no mistake; the discussion is far from over. Pay close attention to the “man behind the curtain” as the great and powerful Golden State is just getting warmed up. Stay Tuned!



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