Monday, June 24, 2013

You want NOx with that?

The South Coast Air Quality Management District looks to trucks and burger joints to achieve federal air quality standards.

The recently approved Air Quality Management Plan in the South Coast air basin is calling for immediate sort term localized reductions to meet 2014 PM2.5 standards and long term truck turnover goals for control of directly emitted Oxides of Nitrogen (NOx) in order to achieve a fast approaching 2020 federal standard for Ground Level Ozone. 

In case you are wondering what NOx is or does, a brief, crude explination follows;  NOx reacts in the atmosphere with sunlight to sunlight form Ozone, which is a precursor to smog, so controlling NOx at the one of the sources (tailpipes) will help s to reduce the formation of Ozone and subsequently, smog.  Without going into a lengthy discussion about air quality chemistry to justify the rather simple explanation above, suffice it to say, for the purposes of this article; if the government says it, it must be true. 

As is the same in every state, California finds itself under the ever-tightening ambient air quality standards of the Federal EPA. More than 100 rules have been written in the Golden State to curtail the burning air of yore resulting in the decline of restricted activity days statewide, with the south coast region enjoying more clearer days more often. Many may find it hard to believe that just over two decades ago, a visitor to Southern California would not even be able to see the 8,000 foot mountain ranges that border the region. The shroud of smog would hide the mountains only having their majesty revealed after strong winds or a downpour of the ever-elusive rain.

Of course it is not enough, as is the battle with Air Quality in California and most industrialized, highly populated regions. The state of California will not stop until Carbon emissions are reduced and the harmful pollutants associated with the heavy-duty transportation sector become part of a bygone era.

In the meantime, the SCAQMD is taking matters into their own hands with a comprehensive and aggressive plan to meet the Federal Air Quality guidelines. As the next few months ware on, we can expect specific details to emerge on how implementation is going to shape up. Incentives for cleaner engine certifications are being considered and the District hopes to entice end users with incentive monies towards the purchase of new technology that currently does not commercially exist for the heavy duty sector.

The region as a whole will benefit from these and other measures outlined in the AQMP, but one particular region within the basin, (outside the San Pedro Port Complex) Mira Loma, will be targeted for reductions above and beyond what is currently being controlled. Businesses in Mira Loma, can expect tightening standards on almost any type of smoke. Including the smoke coming from the char broiled burger joints that dot the landscape of storied southern California.

Mira Loma also shares the designation of being home to some of the largest distribution centers in the region, thousands of trucks travel throughout the roadways on a daily basis to service these facilities. In order to meet the Federal guidelines and beyond, the SCAQMD is endeavoring to have several thousand of those trucks replaced with zero or near zero emission technology over the next ten years to achieve the needed Ozone reductions by practically eliminating NOx from the tailpipe.

Although the District has limited authority over mobile sources and will be hard pressed in forcing any direct change on a local level, there is always the threat of additional regulation or at least targeted enforcement from the State. Even though most attention is being paid to Carbon reductions through the newly minted Cap and Trade program, federal air quality targets are not getting any looser. Standards will need to be met or Federal highway funding for California will be frozen, so continued attention will be paid to these types of reductions now and well into the future. 

This is one reason why it is important to maintain a constant surveillance of regulatory entities in California, because, as goes California, so goes the Nation....and contrary to the popular consensus for most who live outside of California, the state will not be breaking off into the Pacific Ocean any time soon; so we might as well get used to it.

Wednesday, June 5, 2013

CARB Conundrum: Just When You Thought it was Safe To Go Outside

Upgrades are coming...Upgrades are coming!!!!
The diesel user industry in California is no stranger to regulatory efforts directed at emissions reductions. Serious air quality challenges have plagued regions of California for decades and mobile emissions sources have been the largest part of the emissions pie for many years. Because of this, California has led the charge on implementing regulations to control mobile source emissions from gasoline powered cars and trucks as well as more recent efforts aimed at controlling diesel emissions from the heavy duty engines that power the transportation sector.

Throughout the years, these recent efforts and legacy programs have helped local air districts in highly populated, geographically challenged regions achieve drastic improvements in Air Quality with limited end-user resistance and little political opposition.
These efforts have propelled CARB into the spotlight as the “preeminent” air quality regulatory agency in the world. More recent than the catalytic converter and CARB diesel, California has passed several multi-billion dollar rules aimed directly at diesel users in California. Waste collection vehicles, municipal fleets, drayage trucks and refer engines have already fallen before the regulatory guillotine with emissions cuts from these vehicles reaching up to 90%.
 The two flagship diesel regulations are aimed at heavy duty, off-road equipment and heavy duty, on-road equipment; over one million of these pieces of heavy metal operating in California are under regulatory scrutiny. The off-road regulation hasn’t gotten final clearance from the EPA yet, but the on-road regulation has been passed, implemented and is now being enforced.  The trucks that bring everything from toothpaste to tube-socks in California all must fall within specific guidelines. In fact, all diesel-powered trucks over 14,000 pds. GVWR are currently under regulation to replace with 2010 emissions technology in the next 10 years. In the interim, and as of January 2012, any truck operator who has a 1996 – 2004 engine in any truck in their fleet must have a Level 3 Particulate Matter control device, unless they have registered for one of the many exemptions to the current requirements. 
 Most folks who have been around these regulations will know these facts like the back of their hand. CARB has been workshopping and training end users since 2006, and despite strong opposition from certain sectors of the fleet, the regulation is moving ahead swiftly and in fact, it is picking up speed.
 In its second year, the On-Road Truck and Bus Rule, the first of its kind in the nation and in its entirety, the most complex, restrictive emissions program for heavy duty trucking in the world, will force thousands of truck owners to upgrade their trucks or face stiff penalties that may total up to $10,000 per day. The exemptions, although some more complicated than others, offer a way for fleets to comply without meeting the direct schedule.

There are considerations for smaller fleets with 3 or fewer trucks over 14,000 GVWR, as well as a phase in schedule for larger fleets, mileage and model year restrictions for vocational fleets and a separate schedule for trucks operating exclusively in specific counties, all require reporting and all expire within the next few years.
On January 1, 2014, a major exemption for small fleets (3 or less trucks) runs out. This means that the over 100,000 single, two and three truck operators registered in California and coming into California from all over the country are facing an upgrade requirement at the end of 2013. What this also means is that anyone who dispatches one of these heavy duty diesel vehicles in California or into California after 2014 will be subject to penalties if a non-compliant vehicle is found; no mater whose authority they are operating under.
 Although only California based brokers are subject to direct penalties under this regulation, any motor carrier based anywhere will be caught up in the regulatory web and fined, potentially for each dispatch going back to the beginning of 2012. CARB has already levied heavy fines against drayage operators who dispatched non-compliant vehicles to covered Intermodal facilities over the past 3 years and just levied a $300,000 fine against a fleet for engaging in dray-off near the Mexican border. Proof in point that no one can escape the regulatory gauntlet; if you are operating in California, you must meet the standards. 
 To hammer home their authority where they need it, CARB has a couple of different measures at their disposal. One that allows them to deny registration at time of renewal through California DMV if a fleet has not paid their CARB related fines and another, in conjunction with CHP that allows them to impound vehicles that have cancelled registration because of outstanding violations. CARB can even levy an unfair business practices lawsuit against violators if the infraction is serious enough. When they find you, they will fine you, and as many California diesel operators can attest, CARB settlements instruct you on how much you will need to pay in order to clear the citation; it is not really a negotiation, they settle on an amount and you pay it. The fine amount is of course in addition to the additional capital required to upgrade the equipment to meet the standards; a double edged pendulum for anyone who gets caught operating or dispatching non-compliant equipment.
 With renewed debate surrounding model year registration bans that are surfacing from the legislative scrap heap, the industry will continue to be faced with increasing compliance costs as standards and restrictions keep rolling in. Active engagement in the requirements is necessary to minimize the risk that all transportation businesses face when turning miles in the Golden State. Although the skies in California are getting clearer, the industry can expect more hazy insinuations from regulators regarding zero-emission freight corridors and sustainability plans that seek additional reductions from the on-road diesel sector. The efforts around emissions reductions are far from over, the sky’s the limit, no matter how clean (or dirty) it gets.
Matt Schrap is President of California Fleet Solutions (CFS) and VP of Government Programs for Crossroads Equipment Lease and Finance. CFS and Crossroads are the trusted source for CARB regulatory information for fleets operating in and out of California.

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