January 1, 2013 represented a key compliance date for several CARB regulations:
CARB’s Portable Engine Airborne Toxic Control Measure (ATCM) required the first level of fleet diesel PM emissions to be met. Most levels of compliance were set at the Tier 2 emissions standard. Although the regulation allows the use of the actual PM certification value, which would be less than the standard, this date will affect many owners with Tier 1 diesel portable engines because in most cases, the PM levels for those engines will be greater than the fleet average requirements. Additionally, for many of the portable engines, especially those that are under 175 HP that cannot achieve enough engine temperature or the right NOx/PM ratio in the exhaust, there are no Diesel particulate Filter (DPF) solutions. Owners of these engines will be forced to replace this expensive equipment.
All on-road diesel vehicles > 26,000# GVWR with engines between 2000 and 2004 were required to do one of the following to be in compliance under the straight BACT requirements: 1) replace the vehicle with one that has a 2010 engine or later, 2) retire the vehicle altogether, 3) install a DPF, or 4) designate as low use (< 1,000 miles/year). January 1, 2012 already saw compliance for those > 26,000# GVWR vehicles with diesel engines between 1996 and 1999. There is an extension for compliance for those owners with 3 or fewer diesel vehicles > 14,000# GVWR. These owners would need to have their first of three vehicles fitted with a DPF or replaced by January 1, 2014; the second by January 1, 2015, and the third by January 1, 2106. If the owner only has 1 vehicle, the January 1, 2014 date applies. "Small Fleet" owners needed to register their vehicles to be in compliance and to be able to utilize this extension.
January 1, 2013 started the first "compliance year" for large off-road fleets (> 5,000 HP). Large fleets must either meet the NOx fleet average by January 1, 2014 or turn over at least 4.8% of their fleet HP. Turnover of fleets prior to January 1, 2013 would not be counted towards the 4.8% unless machines were repowered or retrofitted with a DPF.
All off-road diesel vehicle 25 HP and greater must now be labeled with an Equipment Identification Number (EIN) on both sides. CARB will be out in full enforcement to find those machines that are not labeled correctly.
January 1, 2013 also placed a ban for large off-road fleets on the purchase of machines with Tier 1 engines. However, until an EPA waiver is granted to California for this regulation, this ban cannot be enforced. A similar ban was placed on Tier 0 engines March 1, 2009 but it too cannot be enforced without the EPA waiver.
Other key 2013 reporting deadlines:
By January 31, 2013 owners must report under the on-road regulation. Reporting is only required for those fleets using the small fleet provision, the construction truck extension, the fleet averaging (phase-in) option, agricultural provisions, or any of the low-use provisions. Reporting reflects the fleet as of January 1, 2013. Those owners using the straight BACT method (replacement of retrofit by dates set by CARB) are not required to report, excepting the low-use or other exception vehicles.
By March 1, 2013 large off-road mobile diesel fleets must report their fleet compliance by affirmation through use of the Responsible Official Affirmation of Reporting (ROAR) form(s). The March 1, 2013 reporting reflects compliance with the regulation as of January 1, 2013. Since there have been no turnover requirements yet, the reporting is only an affirmation that all information reported through DOORS is accurate. Medium fleets (2501 HP - 5000 HP) start reporting March 1, 2016, and small fleets (2500 HP and less) start reporting March 1, 2018.
Also by March 1, 2013, for compliance with the portable engine ATCM, all owners must provide a report showing that all of the portable engines 50 HP and larger in their fleet meet the PM fleet averages. This includes those diesel engines registered in CARB's PERP program, and also those permitted in local districts. Reporting is in three categories: under 175 HP, 175 HP - 750 HP, and > 750 HP.
OFF ROAD MOBILE DIESEL REGULATION
The off-road mobile diesel regulation was placed into California law on June 15, 2008. Since that time owners have been required to report their off-road fleets to CARB and install Equipment Identification Numbers (EIN) on the reported machines. CARB is waiting for a waiver from EPA to implement the emissions reduction portions of this regulation. Presently, several elements of the regulation remain enforceable:
5-Minute Idling Restriction
Owners will be required to inform their operators that machines cannot idle for more than 5 minutes. Exceptions do apply. As of March 1, 2009, owners of Large and Medium fleets are required to have a written idling policy. For more information, click on CARB’s advisory.
Anyone selling off-road mobile diesel equipment in California must provide a written disclosure on their bill of sale. This disclosure is required whether you sell to a private party, auction house or broker. For more information, click on CARB’s advisory.
Vehicle Reporting and Labeling
All off-road mobile diesel equipment should have been reported in 2009. CARB uses an on-line reporting system DOORS (Diesel Off-Road On-Line Reporting System). For more information on CARB registration, click on DOORS Reporting. Once reported, each of these machines must be labeled. For more information, click on CARB’s advisory.
For more information, visit CARB's Off-Road Website.
ON-ROAD DIESEL VEHICLE REGULATION
In December 2008, CARB's Governing Board approved the on-road diesel vehicle regulation for private fleets (Truck and Bus Regulation). The regulation requires owners to install diesel particulate filters (DPF) to reduce particulate matter (PM) emissions, and to replace or retire vehicles to reduce NOx emissions. Separate regulations apply to on-road diesel vehicles used in municipalities, for solid waste handling.
Between January 1, 2012 and January 1, 2014 the Truck and Bus Regulation requires retrofits on diesel vehicles greater than 26,000 pounds Gross Vehicle Weight Rating (GVWR) with engines between the years of 1996 and 2006. Replacement of retrofitted vehicles would be required by January 1, 2020. Those vehicles greater than 26,000 GVWR and older than 1998 will be required to replace the vehicles between 2014 and 2017 with vehicles containing 2010 or later model year engines. CARB also provided relief for later compliance with vehicles less than or equal to 26,000 GVWR. There are also extensions provided for small fleets (3 or less vehicles), construction vehicles, and vehicles used for agriculture.
Like the off-road mobile diesel regulation, CARB can enforce the Sales Disclosure requirements, and reporting requirements. For more information, visit CARB's On-Road Website.
CARB’s has two portable equipment regulations. The Portable Equipment Registration Program (PERP) regulation provides for statewide permitting of portable engines and equipment to allow more flexibility to operate this equipment in multiple air districts within California. This permitting regulation covers all fuel types. Registration of portable engines into this program now requires the engines to meet the most stringent emissions level of Tier 4 Interim for diesel, and sets other requirements for spark-ignited engines. For more information, see CARB’s . CARB also has a regulation that affects the overall fleet particulate Matter (PM) emissions levels. This regulation is known as the Portable Engine Airborne Toxic Control Measure (ATCM). The first date of fleet PM emissions levels occurred January 1, 2013. This regulation also requires portable engines to meet a minimum Tier 1 emissions standard. With the exception of emergency and low-use portable engines (< 80 hours/year), use of Tier 0 engines is not allowed in the State of California. For more information on this portable engine regulation, see CARB’s Portable Engine ATCM website.
AGRICULTURAL OFF ROAD MOBILE DIESEL REGULATION
CARB intends on having an off-road mobile diesel regulation for the agricultural industry in place by the end of 2013. Although CARB has not set any implementation dates, they are currently setting up small groups of agricultural owners to discuss the proposed provisions of this regulation. Any interested parties should be contacting CARB staff to arrange for discussions either in a group or one-on-one. For more information visit the CARB AG website.
Quinn's product support representatives can assist you with information on the Caterpillar engines and equipment in your fleets. Quinn can also help you with solutions to keep you in compliance.
For off-road machine engine solutions, contact your Quinn Product Support Representative. If you do not know who your representative is, please call 559-891-6623.
We also provide solutions for your portable, stationary, and industrial engines. Contact your Quinn Power Systems Sales Representative. If you do not know who your representative is, please call 562-463-6078.
Understanding the multitude of complex state and local emissions regulations and how they affect your fleets or business operations can be difficult. We can help you determine what emissions regulations apply to your business and help you find solutions to keep you in compliance. For information call 562-463-6013.