South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: June 7, 2002 AGENDA NO. 37
Amend Rule 1193 – Clean On-Road Residential and Commercial Waste Collection Vehicles
SYNOPSIS:
Staff is proposing an amendment to the sunset date of July 1, 2002 to allow the acquisition of dual-fueled heavy-duty engines for use in waste collection vehicles for an additional year. The proposed amendment is based on recent submittals by dual-fuel engine manufacturers certifying that dual-fuel engines that operate primarily on an alternative-fuel will continue to do so in a "stop-and-go" refuse collection duty cycle.
COMMITTEE:
Mobile Source, April 26, 2002, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the Notice of Exemption (NOE) completed in compliance with the CEQA (California Public Resources Code Section 21000 et. seq.); and
- Amending Rule 1193 – Clean On-Road Residential and Commercial Waste Collection Vehicles
Barry R. Wallerstein, D.Env.
Executive Officer
Background
On June 16, 2000, the AQMD Board adopted Rule 1193 – Clean On-Road Residential and Commercial Waste Collection Vehicles. This rule requires public and private refuse collection fleets with 15 or more refuse collection vehicles (refuse trucks) operating in the District to acquire alternative-fueled or dual-fuel powered vehicles when procuring or leasing these vehicles. The rule defines three types of refuse trucks: (1) solid waste collection vehicles (or curbside collection vehicles), which collect waste using manual or automated front, side, or rear loaders, (2) rolloff vehicles, which transport waste containers such as open boxes or compactors, and (3) transfer vehicles, which transport waste using a tractor/trailer combination from a processing or transfer station. Dual-fuel vehicle basically means a vehicle equipped with a diesel engine that uses an alternative fuel, such as natural gas, in combination with a small amount of diesel to initiate combustion.
Rule 1193 currently applies a sunset date of July 1, 2002 for the purchase of leasing of dual-fuel curbside collection vehicles. At the time of rule development, information on first generation dual-fuel engines operating in a "stop-and-go" duty cycle, typical of curbside collection vehicles, indicated that the engines may not operate primarily on the alternative fuel. In addition, the early generation engines had the capability of running on diesel fuel only if the operator desired so. The manufacturer/developers of dual-fuel engine technology indicated that they were in the process of developing next generation engines that would operate primarily on the alternative fuel. For the 2001 and 2002 model years, specific dual-fuel engine models were certified by CARB that were designed by the engine developer to maintain alternative-fuel operation during a "stop-and-go" duty cycle. The recent CARB certified engines are not capable of running on diesel fuel alone at full capacity without extensive costly modifications to the engine components. In addition, such modifications would be considered tampering under CARB’s certification and would be subject to enforceable actions. For these reasons, staff initially recommended an amendment to Rule 1193 to delete the sunset provisions for dual-fuel engines, as well as other minor rule language modifications.
Staff received public input supporting staff’s proposal to remove the sunset date. However, staff also received comments that the sunset date should be extended and that additional in-use emissions testing be conducted to determine the actual NOx and PM emission levels associated with the dual fuel engines when they are operating in a "stop-and-go" cycle. After such studies are completed, staff would evaluate whether the sunset date would be removed. After the discussions of this item at the April 26, 2002 Mobile Source Committee meeting, the Mobile Source Committee suggested that staff consider preparing alternative language that would extend the sunset date by one year for the full Governing Board’s consideration.
Proposal
Staff’s Proposal as of May 3, 2002
Staff initially recommended that the sunset date provision in Rule 1193 be removed and provided the Board with a staff report on PAR 1193 at the Board’s May 3, 2002 meeting. Staff proposed a rule amendment to remove the sunset date of July 1, 2002 under subparagraph (d)(1)(B) of Rule 1193, allowing the continued future use of dual-fuel engines in solid waste collection vehicles. This initial recommendation was based on the current demonstration within the framework of the Carl Moyer Program and separate certification of an engine family to substantiate 85 percent alternative fuel use for solid waste collection vehicles.
In addition to the preceding, existing rule language associated with the July 1, 2002 sunset date is proposed for deletion that extends the July 1, 2002 sunset date by one year provided that fleet operators retrofit existing 1995 and subsequent model-year refuse fleet vehicles with particulate matter control devices [Paragraph e(6)]. The proposed amendment also modifies the definition of dual-fuel heavy-duty vehicle to specify that (1) dual-fuel vehicles meet optional NOx or combined NOx plus non-methane hydrocarbons (NMHC) emission levels, which are considered to be comparable with corresponding emission levels found in alternative-fueled vehicles, and (2) particulate matter (PM) emission reduction levels for dual-fuel engines used as a solid waste collection vehicles be as clean as their diesel counterpart when a CARB verified PM Control device is installed. These modifications to the definition are being proposed to take advantage of the certification of the dual-fuel engine families (1PSXH0629E6K and 2PSXH0629E6K) to an optional NOx emission standard and verification of PM control devices for a substantial number of diesel heavy-duty engine models. Finally, a definition of "Approved Control Devices" is being added to ensure that these devices are CARB approved and properly installed. This is to ensure that real and durable emission reductions result from the use of these devices in refuse vehicle applications.
Alternative Proposal
In response to concerns raised by the public that the dual-fuel vehicle in-use emissions might be much greater than their dedicated alternative fuel counterparts, at its April 26, 2002 meeting, the Mobile Source Committee suggested that staff consider development of an alternative proposal that would extend the sunset date by one year so that staff can adequately evaluate the in-use emissions associated with dual-fuel engines. Staff prepared the draft alternative language (provided as Attachment E) that would extend the sunset dates and this language serves as an alternative to staff’s proposed amendments provided in the May 2002 Set Hearing package [Agenda Item No. 2(B)]. The relevant changes are in Paragraphs (d)(1)(B) and (e)(6) of the draft language. The other changes are the same as that provided in the Set Hearing Package.
Staff Recommendation
Since the May 2002 Set Hearing package was released, staff has been further reviewing public comments on the in-use emissions of dual-fuel engines. Staff received some limited information regarding the assumptions used in calculating the emission levels used in the certification of the dual fuel engines in a refuse collection mode. The manufacture/developer data indicate that the dual fuel engines are operating on about 70 percent alternative fuel. In addition, the manufacturer/developer indicate that in the curbside collection mode (i.e., stop-and-go), NOx emission levels are higher than the overall cycle which includes city/freeway driving and idling modes. However, the overall cycle emissions are used in the certification of the dual fuel engines. As such, staff believes that further emissions testing is warranted to fully understand the emissions associated with the dual-fuel engines. Furthermore, in-use emissions testing should be performed in a side-by-side comparison between dedicated diesel refuse vehicles and dedicated alternative fuel refuse vehicles. Therefore, staff is recommending that the Board adopt the alternative language provided in Attachment E as the staff’s recommended proposal at this time. In addition, with the Board’s approval, staff would proceed to conduct in-use emissions testing of refuse vehicles powered by conventional diesel fuel, dual-fuel, and natural gas.
Public Process
One public workshop was held on March 27, 2002. Representatives of engine manufacturers, environmental groups, and fleet operators primarily attended the workshop. Most workshop participants supported the initial proposed rule amendment to remove the sunset date, as they believe that the continued use of dual-fuel technology in solid waste collection vehicles would help lower the cost of rule implementation. The most significant comments against the proposed amendment were (1) the potentially higher emissions of dual-fuel engines versus their dedicated alternative fuel counterpart, (2) the potential negative economic impacts that could be experienced by competitors to the dual-fuel engine technology, and (3) further in-use emissions testing regarding dual fuel engine usage in the stop-and-go mode is needed and that the sunset date could be extended to allow for such testing. With regard to the first concern, staff’s response was that there are protections in the rule language which assure that dual-fuel engines achieve comparable emission levels relative to dedicated alternative-fuel engines. In response to the second concern, it would be difficult to speculate about the potential negative economic impacts of the sunset date removal since a number of factors besides cost determine the type of vehicle that is purchased by the affected fleet. Lastly, relative to the third concern, staff is now proposing to extend the sunset date by one year rather than removal of the sunset date.
Emission Reductions
At this time staff estimates that PAR 1193 would not have a significant impact on the air quality benefits of the rule. Staff anticipates that the emissions performance of dual-fuel engine in solid waste vehicle applications would be comparable to dedicated alternative fuel engines.
California Environmental Quality Act (CEQA)
The SCAQMD has reviewed the proposed project pursuant to state CEQA Guidelines §15002(k)(1). Because the proposed amendments to Rule 1193 would not adversely affect air quality, it can be seen with certainty that there is no possibility that the proposed project in question has the potential to have a significant adverse effect on the environment. Thus, the proposed project is exempt from CEQA pursuant to CEQA Guidelines Section 15061(b)(3) - Review for Exemption. A Notice of Exemption, in accordance with CEQA Guidelines Section 15062, will be prepared for the proposed project and will be filed with the county clerks immediately following the adoption of the proposed amendments to the rule.
Socioeconomic Assessment
The proposed amendments would delay purchase of alternative-fueled vehicles by allowing continued future use of dual-fueled engines. On the average, dual-fueled engines with PM10 trap would cost less than alternative-fueled vehicles. Therefore, the proposed amendments are expected to result in savings to owners or operators of refuse collection vehicles.
Recommendation
Staff recommends that the proposed amendment to Rule 1193 be adopted. The proposed rule amendment will increase compliance flexibility and thus result in potential cost savings to fleets that prefer to use the dual-fuel engines in solid waste collection vehicles.
Attachments (1,799 KB)
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