BOARD MEETING DATE: June 6, 2003
AGENDA NO. 38

Amend Rule 1193 – Clean On-Road Residential and Commercial Waste Collection Vehicles, and Authorize Execution of Contracts for Emission Testing and Analysis of Dedicated Natural Gas and Diesel Solid Waste Collection Vehicles.

SYNOPSIS:

Staff is proposing to amend the requirements for dual-fuel heavy-duty engines used in curbside waste collection vehicles. Rule 1193 currently provides a sunset date of July 1, 2003 for dual-fuel heavy-duty engines used to power waste collection vehicles. The proposed amendment is in response to recent in-use emissions testing of dual-fuel engines compared to dedicated diesel-fueled engines. Staff also proposes executing a contract with West Virginia University for emission testing of natural gas and diesel solid waste collection vehicles in an amount not to exceed $260,000, and with Engine, Fuels and Emissions Engineering for prescreening, transportation and analysis of natural gas and diesel solid waste collection vehicles in an amount not to exceed $50,000.

COMMITTEE:

Mobile Source, April 25, 2003, Reviewed

RECOMMENDED ACTION:

1. Adopt the attached resolution:
       a)   Certifying the Notice of Exemption (NOE) completed in compliance
             with CEQA (California Public Resources Code Section 21000 et.
             seq.); and
       b)   Amending Rule 1193-Clean On-Road Residential and Commercial
             Waste Collection Vehicles.
    
2. Authorize the Executive Officer to execute a contract with West Virginia University for emission testing of heavy-duty dedicated natural gas and new diesel solid waste collection vehicles for an amount not to exceed $260,000 from the Clean Fuels Fund (Fund 31).
    
3. Authorize the Executive Officer to execute a contract with Engine, Fuels and Emissions Engineering for prescreening, transporting, and analysis of heavy-duty dedicated natural gas and new diesel solid waste collection vehicles for an amount not to exceed $50,000 from the Clean Fuels Fund (Fund 31).

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Rule 1193 applies to public and private operators of fleets of 15 or more heavy-duty refuse collection vehicles. Heavy-duty refuse collection vehicles include solid waste collection (or curb-side collection) vehicles, transfer vehicles, and roll-off vehicles. Rule 1193 purchase requirements are now completely phased in, incorporating two implementation dates. As originally adopted, the first implementation date was July 1, 2001 and required refuse truck fleet operators that operate a fleet of 15 or more transfer and roll-off vehicles, or 50 or more solid waste collection vehicles, to purchase or lease alternative-fuel or dual-fuel heavy-duty vehicles when adding or replacing these vehicles. Dual-fuel engine technology utilizes an alternative fuel (typically natural gas) with a small amount of diesel fuel to initiate compression ignition. The second implementation date was July 1, 2002, requiring refuse truck fleet operators of 15 or more combined solid waste collection vehicles, roll-off vehicles, or transfer vehicles to purchase or lease alternative-fuel or dual-fuel refuse vehicles when adding to an existing fleet or forming a new fleet. The rule as adopted by the Board in June 2000 contained a sunset date of July 1, 2002 for allowing the purchase of dual-fuel solid waste collection vehicles as a compliance option.

On June 7, 2002, the Board considered amendments to Rule 1193 to address concerns regarding the potential emission benefits of dual-fuel-powered solid waste collection vehicles, as well as the potential need to continue allowing the purchase of dual-fuel-powered solid waste collection vehicles as a compliance option, based on input provided by various refuse truck fleet operators. To address both of these concerns, the Board amended Rule 1193 to extend the sunset date for the purchase or lease of dual-fuel-powered solid waste collection vehicles to July 1, 2003, as well as extended the date of the associated exemption language to July 1, 2004 if the fleet operation retrofits all existing 1995 and newer vehicles. The Governing Board, as part of the June 7, 2002 amendment, also directed staff to collect and evaluate in-use emission data relative to dual-fuel engine applications in curbside collection vehicles and compare this information with curbside collection vehicles operating entirely on diesel fuel and curb-side collection vehicles operating entirely on an alternative fuel, within a ten-month time frame.

The in-use emissions study (see Attachment E - Draft Staff Report) was accomplished by procuring comparable solid waste collection vehicles equipped with diesel, dedicated natural gas, and dual-fuel engines, and subjecting these vehicles to chassis dynamometer emission testing using duty cycles that reflect real-world operating conditions. The in-use study produced unusually high NOx emissions data for the dedicated natural gas refuse vehicles, inconsistent with emission values generated by CARB engine certification data for the engines powering these vehicles. It was subsequently determined that the high NOx emissions were caused by faulty turbochargers; specifically, the turbocharger wastegate was not performing properly. It was subsequently determined that the turbocharger and housing needed to be replaced.

Relative to the in-use emissions testing of dual fuel engines compared to their diesel counterparts, staff found that the dual fuel engines have about a 20 percent reduction in nitrogen oxide emissions compared to the diesel engines. However, based on the dual fuel engine certification data, dual fuel engines are expected to have about a 35 percent reduction in nitrogen oxide emissions.

Proposal

In response to the in-use testing results, staff proposes an amendment to Rule 1193 to extend the sunset date (and corresponding exemption provision sunset date) by one year for the purchase or lease of dual-fuel-powered solid waste collection vehicles as a compliance option. This extension would allow the purchase of dual fuel engines that are cleaner than their diesel counterparts. In addition, this extension will allow time for staff to emission test properly functioning dedicated natural gas-powered refuse vehicles. Upon Board approval, staff will initiate additional emissions testing of these refuse vehicles, with the intent to generate sufficient data to confirm whether the emissions performance of dedicated natural gas- and dual-fuel-powered solid waste collection vehicles are equivalent. This confirmation is necessary to address the dual-fuel refuse vehicle sunset date provisions in Rule 1193.

In recognition of a clean alternative fuel engine technology that was initially certified for the 2000 model year, though not yet commercially available in large numbers, staff also proposes to include pilot ignition heavy-duty (PIHD) vehicles (and a corresponding definition of PIHD vehicles) as an additional compliance option for the purchase of solid waste collection vehicles, rolloff vehicles, and transfer trucks. PIHD technology is a dual-fuel, diesel compression ignition technology that restricts the amount of diesel use to a maximum of 10 percent of the total fuel used on an energy equivalent basis. In addition, the pilot ignition technology does not rely on diesel fuel during idling. This is directionally an improvement over commercially available dual-fuel engines that may consume a significantly greater percentage of diesel fuel. A PIHD engine is presently undergoing certification review by CARB (according to the manufacturer for the 2003 model year) and is included as a compliance option in CARB’s adopted Public Transit Bus Fleet Rule and CARB’s proposed Diesel Particulate Matter Control Measure for On-Road Heavy-Duty Diesel-Fueled Residential and Commercial Solid Waste Collection Vehicles.

Public Process

One public consultation meeting was held on April 22, 2003. Representatives of natural gas engine and component manufacturers, fuel suppliers, and fleet operators primarily attended the meeting. Most meeting participants supported the proposed rule amendment to extend the sunset date by one year for dual-fuel-powered solid waste collection vehicles as a compliance option, as well as the addition of pilot ignition heavy-duty Vehicles as another compliance option. In addition, meeting participants supported the proposal to conduct additional in-use emission testing of solid waste collection vehicles, provided that the latest "clean diesel" technology was included in this emission testing. Finally, various fleet representatives noted operational problems with dual-fuel and dedicated alternative-fuel refuse vehicles.

Emission Reductions

At this time staff estimates that PAR 1193 would not have a significant impact on the air quality benefits of the rule as estimated in the June 2000 Staff Report on the adoption of Rule 1193. Staff anticipates that the emissions performance of dual-fuel engines in solid waste vehicle applications would be comparable to dedicated alternative fuel engines based on engine certification data. However, until the appropriate in-use emissions testing of dedicated alternative fuel vehicles is performed, staff is not in the position to recommend removal of the sunset provision in Rule 1193. In addition, with the introduction of pilot ignition heavy-duty vehicle technology as a rule compliant option, staff believes that affected fleet operators will have a greater choice of rule compliant vehicles, enhancing the air quality benefits of Rule 1193.

California Environmental Quality Act (CEQA)

The AQMD has reviewed the proposed project pursuant to state CEQA Guidelines §15002(k)(1). Since the project is an action taken by a regulatory agency to assure the enhancement of the environment and will not result in a degradation to the environment, the proposal is exempt from CEQA pursuant to CEQA Guidelines §15308 – Actions by Regulatory Agencies for the Protection of the Environment. A Notice of Exemption, in accordance with CEQA Guidelines §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 amendment to extend the sunset date on dual-fuel heavy-duty vehicles would provide greater choices of rule compliant vehicles to affected fleet operators. The cost of a dual fuel engine equipped with a particulate trap is less than the cost of dedicated alternative fueled engines at this time. The proposed amendment would also serve as a "bridge" to pilot ignition technologies that are anticipated to be commercially available in the near future. Since the pilot ignition technology is not currently commercially available, staff assumes that the cost of the pilot ignition engines would be similar to other dedicated alternative fuel engines. In conclusion, since on average the cost of dual-fuel technology with particulate traps is less than the cost of alternative-fueled technology, the proposed amendments are expected to result in savings to owners or operators of refuse collection vehicles.

Proposed Emission Testing and Prescreening of Heavy-Duty Vehicles

Staff proposes to contract with West Virginia University (WVU) to conduct the in-use emissions evaluation of at least 10 solid waste collection vehicles from existing fleets operating with the latest dedicated natural gas and certified clean diesel technologies. Emission testing will be conducted using WVU’s Transportable Heavy-Duty Vehicle Emissions Laboratory located in Riverside and will use the test cycle that most accurately simulates heavy-duty refuse collection vehicle operation. The cost estimate of emissions testing is not to exceed $260,000 and will be funded through the Clean Fuels Program.

In addition, staff proposes to contract with Engines, Fuels and Emissions Engineering (EF&EE) to perform vehicle prescreening and vehicle transportation operations. The test vehicles will be loaned to the AQMD by various existing fleets subject to Rule 1193 and transported to the testing site by the contractor. Prior to selecting a test vehicle, the contractor, a technical representative from the original equipment manufacturer (OEM), and AQMD staff will perform prescreening analyses to ensure each vehicle is operating in accordance with OEM specifications. The cost of prescreening and transportation is estimated not to exceed $50,000 and will be funded through the Clean Fuels Program.

Sole Source Justification

Section VIII.B.2. of the Procurement Policy and Procedure identifies four major provisions under which a sole source award may be justified. This request for this sole source award is made under provision B.2.d.: Other circumstances exist which in the determination of the Executive Officer require such waiver in the best interest of the AQMD. Specifically, clause B.2.d.(8): Research and development efforts with educational institutions, or nonprofit organizations; and B.2.d.(4): Level-of-effort expert consultation services.

There are two organizations that have the capability of conducting chassis dynamometer emissions testing in the South Coast Air Basin, the Los Angeles County Metropolitan Transportation Authority (MTA) facility operated by CARB and the West Virginia University facility located in Riverside, CA. Other facilities outside of the South Coast Air Basin capable of conducting such testing are located in northern California and various locations nationally. However, the cost to have vehicles selected from the refuse fleets operating in the South Coast Air Basin would incur more expenses. Staff proposes to utilize both facilities located in the South Coast Basin as part of the in-use emissions testing. Staff is in discussions with CARB staff to schedule time at the MTA facility. The MTA facility testing will be limited to a subset of the total vehicles tested. The MTA facility testing will provide information on the variability of testing vehicles using different testing equipment.

The proposed project will be conducted by West Virginia University, an educational institution, utilizing their Transportable Heavy-Duty Vehicle Emissions Laboratory. This laboratory is presently located in Riverside at the Ralph’s Grocery Distribution Center. Vehicle screening and transportation will be performed by Engine, Fuels and Emissions Engineering (EF&EE). EF&EE is uniquely qualified having vast experience with natural-gas heavy-duty vehicles throughout the world and possessing a unique portable emission analyzer system capable of measuring mass emissions on operating vehicles. The portable emission analyzer equipment and methodology system is known as RAVEM (Ride-Along Vehicle Emission system) and is validated with a heavy-duty chassis dynamometer. The prescreening process will help in the selection of vehicles that will be tested by WVU, and determine if potential test refuse trucks are operating in accordance with engine manufacturer specifications.

Resource Impacts

The total AQMD cost for the emission testing by WVU and EF&EE will not exceed $310,000.

The Clean Fuels Program, under Health and Safety Code Sections 40448.5 and 40512 and Vehicle Code Section 9250.11, establishes mechanisms to collect revenues from mobile sources to support projects to increase the utilization of clean fuels, including the development of the necessary advanced enabling technologies. Funds collected from motor vehicles are restricted, by statute, to be used for projects and program activities related to mobile sources that support the objectives of the Clean Fuels Program.

Recommendation

Staff recommends that the proposed amendment to Rule 1193 be adopted. The proposed rule amendments will increase compliance flexibility and result in potential cost savings to fleets. In addition, staff recommends that the Executive Officer be authorized to execute an agreement with West Virginia University for emission testing of heavy-duty dedicated natural gas and clean diesel solid waste collection vehicles for an amount not to exceed $310,000 from the Clean Fuels Fund (Fund 31).

Attachments

1. Summary of PAR 1193 Proposal
2. Rule Development Process
3. Resolution
4. Proposed Amendments to Rule 1193
5. Draft Staff Report on PAR 1193
6. Notice of Exemption

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