BOARD MEETING DATE: December 3, 2010
AGENDA NO. 29
REPORT:
Mobile Source Committee
SYNOPSIS:
The Mobile Source Committee met Friday, November 19, 2010.
Following is a summary of that meeting.
RECOMMENDED ACTIONS:
Receive and file.
Jane Carney, Acting Chair
Mobile Source Committee
Attendance
Acting Chair Jane Carney called the meeting to order at 9:06 a.m. Attending via videoconference was Committee Member Jan Perry (arrived at 9:16 a.m.). Chair Ronald Loveridge, and Committee Members John J. Benoit, Bill Campbell and Josie Gonzales were absent. The following items were presented:
INFORMATIONAL ITEMS:
Update on CARB On-Road and Off-Road Regulations
Henry Hogo, Assistant Deputy Executive Officer, provided an update on CARB staff activities relative to the changes to the on-road and off-road mobile source emissions inventories and proposed amendments to the statewide On-Road Truck and Bus Regulation and the statewide In-Use Off-Road Diesel Vehicle Regulation. CARB staff evaluated the combined impacts of the two regulations on affected fleets given the current economic recession. Based on updated on-road and off-road emissions inventories, CARB staff determined the level of remaining emissions in the two categories with full implementation of the existing regulations and compared those with the remaining emissions targeted in the 2007 SIP. The difference represents a margin by which CARB staff could propose regulatory relaxations to the existing regulations. For the South Coast Air Basin, this represents 62 tons/day of NOx equivalent emissions (CARB equated particulate emissions to NOx emissions based on the efficacy for NOx to produce particulates, which is a factor of 10 based on the 2007 AQMP air quality modeling).
Staff provided a summary of the changes to the off-road and on-road mobile source emissions inventories. Relative to the off-road mobile source emissions inventory, CARB staff indicated that the economic recession resulted in about a 50% decrease in emissions compared to the levels provided in the 2007 SIP and the other 50% is due to methodology and data assumption changes. There three major contributors to the methodology and assumption changes: off-road vehicle population (down by 26%); hours of use (down by 30%); and load factor (reduced 33% across all off-road vehicle types). With the changes in the methodology, data assumptions, and the impact of the economic recession, CARB staff estimated that the revised off-road emissions inventory would be about 71% lower (27.6 tons/day of NOx in 2014 compared to 96.1 tons/day provided in the 2007 SIP).
Relative to the on-road mobile source emissions inventory, staff believes that with the amount of new data, the revised on-road truck emission estimates are reasonable and more certain compared to the off-road emission estimates. CARB had conducted an origin-destination survey of heavy-duty trucks in 2008. In addition, the on-road truck population is more certain since trucks must be registered to operate in California.
CARB staff evaluated the on-road trucks based on: registration type (in-state vs. out-of-state); body type (tractor/trailer, single unit); vocation (agricultural, construction, drayage operation); and vehicle weight category (medium heavy-duty trucks with 26,001 to 33,000 lbs gross vehicle weight rating compared to heavy heavy-duty trucks with gross vehicle weight ratings greater than 33,000 lbs). CARB staff found that the economic recession has a 25% lowering effect on the heavy-duty truck emissions. Based on methodology and assumption updates, the on-road heavy-duty truck emissions are higher compared to the 2007 SIP emissions inventory (without the impacts of the economic recession). Overall, the on-road truck emissions for the South Coast Air Basin are comparable to the emissions estimated in the 2007 SIP (127.6 tons/day NOx compared to 131 tons/day in the 2007 SIP).
Staff indicated that there are uncertainty ranges provided by CARB for each of the factors and assumptions. Within the uncertainty range, staff believes that the off-road emissions could be higher by as much as 20 to 30%. However, CARB staff estimates are the best available given the available data. Staff indicated that with higher emissions, the 62 tons/day margin would be eroded. Staff provided comments to the CARB Board at their meeting on November 18, 2010, indicated that there is a need to be cautious with the use of the emissions inventories when proposing regulatory relaxations.
Staff provided an overview of the key proposed amendments to the Off-Road Diesel Vehicle Regulation. CARB staff is proposing to delay the first compliance date by four years to 2015; no longer requiring retrofitting off-road vehicles to meet rule requirements; to meet rule requirements off-road vehicles need to be turnover to the cleanest commercially available technologies (Tier 4 and 4i engines available beginning 2014); extending several credit provisions for early implementation and fleet downsizing due to the economy; and simpler compliance options for the smallest off-road fleets.
Relative to the On-Road Truck and Bus Regulation, CARB staff is proposing compliance based on vehicle weight. For on-road trucks with gross vehicle weight rating (gvwr) of 26,000 lbs or less, there would be no particulate filter retrofit requirements. However, beginning in 2015 through 2020, trucks that are 20 years or older must be replaced with engines that meet 2010 emissions standards. All trucks in this category must meet 2010 emissons standards by 2023.
For trucks with greater than 26,000 lbs gvwr, beginning in January 1, 2015, model year 1993 and older trucks must be replaced or have engines that meet 2010 emissions standards. CARB is proposing that by 2022, all pre-2007 trucks will be replaced or have engines that meet 2010 emissions standards. By 2023, all 2007 to 2009 model year trucks must meet 2010 emissions standards. In addition to the replacement schedule, CARB is proposing that model year 1998 to 2006 trucks and any model year 2007 to 2009 trucks that are not originally equipped with a diesel particulate filter, be retrofitted with diesel particulate filters between 2012 to 2014.
CARB staff is proposing a compliance option for fleets with 3 or less vehicles a choice to wait until 2014 to comply with the particulate filter retrofit. Fleets with more than three vehicles would be allowed to phase in the particulate filter retrofit to 2016. In addition, credits would be provided to exempt another diesel vehicle prior to 2017 for each particulate filter retrofit that occurred prior to 2011 or the fleet purchased a hybrid or alternative fueled vehicle.
With the proposed amendments, CARB staff indicated that there will be substantial relief to affected fleets prior to 2015. Fleets will still need to meet rule requirements to 2023. CARB staff indicated that by 2023, the emission reduction benefits would be the same for the proposed amendments and the existing regulations.
Staff discussed amendments to the Drayage Truck Regulation, the Tractor-Trailer Greenhouse Gas (GHG) Regulation, and the Large Spark Ignition (LSI) Fleet Regulation. Relative to the Tractor-Trailer GHG Regulation and LSI Fleet Regulation, CARB is proposing greater compliance flexibility if rule-compliant trailers or tires are not available (Tractor-Trailer GHG Regulation) and if retrofit kits are not available for LSI engines (LSI Fleet Regulation). In addition, CARB is proposing several administrative amendments for the two rules.
The proposed amendments to the Drayage Truck Regulation would remove the Phase 2 requirements to not allow model year 2004 to 2006 drayage trucks to operate out of ports and intermodal yards. These trucks would be subject to the On-road Truck and Bus Regulation. In addition, CARB is proposing to expand the definition of a drayage truck to include trucks that have gross vehicle weight ratings of 26,000 lbs and greater. The expanded definition would also cover trucks that perform “dray-off” operations. Currently, some drayage operators are using rule compliant trucks to enter the ports or intermodal yards to move container cargo. Once the truck is outside of the port or intermodal yard and within a few miles of the port or intermodal yard, the cargo container is transferred to a non-rule compliant truck and transported to its final destination. With the proposed expanded definition, the non-rule compliant truck would be subject to the regulation.
Staff is completing its review of the CARB proposed amendments and will prepare comments to CARB for its December 2010 Board hearing on the regulations. Staff indicated that the uncertainties associated with the emissions inventories may lead to over relaxation of the existing regulations and the CARB Board needs be cautionary in considering the proposed amendments. Even though the changes in the emissions inventory and air quality measurements indicate that the South Coast Air Basin will attain the annual PM2.5 air quality standard, controls will be needed shortly thereafter to meet the future air quality standards. Staff believes that the SOON Program should continue to meet the local commitment to achieve additional NOx emissions reductions. In addition, given that the proposed amendments rely on the revised emissions inventories, there is a greater need to incentivize early clean up of older vehicles and that greater flexibility is needed for fleets to access public funding assistance.
Ms. Jane Carney asked several clarification questions including whether the changes to the mobile source emissions inventory could be discerned in the air quality measurements. Staff indicated that some initial air quality modeling was performed to examine the impacts of the economic recession and the model results indicate that overall PM2.5 air quality levels will be lower in 2014. PM2.5 ambient measurements indicate lower concentrations due in part to the recession. Staff also commented that the changes in the inventories provide better modeling tools to evaluate future ambient air quality. A question was also asked if there are sufficient near roadway measurements showing changes in particulate air quality. Staff indicated that a special near-roadway monitoring was conducted in 2009 and focused on nitrogen dioxide.
U.S. EPA’s Notice of Proposed Partial Approval/Partial Disapproval of the South Coast PM2.5 Plan
Joe Cassmassi, Planning and Rules Manager, provided an overview of U.S. EPA’s Notice of Partial Approval and Partial Disapproval of the 2007 AQMP. Mr. Cassmassi indicated that the Plan’s emissions inventories and air quality modeling were approved; however, the attainment demonstration was disapproved primarily because the mobile source on-road truck and off-road equipment measures in CARB’s State Strategy had not been finalized and submitted to U.S. EPA as enforceable rules. In addition, U.S. EPA would not accept assignment of 10 TPD emissions reductions in 2014. The decision to disapprove the attainment demonstration automatically disapproved additional plan elements including: the RACT/RACM SIP’s, the RFP and transportation conformity budgets, and the request to extend the attainment date to 2015. Mr. Cassmassi discussed the impacts of the disapproval with regards to sanctions and potential Federal Implementation Plan actions. Barbara Baird, District Counsel, added background on the potential for sanctions and addressed a potential for a “conformity freeze” which would impact future transportation projects. Ms. Jane Carney questioned staff on the degree of District adoption of 2007 AQMP control measures and the extent of the remaining “commitment” to develop enforceable rules. Dr. Elaine Chang, Deputy Executive Officer, replied that the District had adopted rules to satisfy a high percentage of SIP emissions reduction commitments. Dr. Chang emphasized that U.S. EPA’s target of only 10 percent outstanding commitments compared to enforceable rules was an almost insurmountable hurdle for the agency to achieve, given the limited timeframes between plan adoption and U.S. EPA approval.
U.S. EPA will publish its decision in the Federal Register on Monday, November 22, 2010 and a 60-day comment period will commence. Staff plans to respond to the disapprovals, yet work with all of the agencies impacted to develop a solution to the issue. Mr. Cassmassi pointed out that a Mid-Course Correction analysis is due to U.S EPA in April 2011, to assess the status of achieving the National Ambient Air Quality Standard. The scope of that analysis may reflect a revision of the attainment demonstration, in light of new emissions budgets from CARB.
Councilwoman Jan Perry left at 9:50 a.m.
Rule 2202 Activity Report
Written report submitted. No comments.
Monthly Report on Environmental Justice Initiatives – CEQA Document Commenting Update
Written report submitted. No comments.
Other Business
None-
Public Comment
None
The meeting adjourned at 10:30 a.m.
Attachment (DOC, 50k)
Attendance Roster