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Diesel Retrofit Programs

Background

Following the identification of diesel particulate matter as a toxic air contaminant (TAC) in 1998, the California Air Resources Board (ARB) developed a comprehensive strategy to control diesel PM emissions. The “Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles”—a document approved by ARB in September 2000—set goals to reduce diesel PM emissions in California by 75% by 2010 and 85% by 2020.

This objective would be achieved by a combination of approaches (including emission regulations for new diesel engines and low sulfur fuel program). An important part of the Diesel Risk Reduction Plan are measures for various categories of in-use on- and off-road diesel engines, which are generally based on the following types of controls:

  1. Retrofitting engines with emission control systems, such as diesel particulate filters or oxidation catalysts,
  2. Replacement of existing engines with new technology diesel engines or natural gas engines, and
  3. Restrictions placed on the operation of existing equipment.

Once the Diesel Risk Reduction Plan was adopted, the ARB started developing PM emission regulations for a number of categories of in-use diesel vehicles and equipment. The regulations have mandatory character, requiring diesel engine operators to apply certain control measures, but in most cases include flexibilities to allow a choice of approach (the ARB regulations should not be confused with the rules by South Coast Air Quality Management District—adopted in 2000 and later invalidated by US Supreme Court—which attempted to ban the purchase of diesel vehicles, regardless of their PM emission level).

The general objective of the various regulations is to reduce diesel PM emissions to levels of below 0.01 g/bhp-hr, equivalent to the 2007 PM emission standard for new heavy-duty highway engines. Thus, all existing engines of PM emission levels higher than 0.01 g/bhp-hr are potential targets of the regulations.

Control Equipment Verification Program

To support diesel retrofit programs under the Diesel Risk Reduction Plan, the ARB has developed a verification program for Diesel Emission Control Strategies. The Verification Procedure [CCR 13, Sections 2701-2709] provides a way to evaluate the PM emission reduction capabilities and durability of the diesel emission control strategies to be used for retrofitting of in-use diesel engines.

Depending on their PM emission reduction capability—as demonstrated by laboratory emission testing—emission control equipment can be verified as Level 1, 2, or 3 strategy (Table 1). Optionally, strategies can be also verified for their NOx reduction effect.

Table 1
Verification Classification for Diesel Emission Control Strategies
PollutantReductionClassification
Verification for PM Emission Reduction
PM< 25%Not verified
≥ 25%Level 1
≥ 50%Level 2
≥ 85%, or
≤ 0.01 g/bhp-hr
Level 3
Optional Verification for NOx Reduction
NOx< 15%Not verified
≥ 15%Verified in 5% increments

In addition to the above emission performance, verified technologies must meet the following requirements:

  • Nitrogen Dioxide Emission Limit: The first version of the protocol included a post-control NO2 emission limit—defined as 20% (by mass) of the total baseline NOx emission—which was later suspended. A modified NO2 limit of 30% was introduced effective 2007, and of 20% effective 2009, applicable to both new and existing verifications. The modified limit is defined as the maximum percentage increase incremental over the baseline NO2 emission level. For instance, for an engine with a baseline NO2 fraction of 12%, it corresponds to total NO2 emissions of 42%/32% of the NOx, effective 2007/2009, respectively. Devices must be pre-conditioned before testing to remove any stored PM that could react with NO2.
  • Durability Demonstration: Manufacturers must demonstrate through a field or laboratory test that the required emission reduction can be still achieved after a certain period of operation. The required durability demonstration periods are listed in Table 2.
    Table 2
    Minimum Durability Demonstration Periods
    Engine TypeDurability Demonstration Period
    On-road50,000 miles or 1000 hours
    Off-road (including portable) & stationary1000 hours
    Stationary emergency standby engines500 hours
  • Warranty Requirements: Manufacturers must provide a warranty for the verified emission control device, covering both materials/workmanship and emission performance. The warranty must also cover the engine. Should an engine failure be caused by the retrofit device, the warranty must cover the full repair or replacement cost of the affected engine components. The required warranty periods are listed in Table 3.
    Table 3
    Minimum Warranty Periods
    Engine TypeEngine SizeWarranty Period
    On-roadLight heavy-duty, 70 - 170 hp, GVWR < 19,500 lbs5 years or 60,000 miles
    Medium heavy-duty 170 - 250 hp, GVWR 19,500 - 33,000 lbs5 years or 100,000 miles
    Heavy heavy-duty, above 250 hp, GVWR > 33,000 lbs5 years or 150,000 miles
    Heavy heavy-duty, above 250 hp, GVWR > 33,000 lbs, and the truck is:
    1. Typically driven over 100,000 miles per year, and
    2. Has less than 300,000 miles on the odometer at the time of installation
    2 years, unlimited miles
    Off-road & stationaryP < 25 hp, and constant speed engines < 50 hp with rated speeds ≥ 3,000 rpm3 years or 1,600 hours
    25 hp ≤ P < 50 hp4 years or 2,600 hours
    P ≥ 50 hp5 years or 4,200 hours

    If a manufacturer sells an ARB verified retrofit technology outside of California, the ARB mandates that the retrofit technology is sold with the mandated ARB warranty coverage.

Adopted Control Regulations

Adopted diesel PM control regulations include rules for:

  1. public transit agency fleets,
  2. solid waste collection vehicles,
  3. idling regulations & APSs,
  4. transport refrigeration units,
  5. cargo handling equipment,
  6. public fleets,
  7. commercial harbor craft,
  8. drayage trucks,
  9. truck and bus fleets (including private fleets),
  10. in-use off-road diesel vehicles,
  11. stationary & portable diesel engines,
  12. marine auxiliary engines.

Public Transit Agency Fleets

The public transit bus fleet rule was adopted in February 2000 and modified on several later occasions [CCR 13, 1956.2]. The regulation applies to urban buses, defined as vehicles powered by heavy heavy-duty diesel engines, capable of carrying 15 or more passengers, and intended primarily for inter-city operation. Under the rule, California fleet operators have to choose between a “diesel path” and an “alternative fuel path” for their future urban bus procurements. The alternative fuel path requires that 85% of buses purchased or leased each year through MY 2015 are fueled by alternative fuels. Transit operators who stay on the diesel path can purchase diesel fueled buses, but are required to follow a more aggressive emission reduction schedule. When the regulation is fully implemented, buses on both paths will produce the same near-zero emission levels.

The regulation provides numerous detailed provisions and schedules, which can be summarized as follows:

  • A NOx fleet average limit of 4.8 g/bhp-hr is effective from 2002.10 for both diesel and alternative fuel paths.
  • Ultra low sulfur diesel fuel (15 ppm wt.) is required from 2002.07.
  • The total PM emission from the fleet must be reduced by 85% relative to the emissions in January 2002. This requirement is phased-in by 2007 on the diesel path, and by 2009 on the alternative fuel path. The PM emission reduction may be achieved by introducing cleaner engines, or retrofitting existing engines with verified, Level 1, 2, or 3 emission control equipment.
  • New model year 2004-2006 diesel bus engines have to be certified to 0.5 g/bhp-hr NOx, 0.01 g/bhp-hr PM, 0.05 g/bhp-hr NMHC, 5.0 g/bhp-hr CO, and 0.01 g/bhp-hr formaldehyde emission standards. (A requirement for 2007-2009 bus engines meeting 0.2 g/bhp-hr NOx limit has been relaxed, and engines certified to federal standards were allowed.)
  • Zero emission bus purchase quota of 15% applies for fleets of 200 or more buses from 2008 on the diesel path and from 2010 on the alternative fuel path, through MY 2015.

Amendments have been proposed to expand the transit fleet rule to include smaller diesel and alternative fuel buses, commuter buses, and heavy-duty trucks owned or operated by transit agencies. The affected vehicles are called transit fleet vehicles and would be subject to a fleet average NOx limit and PM reduction requirement, phased in between 2007 and 2010.

Solid Waste Collection Vehicles

The rule “Diesel Particulate Matter Control Measure for On-Road Heavy-Duty Residential and Commercial Solid Waste Collection Vehicles” was adopted in September 2003 and became effective on 20 July 2004 [CCR 13, 2020-2021]. The regulation covers MY 1960-2006 engine on-road diesel-fueled heavy-duty residential and commercial solid waste collection vehicles with a GVW rating over 14,000 lbs. The implementation schedule starts in 2004 and continues through 2011. The regulation applies to garbage truck owners, as well as to municipalities that contract waste collection services.

The rule requires that the “best available control technology” is implemented according to a specified schedule. Three best available control technology options are available to truck owners:

  • To use a diesel engine, alone or in combination with a verified diesel emission control strategy, that is certified to the 0.01 g/bhp-hr PM emission standard,
  • To use an alternative fuel engine, or a heavy-duty pilot ignition (dual fuel) engine, or
  • To apply the highest level diesel emission control strategy verified by ARB for a specific engine.

Idling Regulations & APSs

Several regulations have been adopted to control idling emissions from heavy-duty engines:

  1. A control measure to limit school bus idling became effective in 2003 [CCR 13, 2480]. The rule requires a driver of a school bus, transit bus, or other commercial motor vehicle to manually turn off the bus or vehicle engine whenever they are within 100 feet of a school, and to restart no more than 30 seconds before departing.
  2. Commercial diesel vehicles with a GVWR > 10,000 lbs are subject to idling restrictions effective February 1, 2005 [CCR 13, 2485]. Affected vehicles are required to limit idling to no longer than 5 minutes under most circumstances.
  3. A rule to further limit idling of new and in-use sleeper berth equipped diesel trucks was adopted on October 20, 2005 (still pending approval by the Office of Administrative Law). The regulation consists of new engine and in-use truck requirements, as well as emission performance requirements for technologies used as alternatives to the truck’s main engine idling. The new engine requirements require MY 2008 and newer heavy-duty diesel engines to be equipped with a non-programmable engine shutdown system that automatically shuts down the engine after 5 minutes of idling or optionally meet a NOx idling emission standard of 30 g/hr. The in-use truck requirements require operators of both in-state and out-of-state registered sleeper berth equipped trucks to manually shut down their engine when idling more than 5 minutes at any location within California beginning in 2008.

The 2008 regulation also includes emission requirements for cab comfort devices, such as internal combustion auxiliary power systems (APS) or units (APU), and fuel-fired heaters. Performance requirements for these systems differ depending on whether the truck’s engine is a 2007 or later model:

  • Beginning in 2008, trucks with MY 2007 and later engines equipped with a particulate filter will be required to either route the APS’s exhaust through the particulate filter of the main truck engine or to retrofit the APS separately with a Level 3 PM control device.
  • Trucks equipped with MY 2006 or older engines may use a diesel-fueled APS without adding PM control devices.

Beginning in 2008, all 2007 and subsequent model year trucks equipped with fuel-fired heaters will need to comply with the fuel-fired heater emissions requirements specified in the Low Emission Vehicle Program to operate in California.

Transport Refrigeration Units (TRU)

The TRU regulation was adopted in 2003 and became effective from 10 December 2004 [CCR 13, 2477]. It applies to owners and operators of diesel fueled TRUs and TRU generator sets that are installed on trucks, trailers, shipping containers, or railcars that operate in the state of California (including out-of-state vehicles).

TRU units must meet in-use performance standards, shown in Table 4, by either:

  • Using a certified engine meeting the applicable nonroad emissions standards for all regulated pollutants and the in-use PM performance standard, or
  • Equipping the engine with the required Level of Verified Diesel Emission Control Strategy (VDECS).
Table 4
In-Use Performance Standards for TRU Engines
Emission CategoryEngine PM CertificationVDECS Retrofit
TRU engines < 25 hp
Low emission TRU (LETRU)0.30 g/bhp-hrLevel 2
Ultra low emission TRU (ULETRU)n/aLevel 3
TRU engines ≥ 25 hp
Low emission TRU (LETRU)0.22 g/bhp-hrLevel 2
Ultra low emission TRU (ULETRU)0.02 g/bhp-hrLevel 3

The engine certification levels in Table 4 correspond to the nonroad Tier 4 PM emission standards. Thus, the TRU regulation enforces Tier 4 PM emission levels on older in-use TRU engines, and ensures that in the long term particulate filters are also used on older engines below 25 hp (which will not use filters under the Tier 4 rule).

The TRU emission requirements apply to in-use engines older than seven years. Owners/operators must meet the TRU engine performance standards on the following schedule:

  • MY 2001 and older engines must meet LETRU standards by 31 December 2008, and ULETRU standards by 31 December 2015.
  • MY 2002 engines must meet LETRU standards by 31 December 2009, and ULETRU standards by 31 December 2016.
  • MY 2003 and later engines must meet ULETRU standards by 31 December of the seventh year past the unit’s model year (i.e., MY 2003 engines must meet ULETRU standards by 31 December 2010, MY 2004 by 31 December 2011, and so on).

As an alternative to meeting the in-use performance standards, an owner/operator may operate a TRU meeting one of several Alternative Technology options (e.g., fueled by alternative fuels).

Cargo Handling Equipment

In December 2005, the ARB adopted a rule to reduce emissions from mobile cargo handling equipment—including cranes, fork lifts, tractors, and yard trucks—that operates at ports and intermodal rail yards [CCR 13, 2479]. Effective 1 January 2007, the regulation calls for the replacement or retrofit of existing engines with ones that use Best Available Control Technology (BACT), to reach 2007/2010 on-road or Tier 4 nonroad emission standards.

Commercial Harbor Craft Regulation

In November 2007, the ARB approved a regulation to reduce diesel PM and NOx emissions from diesel fueled engines on commercial harbor craft (CHC) vessels [CCR 13, 2299.5][CCR 17, 93118.5]. The regulation, effective January 1, 2009, includes requirements for both new and in-use diesel engines used on CHC operating in regulated California waters. The regulation applies to all CHC vessels such as ferries, excursion vessels, tugboats, towboats, crew and supply vessels, work boats, pilot vessels, research vessels, emergency response vessels, barges, and commercial and charter fishing boats.

In-use requirements for ferries, excursion vessels, tugboats, and towboats include meeting US EPA Tier 2 or Tier 3 marine engine emission standards over a regulatory compliance schedule. Tier 4 is required for newly built vessels once standards come into effect. Best available control technology is required for all propulsion engines on newly built ferries.

Marine Auxiliary Engines

In December 2005, the ARB adopted a fuel quality rule for auxiliary engines used on oceangoing ships, such as cargo ships, cruise liners and other large vessels [CCR 13, 2299.1]. The rule applies to auxiliary diesel engines and diesel-electric engines operated on oceangoing vessels located within California waters, 24 nautical miles of the coast. The regulation requires the use of marine diesel fuels of reduced sulfur content:

  • 0.5% sulfur limit effective 1 January 2007,
  • 0.1% sulfur limit effective 1 January 2010.