Draft Diesel Truck Engine Rules outreach effort reaches World Ag Expo audience

At the World Ag Expo in Tulare this week, agricultural organizations, including CWA, initiated a broad information campaign to increase awareness among farmers, ranchers, truck operators and truck engine manufacturers about the proposed regulations that would require the replacement or retrofitting of all diesel trucks over 14,000-pound gross vehicle weight, including those trucks used in on-road farm-related activities. 

The California Air Resources Board’s proposed rule calls for a two-phase approach that could ultimately impact about 400,000 in-state, on-road diesel vehicles. Phase 1 requires trucks to have a 2007 model or newer engine, or meet the emissions level of a 2007 engine. Phase 2 requires trucks to have a 2010 model or newer engine, or meet the emissions level of a 2010 engine. Truck emissions must be reduced according to a schedule that follows engine model year and a compliance deadline, the first one being Dec. 31, 2010 for truck engines older than 1998.

The only exemptions to the rule are:

·          Pick-ups and other vehicles for non-commercial use, w/ GVWR<14,000 lbs

·          Off-road vehicles

·          “Low use” vehicles (operate less than 100 hours and 1000 miles per year)

·         “Mileage Exempt Vehicles” are limited to heavy duty (HD) vehicles with a GVWR greater than 33,000 lbs operating anywhere in the state with less than 7,500 miles and 250 hours per year and requires installation of a particulate matter retrofit device.  Owner operators of these HD diesel trucks who live in the counties of Alpine, Colusa, Del Norte, Glenn, Humboldt, Lake, Lassen, Mendocino, Modoc, Monterey, Plumas, San Benito, San Luis Obispo, Santa Barbara, Santa Cruz, Shasta, Sierra, Siskiyou, Trinity, Tehama, and Yuba may drive the HD vehicles without a mileage limitation but they must only operate in these counties and they must still install a particulate matter retrofit device.

 

The World Ag Expo served as the perfect venue to reach farmers and agricultural-related businesses that will be impacted by the proposed rules. Although some changes have been made in the proposed rule, it still proposes actions that are far more aggressive than the agricultural economy can support. The agricultural industry will continue to push for revisions that can make these onerous rules more realistic with the technology that is available and without crippling the state’s economy.

 

Attached is an assessment of the issue prepared by the Fresno County Farm Bureau that was used at the World Ag Expo as well as across the state for discussion purposes.

 

Judy Case Denied ARB Board Position

Judy Case, a Fresno County Board of Supervisor, San Joaquin Valley Air Pollution Control District Board Member and Registered Nurse, failed Senate confirmation to the California Air Resources Board last month.  Governor Schwarzenegger appointed Case to the position last year.  Senator Dean Florez mounted a successful campaign before her confirmation to have her ousted.  She has two months from the confirmation vote to vacate the position.  No word on who will next be appointed to the position.

 

Air Resources Board’s Diesel Truck

 and Bus Rule - 2008

 

ISSUE: The California Air Resources Board’s (ARB) “Proposed Regulation for In-use On-road Heavy-Duty Diesel-Fueled Vehicles” threatens the California economy and agricultural industry.

 

ARB PROPOSED TRUCK EMISSION RULES

A statewide proposal to require older diesel vehicles to be phased-out will have a major impact on California’s economy, especially farms and other transportation-related components of the agricultural sector.  The proposal, as written by ARB staff, mandates that older diesel on-road truck engines be either upgraded and/or replaced to help reduce emissions.

 

All diesel trucks and fleets operating within the state with a gross vehicle weight rating greater than 14,000 lbs would be affected.  (GVWR is the maximum allowable total weight of a road vehicle or trailer that is loaded, including the weight of the vehicle itself plus fuel, passengers, cargo, and trailer tongue weight.)  A preliminary estimate of vehicles affected includes over 400,000 in-state registered trucks and 1.2 million out-of-state trucks that operate within California.

 

The proposed rule would require that truck emissions be reduced to meet the following:

Phase 1 – Trucks must be a 2007 model or newer truck, or meet the emissions level of a 2007 truck;

Phase 2 – Trucks must be a 2010 model or newer truck, or meet the emissions level of a 2010 truck. Truck emissions must be reduced according to the following schedule:

 

Phase 1
Engine Model Year	Compliance Deadline as of December 31
Pre-1998	2010
1998 – 2002	2011
2003 – 2004	2012
2005 and newer	2013
Phase 2
Pre-2004	2017
2004 - 2006	2018
2007	2019
2008	2020
2009	2021

 

The only exemptions to the rule are:

        Pick-ups and other vehicles for non-commercial use, w/ GVWR<14,000 lbs

        Off-road vehicles

        “Low use” vehicles (operate less than 100 hours and 1000 miles per year)

        “Mileage Exempt Vehicles” are limited to heavy duty (HD) vehicles with a GVWR greater than 33,000 lbs operating anywhere in the state with less than 7,500 miles and 250 hours per year and requires installation of a particulate matter retrofit device.  Owner operators of these HD diesel trucks who live in the counties of Alpine, Colusa, Del Norte, Glenn, Humboldt, Lake, Lassen, Mendocino, Modoc, Monterey, Plumas, San Benito, San Luis Obispo, Santa Barbara, Santa Cruz, Shasta, Sierra, Siskiyou, Trinity, Tehama, and Yuba may drive the HD vehicles without a mileage limitation but they must only operate in these counties and they must still install a particulate matter retrofit device.

 

REGULATORY COSTS

ARB’s timetable for implementing the proposal is far more aggressive than the agricultural economy can support.  Agricultural equipment, including trucks, have much longer life spans than most other industrial equipment because of the seasonality of agriculture (typically used for short spans of the year).  In addition, agricultural investment returns are typically low, making it difficult to buy newer equipment.  Not withstanding, agriculture will pay for this rule twice: first for its own new/retrofitted trucks; and second, for the cost of suppliers/haulers to buy/retrofit their trucks.  Suppliers and haulers can just charge more for their services and tax on a surcharge.  Farmers and ranchers cannot pass along the cost of this or any other regulation.  Unlike any other commodity, agricultural commodities are in the class of price-takers, not price-makers.

 

2004-07 year engines may be able to be retrofitted at a cost of $15,000-35,000 per truck, assuming current prices stay fixed, but they would be mandated to replace the engine again based on Phase 2 standards.  The retrofits can be very difficult to maintain and are problematic because the ingredients they collect are considered hazardous material.  This is yet another new burden on farmers and ranchers.

 

Most retrofitted engines older than 2004 cannot meet the required standards, thus a 2004-07 powered truck would have to be purchased, plus retrofitted to meet the 2007 engine standards.  Many of agriculture’s trucks are uniquely specialized for farm work, which additionally increases the cost of the replacement vehicle.  Replacement vehicle costs will vary sharply, but for most the cost range will likely be $50,000-300,000.  Conservatively, this rule is estimated to cost transporters in the state $25 billion.

 

AGRICULTURE’S SOLUTION

Agriculture is working to educate ARB on how the proposal would impact operations by outlining the major concerns on behalf of farmers, ranchers and agricultural business owners and offering alternative measures that will help accomplish the goal of cleaning California’s air without unreasonably forcing many in agriculture out of business.

Please go to www.fcfb.org for further information on this and other issues important to California agriculture.

 

FUTURE RULES

In addition to the truck rule this year, ARB will be proposing an on-farm diesel equipment rule next year.  This rule would target tractors, harvesters, and all other equipment used in agricultural production.  The combination of just these two rules will cost California’s farmers and ranchers billions of dollars—a cost they cannot pass on.