CALIFORNIA AIR RESOURCES BOARD
Auditorium, First Floor
400 "P" Street
May 14, 1992
92-6-1 Public Meeting to Consider a Plan to Control 001
Emissions from Off-Highway Vehicle Engines.
92-6-2 Public Hearing to Consider Adoption of Amendments 021
to the Certification and Compliance Test Procedures
for Alternative Fuel Retrofit Systems for Motor
92-6-3 Consideration of Research Proposals. 130
ITEM NO.: 92-6-1
Public Meeting to Consider a Plan to Control Emissions from Off-Highway
The staff recommends that the Air Resources Board (ARV or Board)
approve the staff's regulatory plan to control emissions from
off-highway vehicle engines and equipment.
The California Clean Air Act (CCAA), codified in Health and
Safety Code (HSC) Sections 43013 and 43018 grants the ARB
authority to regulate emissions from off-road vehicles and other
nonvehicular mobile sources. The CCAA mandates a five percent
per year reduction in ozone precursor and carbon monoxide
emissions from the 1987 baseline emission inventory. Engines
used in equipment contained in the off-highway vehicle category
produce significant amounts of HC and NOx emissions which are
The off-highway vehicle category includes construction and farm
equipment, industrial equipment such as forklifts, generators,
pumps, compressors, along with off-road motorcycles, all-terrain
vehicles, snowmobiles, golf cars and similar equipment. Although
part of the off-highway vehicle category, the federal Clean Air
Act has preempted the ARB from regulating new construction and
farm equipment under 175 horsepower. However, the Environmental
Protection Agency has not yet defined what qualifies as
construction and farm equipment. For the purpose of this report,
staff has categorized the equipment based on the latest available
information and has estimated emission inventories based on this
information. Because of the preemption restrictions and because
the vehicles and equipment in this category vary greatly in terms
of use, application, and available technology, it is appropriate
to divide the category into three separate subcategories:
preempted farm and construction equipment, off-highway utility
equipment, and off-highway recreational vehicles.
The staff has prepared a plan which identifies a feasible and
cost effective regulatory strategy to control emissions from off-highway
vehicles. Because of the preemption restrictions,
however, no regulatory control plan is proposed for the preempted
farm and construction subcategory.
Upon approval by the Board, the staff will develop formal
regulatory proposals for the "nonpreempted" subcategories. These
proposals will recommend a complete regulatory package, similar
to those adopted for other on- and off-road vehicles/equipment.
This will include exhaust emission standards, certification
requirements, quality auditing, and emissions control warranties.
If approved, the regulatory proposal for off-highway recreational
vehicles will be presented to the Board later this year followed
by a similar proposal for off-highway utility equipment in 1993.
SUMMARY OF IMPACTS OF PROPOSED ACTION
Staff has evaluated the current emission levels, available
technologies, applicable standards and test procedures, as well
as the expected emission reductions and cost effectiveness of
this proposal. It appears that emissions associated with these
vehicles are a significant source of pollution, and that by
utilizing currently available emission control technology,
emission reductions of over 40 percent for combined HC + NOx and
1237 tons per day of CO from the statewide emissions inventory by
the year 2010.
ITEM NO.: 92-6-2
Public Hearing to Consider Adoption of Amendments to the
Certification and Compliance Test procedures for Alternative Fuel
Retrofit Systems for Motor Vehicles.
Staff recommends that the Board adopt the proposed "California
Certification and Installation Procedures for Alternative Fuel
Retrofit Systems for Motor Vehicles Certified for 1994 and
subsequent Model Years," amend the currently applicable
procedures, and amend the regulations which reference these
The regulatory action would strengthen certification and warranty
requirements for alternative fuel retrofit systems. It would add
requirements for more extensive emission testing, including
durability testing, in-use compliance testing, and provisions
governing interfacing with on-board diagnostic (OBD) systems.
Explicit warranty requirements of retrofit system manufacturers
and installers would also be added. Installers of retrofit
systems would have to submit each converted vehicle for
inspection and testing at a Bureau of Automotive Repair Smog
Check referee station.
Health and Safety code Section 43004 provides that the emission
standards applicable to gasoline-powered motor vehicles also
apply to vehicles converted to use fuels other than gasoline or
diesel. Health and Safety Code Section 43006 authorizes the
Board to set certification standards for alternative fuel
retrofit systems. For 1994 and subsequent model-year vehicles,
The proposed procedures would supersede existing procedures
governing certification of retrofit systems for compressed
natural gas (CNG) and liquid petroleum gas (LPG), as well as
similar procedures governing retrofit systems for alcohol fuels.
ARB staff has worked with members of the gaseous fuel industries,
alternative fuel conversion equipment manufacturers and
installers, and other interested parties to develop revised
regulations which strengthen the certification requirements for
alternative fuel retrofit systems. There is a general consensus
among these parties that the existing regulations are not
assuring that conversion systems are correctly designed or
installed. The proposed revisions are intended to rectify the
shortcomings identified in the existing regulations, in order to
prevent excess emissions from the fleet of retrofitted vehicles.
The Board's recently-adopted low-emission vehicle standards take
into account the differing reactivities of exhaust gases that
result from using various fuels. A goal of these standards is to
subject all vehicles to a consistent standard based on their
potential for forming ozone, despite the various combinations of
fuel composition, engine design and emission controls that may
exist. Where applicable, the proposed certification procedures
for alternative fuel retrofit systems would be based on the low-emission
vehicle emission standards. They would also allow
certification of retrofit systems as being capable of converting
a vehicle to one of the tiers of the low-emission vehicle
SUMMARY OF IMPACTS
The proposed regulations would result in significant
environmental benefits. Based on ARB's emission testing of
vehicles converted to operate on LPG, staff estimates that under
the existing retrofit procedures the excess emissions from the
LPG fleet in the year 2010 will be 65 tons/day of CO and 1
ton/day of HC + NOx. The proposed procedures should largely
eliminate these excess emissions.
Staff estimates that the maximum per vehicle hardware cost would
be $40 per vehicle. This amount is equivalent to 2-3 percent of
the $1,500 to $2,100 installed cost of present LPG retrofit
systems. There may be additional expenses associated with the
proposed certification procedures. Under a worst case scenario,
staff estimates that certification testing costs will increase by
about $86 per installation. However, because this cost could be
considerably less and because of the competitiveness of the
industry, it is not known whether any of this cost will be passed
along to the consumer. A survey of LPG retrofit system
manufacturers yielded estimated price increases ranging from less
that $40 to over $300 per vehicle.
Over the average life of an LPG retrofit vehicle, the excess
emissions produced under the current certification procedures are
estimated at 4968 lbs of CO and 63 lbs of combined HC and NOx.
Using the estimated maximum per hardware cost of $40, the
proposed regulatory action would reduce CO emissions at an
estimated cost of $0.01/lb and HC + NOx at an estimated $0.63/lb.