Equipment Replacement/Retrofits

TID has embarked on a program to comply with new state mandates aimed at reducing diesel emissions and associated health risks. Administered by the California Air Resources Control Board (CARB), the program is titled the “Fleet Rule for Public Agencies and Utilities” and has been in place since October 2006. This initial regulation is for public agencies, and additional CARB regulations for public off-road equipment, private fleets of off/on-road heavy equipment, and agricultural diesel equipment will be the next phase. CARB is concerned with eliminating particulate matter (PM) that has an aerodynamic diameter of 10 microns or smaller, commonly referred to as PM10.

CARB requires that any public agency that leases or operates on-road diesel-driven equipment and vehicles with a 1960 to 2006 model-year fleet to comply. The targeted vehicles must have a vehicle weight rating greater than 14,000 pounds. The District’s fleet contains ten such pieces of equipment that fall under the regulation. Compliance measures include the following groupings that fall under the state’s Best Available Control Technology (BACT) definition:

1. Retirement of equipment (this requires that the engine be destroyed)

2. Re-power equipment – involves replacing the motor with a 2007or newer motor

3. Retrofit motor with a BACT-compliant filter to remove PM

Agencies are allowed to phase the compliance of equipment and vehicles in order to address time and cost constraints of this program. The compliance time frame consists of percent completion requirements by 2007, 2009, and 2011 as shown in the table below:

Group	Engine Model Year	% to Use BACT	Compliance Deadline
1	1960-1987	20 60 100	2007 2009 2011
2	1988-2002	20 60 100	2007 2009 2011
3	2003-2006	50 100	2009 2010

TID staff has taken a very detailed look at its fleet to determine what replacements, retrofits or re-powering compliance options would be viable. For some of our older equipment, we found that replacement was much more cost effective given the equipment expected life spans. On some of the newer equipment, we found that retrofits were feasible due to the lower costs and ability to utilize their existing computer-driven motors to accommodate the complex BACT filtering systems. Re-powering of equipment has not proven to be practical due to the likelihood that the equipment that could be re-powered will not likely last long enough to justify the cost.

The District began its CARB conversion program in the fall of 2007 by replacing the model-year 1985 tractor-trailer that was utilized for hauling heavy equipment. The District also retrofitted two dump trucks with BACT filters. These actions enabled TID to meet all 2007 compliance deadlines at a cost of about $139,000.00.

Looking towards the 2009 deadline, TID is in the process of a combination of retrofit and retirement projects to meet CARB requirements. It is estimated that the cost to meet 2009 CARB deadlines will be around $210,000. By the 2011 final deadline for full compliance, the District anticipates expenditures in 2010 and 2011 to be around $25,000 and $75,000 respectively.

This program also requires a significant amount of recordkeeping. TID must keep individual records on each piece of equipment and must be prepared for inspections as required by CARB. Each vehicle must also be labeled in a viewable location with CARB-specified information. Violations of this regulation can carry civil penalties as specified by state law.