staff report - alameda-contra costa transit district carb update...staff report to: planning...

T/?19/VS/T Report No: Meeting Date:

Alameda-Contra Costa Transit District

STAFF REPORT TO: Planning Committee

AC Transit Board of Directors

FROM: David J. Armijo, General Manager

SUBJECT: Annual Update on California Air Resources Board (CARB)

BRIEFING ITEM

RECOMMENDED ACTION(S):

13-140 June 12, 2013

Consider receiving annual update on compliance with California Air Resources Board (CARB) regulations.

EXECUTIVE SUMMARY:

Air quality is a top environmental concern in California and the greater Bay Area. Motor vehicles are a major source of airborne smog-producing pollutants. Diesel engines have been a source of emissions, including particulate matter (PM) and oxides of nitrogen (NOx).

This report has been prepared to update the Board on compliance with the California Air Resources Board (CARB) rules that affect the District fleet of vehicles. Currently, there are two CARB rules in place that require the District to comply with measured PM and NOx emission limits:

1. Fleet Rule for Transit Agencies Urban Bus (Urban Bus)

2. Transit Fleet Vehicle Rule (Fleet Rule)

The Urban Bus rule regulates emi.ssion standards for new heavy-duty transit buses and heavyduty engines, and it requires participation in a Zero-Emission Bus (ZEB) demonstration program for agencies with fleets larger than 200 buses. The Fleet Rule regulates emissions on medium duty transit vehicles and requires the District to make percentage reductions in the total diesel PM emissions relative to its January 1, 2005 baseline.

The District is in full compliance with the Urban Bus rule, but we are not currently in compliance with the Fleet Rule since the fifty-one (51) Van Hool 5000 series buses require installation of a particulate filter, and a verified exhaust after treatment device had not been available without extensive structural changes to the buses. However, District staff recently identified exhaust after treatment devices requiring more limited structural modification, issued a Request for Proposal (RFP) for modification of the fleet, and provided communication to CARB on the District's retrofit plan to ensure our compliance with the Fleet Rule.

Report No. 13-140 of 3

BUDGETARY/FISCAL IMPACT:

The capital costs associated with retrofitting the fifty-one (51) Van Hool buses is estimated at

$1,590,450. The District will utilize $795,225 in FTA 5307 funds and $795,225 in District Capital

funds to retrofit these buses. The project and its funding are part of the FY2013 capital budget.

BACKGROUND/RATIONALE:

A summary of the two CARB rules that require transit agencies to reduce transit bus PM and NOx emissions are as follows:

Fleet Rule for Transit Agencies Urban Bus (Urban Bus): In February 2000, CARB adopted the Urban Bus rule that regulates emissions for new heavy-duty transit buses and heavy-duty engines. The regulation also requires participation in a Zero-Emission Bus (ZEB) demonstration program for agencies with fleets larger than 200 buses.

An Urban bus is a passenger carrying vehicle owned and operated by a public transit agency. Vehicles under this rule are powered by heavy-duty diesel engines, usually 35-feet or longer, and/or greater than 33,000 pounds gross vehicle weight rating (GVWR) designed for intra-city operation. The primary focus of this rule is the reduction of oxides of nitrogen (NOx) and particulate matter (PM) emissions.

Transit Fleet Vehicle Rule (Fleet Rule): In February 2005, the Fleet Rule took effect for transit agencies. Vehicles under this rule are less than 35-feet in length, between 8,500 and 33,000 GVWR, and powered by heavy-duty diesel or alternative fuel engines. The District's 30-foot Van Hool buses, service, and storeroom trucks are included in this regulation, and the District must make percentage reductions in the total diesel PM emissions relative to its January 1, 2005 baseline.

Status of District Compliance

Technical Service staff monitors and reports fleet emissions to CARB annually. The District is in full compliance with the Urban Bus rule, but we are not currently in compliance with the Fleet Rule since the fifty-one (51) Van Hool 5000 series buses require installation of a particulate filter, and a verified exhaust aftertreatment· device had not been available without extensive structural changes to the buses.

To comply with the Fleet Rule, the District submitted a plan to CARB in June 2012 for the installation of one exhaust aftertreatment device on a prototype bus for a 12 month evaluation period to identify any installation issues and determine the effectiveness of the filter, which would be followed by the retrofitting of the remainder of the bus fleet. CARB did not support the prototype installation, so the District posted a Request for Proposals (RFP) for the Van Hool exhaust retrofit work with the particulate filter mounted on the roof.

The closure of the particulate filter manufacturer, Cleaire, earlier this year, and potential restrictions on particulate filter placement above passenger compartments resulted in extensions for submission of the RFP until further clarification from CARB has been received by

Report No. 13-140 of 3

the District. District staff has been communicating with CARB on the District's retrofit plan to ensure our compliance with the Fleet Rule.

ADVANTAGES/DISADVANTAGES:

The advantage of installing a new after treatment device is that the District would become compliant with the CARB Transit Fleet Rule.

The disadvantage of this modification is that structural modifications to the Van Hool buses could impact manufacturer structural warranties.

ALTERNATIVES ANALYSIS:

• Do nothing- This alternative is not recommended since the District would continue to be in violation of the CARB Transit Fleet Rule, which could result in enforcement actions by CARB.

• Sell buses outside of California -This alternative is not recommended since the District is not likely to receive the value needed for replacement of the buses.

PRIOR RELEVANT BOARD ACTIONS/POLICIES:

None.

ATTACHMENTS:

1. Staff Report No. 11-132


3. Letter to CARB regarding District mediation plan dated June 12, 2012

4. Letter from CARBin response to District plan dated September 10, 2012

5. Letter to CARB providing an update on mediation plan dated December 21, 2012

6. Letter to CARB requesting an update dated April 22, 2013


Department Head Approval: James Pachan, Chief Operating Officer

Reviewed by: David Wolf, General Counsel Lewis Clinton, Chief Financial Officer

Prepared by: Stuart Hoffman, Manager, Technical Services

This page intentionally blank

AC TRANSIT DISTRICT Board of Directors

Committees: Operations Committee External Affairs Committee Board of Directors

D D D

SR 13-140 Attachment 1

GM Memo No. 11-132

Meeting Date: June 8, 2011

Planning Committee 1Z1 Finance and Audit Committee 0 Financing Corporation 0

SUBJECT: Consider Receiving Annual Update on California Air Resources Board (CARB) Emissions

RECOMMENDED ACTION: 1ZJ Briefing Item D Recommended Motion

Budgetarv/Fiscal Impact:

None

Background/Discussion:

A CARS semi-annual update was presented to the Board on September 22, 2010 (see GM Memo 10-214, attached) and no changes have taken place since then. The AC Transit bus fleet remains in compliance per the three GARB rules for measured emission limits:

1. Fleet Rule for Transit Agencies Urban Bus (UB); 2. Transit Fleet Vehicle (TFV); and 3. Public Agencies and Utilities (PAU).

If GARB rules or emissions measured limits change in any way that can affect AC Transit operations, an update will be provided to the Board.

Prior Relevant Board Actions/Policies:. None

Attachments: GM Memo 10-214

Approved by:

Prepared by:

Date Prepared:

Mary V. King, Interim General Manager Kathleen Kelly, Chief Operating Officer Stuart Hoffman, Manager of Technical Services and Maintenance Training May 25,2011



D D D

GM Memo No. 10-214

GM Memo 11·132 Attachment

Meeting Date: September 22, 2010

Planning Committee jgj Finance and Audit Committee

00

Financing Corporation

SUBJECT: Consider Receiving Semi Annual Update on CARB

RECOMMENDED ACTION: ~ Briefing Item

Budgetary/Fiscal Impact:

None


D Recommended Motion

Air quality Is a top environmental concern in the Bay Area. Motor vehicles are a major source of airborne particulates and smog-producing pollutants. Diesel engines In particular have long been a major source of emissions, Including particulate matter (PM) and smogforming oxides of nitrogen (NOx).

The California Air Resources Board (CARB) was originally established as a combination of the Bureau of Air Sanitation and the Motor Vehicle Pollution Control Board and recognizes the Importance of reducing harmful emissions." GARB's mission Is "to promote and protect public health ... through effective and efficient reduction of air pollutants" (www.arb.ca.gov). As a public transit agency, the District must comply with GARB's requirement to reduce PM and NOx air pollutant emissions.

CARB has Identified three specific rules that require the District to comply with measured emission limits:

1. Fleet Rule for Transit Agencies Urban Bus (UB); 2. Transit Fleet Vehicle (TFV); and 3. Public Agencies and Utilities {PAU).

Staff Is responsible for monitoring and reporting fleet emissions to CARB annually.

Fleet Rule for Transit Agencies Urban Bys:

In February 2000, CARB adopted the Fleet Rule for Transit Agencies Urban Bus which affected emission standards for new urban buses and engines. Urban Buses are powered by heavy/heavy-duty diesel engines, usually 35-feet or longer, and/or greater than 33,000 pounds gross vehicle weight rating (GVWR) designed for Intra-city operation. Emission focus for this rule is on reducing NOx and PM emissions.

GM Memo No. 10-214 Meeting Date: September 22, 2010 Page2 of3

Under the fleet rule, each transit agency was required to select a compliance path - either the "diesel" path or the "alternative fuel" path. AC Transit chose the diesel path. The regulations also Included requirements for transit agencies with 200 or more buses to demonstrate zero emissions buses, or ZBus. A ZBus Is defined as a bus or trolley that produces zero exhaust emissions. The District is in compliance with the Urban Bus fleet average requirements by using ultra-low-sulfur diesel (ULSD), installing exhaust aftertreatment devices on older buses, and purchasing new buses with cleaner burning engines.

Transit Fleet Vehicle Rule:

In February 2006, the Transit Fleet Vehicle Rule took effect for transit agencies. Transit Fleet Vehicles are on-road vehicles, less than 36-feet In length, and 33,000 GVWR, but greater than 8,500 GVWR, and powered by heavy-duty engines fueled by diesel or alternative fuel. The District's 30-foot VanHool buses, service and storeroom trucks, and some paratranslt vans meet this parameter. The District must make percentage reductions in the total diesel PM emissions of Its diesel transit fleet vehicles relative to its January 1, 2005 baseline.

The District Is not in compliance with the Transit Fleet Vehicle Rule because there Is currently no verified exhaust after-treatment device capable of reducing PM and NOx that can be retrofitted in the District's fleet of VanHool 6000 series buses. Each year, until a verified exhaust after-treatment device becomes available, the District requests from CARB and CARB grants, In writing, an annual extension. Until a verified after-treatment device Is available, the District has no further obligation related to this rule.

Public Aaencles and Utilities Rule:

On December 8, 2005, CARB approved the Public Agencies and Utilities Rule, a regulation to reduce diesel PM emissions from fleets operated by public agencies and utilities. AC Transit vehicles pertaining to this rule Include the UC Berkeley buses owned by the District. Under this rule, the District Is required to reduce diesel PM emissions through the application of Best Available Control Technology (BACT). BACT requirements are met by engine retrofitting with the highest-level PM diesel emission control strategy (DECS). Engine emission reductions are based on engine model year and percentage reduction target dates. Annual reporting is not required, but records must be kept In a centralized location at the division where the vehicle resides and labeling must be kept in the vehicle.

Currently, there are no CARB requirements to Install any additional exhaust after-treatment devices on our urban bus fleet. Future bus purchases utilizing diesel engines will require Selective Catalyst Reduction (SCR) strategies as part of the exhaust system from engine manufacturers. These SCR systems utilize Diesel Exhaust Fluid (DEF) which Is a non-toxic liquid made up of purified water and 32.5 percent automotive grade urea. This fluid is then sprayed Into the exhaust system during operation to reduce NO.. AC Transit will need to establish an Infrastructure for this DEF as part of the next diesel bus procurement.

GM Memo No. 10-214 Meeting Date: September 22, 2010 Page 3 of3

Under current regulations, 15% of all new annual urban bus purchases must be i:Buses. The purchase schedule begins with the model year 2011 for agencies on the diesel path and continues through 2026. However, in January 2010, CARB notified all transit agencies with a Regylatory Advisory that until the commercial readiness can be assessed, CARB does not intend to enforce the ZBus purchase requirement. A public hearing process Is set to take place no later than July 2012. Prior to this meeting, CARB will announce public workshops to share progress and foster stakeholder feedback.

Prior Relevant Board Actions/Policies: None

Attachments: None

Approved by: Mary V. King, Interim General Manager Kathleen Kelly, Chief Operating Officer

Prepared by: Michael Flocchini, Training and Education Manager Stuart Hoffman, Manager of Technical Services and Maintenance Training

Date Prepared: September 8, 2010



D D D


GM Memo No. 10-214

Meeting Date: September 22, 2010

Planning Committee 1:8:1 Finance and Audit Committee 0 Financing Corporation 0


RECOMMENDED ACTION: 12?] Briefing Item 0 Recommended Motion

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Budgetarv/Fiscallmpact:

None


Air quality is a top environmental concern in the Bay Area. Motor vehicles are a major source of airborne particulates and smog-producing pollutants. Diesel engines in particular have long been a major source of emissions, including particulate matter (PM) and smogforming oxides of nitrogen (NO.).

The California Air Resources Board (CARB) was originally established as a combination of the Bureau of Air Sanitation and the Motor Vehicle Pollution Control Board and recognizes the importance of reducing harmful emissions. CARS's mission is "to promote and protect public health ... through effective and efficient reduction of air pollutants" (www.arb.ca.qov). As a public transit agency, the District must comply with CARS's requirement to reduce PM and NOx air pollutant emissions.

CARS has identified three specific rules that require the District to comply with measured emission limits:

1. Fleet Rule for Transit Agencies Urban Bus (UB); 2. Transit Fleet Vehicle (TFV); and 3. Public Agencies and Utilities {PAU).

Staff is responsible for monitoring and reporting fleet emissions to CARB annually.

Fleet Rule for Transit Agencies Urban Bus:

In February 2000, CARB adopted the Fleet Rule for Transit Agencies Urban Bus which affected emission standards for new urban buses and engines. Urban Buses are powered by heavy/heavy-duty diesel engines, usually 35-feet or longer, and/or greater than 33,000 pounds gross vehicle weight rating {GVWR) designed for intra-city operation. Emission focus for this rule is on reducing NOx and PM emissions.

GM Memo No. 10-214 Meeting Date: September 22, 2010 Page 2 of3

Under the fleet rule, each transit agency was required to select a compliance path - either the "diesel" path or the "alternative fuel" path. AC Transit chose the diesel path. The regulations also included requirements for transit agencies with 200 or more buses to demonstrate zero emissions buses, or ZBus. A ZBus is defined as a bus or trolley that produces zero exhaust emissions. The District is in compliance with the Urban Bus fleet average requirements by using ultra-low-sulfur diesel (ULSD), installing exhaust aftertreatment devices on older buses, and purchasing new buses with cleaner burning engines.


In February 2005, the Transit Fleet Vehicle Rule took effect for transit agencies. Transit Fleet Vehicles are on-road vehicles, less than 35-feet in length, and 33,000 GVWR, but greater than 8,500 GVWR, and powered by heavy-duty engines fueled by diesel or alternative fuel. The District's 30-foot VanHool buses, service and storeroom trucks, and some paratransit vans meet this parameter. The District must make percentage reductions in the total diesel PM emissions of its diesel transit fleet vehicles relative to its January 1, 2005 baseline.

The District is not in compliance with the Transit Fleet Vehicle Rule because there is currently no verified exhaust after-treatment device capable of reducing PM and NOx that can be retrofitted in the District's fleet of VanHool 5000 series buses. Each year, until a verified exhaust after-treatment device becomes available, the District requests from CARB and CARB grants, In writing, an annual extension. Until a verified after-treatment device is available, the District has no further obligation related to this rule.

Public Agencies and Utilities Rule:

On December 8, 2005, CARB approved the Public Agencies and Utilities Rule, a regulation to reduce diesel PM emissions from fleets operated by public agencies and utilities. AC Transit vehicles pertaining to this rule include the UC Berkeley buses owned by the District. Under this rule, the District is required to reduce diesel PM emissions through the application of Best Available Control Technology (BACT). BACT requirements are met by engine retrofitting with the highest-level PM diesel emission control strategy (DECS). Engine emission reductions are based on engine model year and percentage reduction target dates. Annual reporting is not required, but records must be kept in a centralized location at the division where the vehicle resides and labeling must be kept in the vehicle.

Currently, there are no CARB requirements to install any additional exhaust after-treatment devices on our urban bus fleet. Future bus purchases utilizing diesel engines will require Selective Catalyst Reduction (SCR) strategies as part of the exhaust system from engine manufacturers. These SCR systems utilize Diesel Exhaust Fluid (DEF) which is a non-toxic liquid made up of purified water and 32.5 percent automotive grade urea. This fluid is then sprayed into the exhaust system during operation to reduce NOx. AC Transit will need to establish an infrastructure for this DEF as part of the next diesel bus procurement.

GM Memo No. 1 0-214 Meeting Date: September 22, 2010 Page 3 of3

Under current regulations, 15% of all new annual urban bus purchases must be ZBuses. The purchase schedule begins with the model year 2011 for agencies on the diesel path and continues through 2026. However, in January 2010, CARB notified all transit agencies with a Regulatorv Advisorv that until the commercial readiness can be assessed, CARB does not intend to enforce the ZBus purchase requirement. A public hearing process is set to take place no later than July 2012. Prior to this meeting, CARB will announce public workshops to share progress and foster stakeholder feedback.

Prior Relevant Board Actions/Policies: None

Attachments: None

Approved.by: Mary V. King, Interim General Manager Kathleen Kelly, Chief Operating Officer

Prepared by: Michael Flocchinl, Training and Education Manager Stuart Hoffman, Manager of Technical Services and Maintenance Training


rrAJ·~r Alameda- Contra Costa Transit District

June 12,2012

Mr. Craig Duehring Manager, In-Use Control Measure Section California Air Resources Board 1001 I Street, PO Box 2815 Sacramento, California 95812

RE: District Action Plan on the Transit Fleet Vehicle 30' Van Hool Buses

Dear Mr. Duehring:


The District appreciates the meeting with the California Air Resources Board (CARB) staff on Monday, April9'h 2012 to discuss the Transit Fleet Vehicle (TFV) Rule pertaining to the (51) 2007 30' Van Hool buses. The visit has aiiowed the District's staff to better understand concepts for mitigation to meet emission reductions. As recaiied, the CARB staff referenced possible options for meeting the regulatory requirements of the TFV Rule. As the options were chaiienging from both an engineering and financial perspective, the District staff has developed a proposal that would meet the overaii objective. The District is recommending the instaiiation of one Cleaire LongMile device on a prototype bus for a 12 month evaluation period to identify any instaiiation issues and determine the effectiveness of the particulate filter in an effort to move toward compliance with the TFV Rule.

The considerations from CARB staff in conjunction with the Districts staff recommendations have been summarized in the outlines provided. The Districts position is quantified on historical and current linelevel analysis and methodologies, product availability, and future service and maintenance impacts.

Districts Proposed Action The District has determined that the Cleaire LongMile device is the most cost-effective option available to achieve the desired emissions reductions and meet service demands. The installation of these devices will reduce the particulate emissions of the buses required by CARB for the TFV Rule. The device will produce conformity and maintainability in regards to the fleet and maximize the various routes for operation of these buses in our service area. Moreover, the District will achieve a greater than 85% reduction in pa1ticulate matter exhaust from the buses.

As the (51) 30' Van Hool buses are owned and operated by the District on various routes in its service area, a prototype wiii be tested in operational service. The testing period for the prototype will be revaluated after a 12 month parameter. The period will provide ample time to evaluate staff concerns related to passenger safety, structural integrity and fire concerns resulting from the modifications required for instaiiation of the particulate filter into the buses.

CARB Recommendations In the April 9th discussion, CARB staff indicated that two other filters have been approved (Hug and Huss) which were reviewed by District staff. Unfortunately, these devices failed to meet the 30' Van Hool fleet requirements. The executive order for Hug does not have verified devices for the required engine application. Subsequently, the Huss exhaust afte1treatmcnt device is too big to fit within the confined space, and requires extensive additional structural changes to the bus. The Huss device also produces additional operational challenges, as the system will only allow the engine to operate approximately 8 hours until the system needs to be regenerated with the engine turned off.

1600 Franklin Street !Oakland, CA 946121 TEL 510-891-72151 www.actransit.org

Alameda- Contra Costa Transit District

Cleaire LongMile/ ECS Devices The Districts preceding research efforts to meet the TFV Rule requirements found two possible devices for installation in the Van Hool buses, the Cleaire LongMile and the Emission Control Systems (ECS) system. Both solutions would require some vehicle modification and additional cost to the District. The Districts concerns with the installation of these devices are as follows:

C/eaire Long!vfile The installation of this device would require modification of the bus structure by installing a doghouse beneath a row of passenger seating, which would enlarge the compartment cavity to contain the exhaust aftertreatment device at the floor level.

ECS The installation of this device would require purchase of several regeneration stations and modification of the operating facilities to accommodate duty cycle of the buses, in addition to structural modifications for installation in the buses. The operation of these vehicles would be restricted to dedicated facilities due to the requirement for regeneration stations, and the District would need to modify the service for these vehicles to accommodate the regeneration process.

TFV Extension To allow time for the District and CARB staff to review the results of the prototype installation, the District will submit an extension under Title 13, CCR, Section 20239(1) to CARBin October of2012. During the extension and evaluation period, the District will pursue Federal and Metropolitan Transportation Commission funds to aid in the mitigation costs of- $1.5 Million. As you are probably aware, the District implemented significant service reductions over the past few years due to funding shortfalls; therefore, a dedicated funding source for the installation of these devices needs to be identified. In addition, the District will continue to work with our many stakeholders and agencies in developing environmentally responsible programs to reduce emissions and benefit the communities it operates in, such as our Fuel Cell bus program.

Alternative Options The District is also considering the sale or retirement of all or part of the 30' Van Hool bus fleet as an additional mitigation measure. The sale of these buses to agencies that reside out of the State of California could offset any Federal or Local obligations for operation of the vehicles and bring the District into compliance with the fleet rule.

The Districts appreciates the open discussions during the Sacramento visit, and looks forward to the resolving the 30' Van Hool issue while addressing the implementation issues from both our agencies.

1. cerely,

_;:;; --~ l es D. Pachan

Chief Operating Officer

cc: Sam Marra Stuart Hoffman Bill Ton is

1600 Franklin Street [Oakland, CA 94612 I TEL 510-891-7215 I www.actransit.org

Matthew Rodriquez Secretary for

Environmental Protection

September 10, 2012

Mr. James D. Pachan Chief Operating Officer

Air Resources Board Mary D. Nichols, Chairman

1001 I Street • P.O. Box 2815 Sacramento, California 95812 • www.arb.ca.gov

Alameda- Contra Costa Transit District 1600 Franklin Street Oakland, California 94612

Dear Mr. Pachan:


Edmund G. Brown Jr. Governor

Thank you for your letter where you request another compliance extension from title 13, California Code of Regulations, section 2023, the Transit Fleet Rule. The regulation does not allow for a second extension.

Section 2023(f) of the regulation states that an extension may be granted for up to one year, provided the applicant demonstrates that the technology is unavailable. The Alameda-Contra Costa Transit District already received a one-year extension that expired December 31, 2011, and should have taken action to bring the fleet into compliance during that extension period. No additional extensions will be granted.

In our April 9, 2012, meeting, we discussed that there was at least one suitable verified diesel emissions control strategy that the fleet could have used to bring the remaining buses into compliance. You recently sent a proposed plan to further delay compliance for another year. Further delays are not acceptable. The Alameda-Contra Costa Transit District should immediately bring the fleet into compliance by retrofitting, replacing or parking the buses that do not comply.

The vehicles that are not in compliance with the regulation may be subject to enforcement action. If you have any questions or comments regarding this decision, please contact Mr. Craig Duehring, Manager, at (916) 323-2361 or by email at [email protected].

7~ Tony~il, Chief Heavy-Duty Diesel Implementation Branch

cc: See next page.

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a Hst of simple ways you can reduce demand and cut your &nergy costs, see our website: hllp:/lwww. arb.ca.gov.

California Environmental Protection Agency

Printed on Recycled Paper

Mr. James D. Pachan August10,2012 Page2

cc: Mr. Warren Hawkins, Manager Specialized Fleet Enforcement Section Enforcement Division

Mr. Craig Duehring, Manager In-Use Control Measures Section Mobile Source Control Division


December 21, 2012

Mr. Tony Brasil, Chief Heavy Duty Diesel implementation Branch California Environmental Protection Agency Headquarters California Air Resources Board P.O. Box 2815 Sacramento, CA 95812

DearMr. Brasil:


James Pachan, Chief Operating Ollie"!_

Thank you for your letter on September 10, 2012 In response to the District's request for a compliance extension on our fleet of vehicles under the Transit Fleet Rule.

Based on your response, District staff worked to identify funds for the exhaust retrofit program and prepared an exhaust retrofit Scope of Work (SOW) for solicitation by outside contractors. The SOW was included in a Request for Proposals (RFP) for the exhaust retrofit work that was posted for bid on December 17, 2012. The District's plan is to award a contract for the retrofit of the exhaust systems on the fifty-one (51) bus fleet in early 2013.

As previously stated, the unique vehicle configuration on these Van Hool buses made this particulate filter retrofit very challenging from both an engineering and financial perspective. However, the District's technical services staff worked hard to develop a solution for the retrofits on these buses, and they are confident that the solution identified will be effective and bring the District into compliance with the Transit Fleet Rule.

We appreciate your understanding in working with us towards meeting the Transit Fleet Vehicle requirements as we resolved the engineering and financial issues related to this vehicle retrofit.

Regards, I

~£;~~~- -Chief Operating Officer

cc: Stuart Hoffman Bill Ton is

Attachment: CARB September 10, 2012 Letter to AC Transit

--·-··-----1600 Franklin Street- Oakland, CA 94612- TEL (510) 891-7215- FAX (51 O) 891-7157- www.actransil.org


April 22, 2013

Mr. Craig Duehring, Manager In-Use Control Measures Section Mobile Source Division California Air Resources Board 10011 Street, P .0. Box 2815 Sacramento, CA 95812

RE: Request for Update on Transit Fleet Vehicle 30' Van Hool Buses

Dear Mr. Duehring:


James Pachan. Chief Operating Officer

This letter is written to request an update from the California Air Resources Board (CARB) regarding installation of Diesel Emission Control System (DECS) particulate filters on AC Transit's remaining (51) Van Hool30' buses in order to bring these buses into compliance with the Transit Fleet Vehicle rule.

The District notified CARB on December 21, 2012 that a Request for Proposal (RFP) had been posted for installation of DECS systems on the (51) Van Hool buses. The RFP specified the installation of a Cleaire exhaust aftertreatment device on the roof of the Van Hool buses due to this vehicle's unique configuration.

The submittal date for the RFP was extended twice due to the closure of Cleaire Advanced Emission Controls in early 2013 and communication from CARB regarding potential regulation eliminating roof mounted DECS installations. The latest extension resulted in the District moving the solicitation due date to May 31, 2013.

District staff is of the understanding that the current regulations do not restrict the installation of a Donaldson DECS particulate filter on the roof of buses; however, staff has been attempting to obtain clarification regarding any pending regulation. CARB staff indicated that the District would be provided with an update on this issue; however, the District has not received any update on our request for a roof mounted DECS installation for these vehicles.

The District appreciates CARB's understanding of the unique configuration of these buses and our safety concerns with installation of a DECS under the bus or within the passenger compartment area, and we would like to work together to identify a solution to resolve this issue. I look forward to your response regarding to this issue.

ames D. Pachan Chief Operating Officer

cc: David Armijo, General Manager (AC Transit)

1600 Franklin Street- Oakland, CA 94612- TEL (510) 891-7215- FAX (510) 891-7157- www.actransit.org

Report No: Meeting Date:


STAFF REPORT TO: Planning Committee

AC Transit Board of Directors

FROM: David J. Armijo, General Manager

SUBJECT: Annual Update on California Air Resources Board (CARS)

BRIEFING ITEM

RECOMMENDED ACTIONISI:


12-131 August 15, 2012

Consider receiving annual update on compliance with California Air Resources Board (CARS) regulations.

EXECUTIVE SUMMARY:

Air quality is a top environmental concern in California and the greater Bay Area. Motor vehicles are a major source of airborne smog-producing pollutants. Diesel engines have been a source of emissions, including particulate matter (PM) and oxides of nitrogen (NOx).

This report has been prepared to update the Board on compliance with the California Air Resources Board (CARB) rules that affect the District fleet of vehicles. Currently, there are two CARB rules in place that require the District to comply with measured PM and NOx emission limits:

1. Fleet Rule for Transit Agencies Urban Bus (UB)

2. Transit Fleet Vehicle Rule (TFV)

The Fleet Rule for Transit Agencies Urban Bus regulates emission standards for new heavy-duty transit buses and heavy-duty engines, and it requires participation in a Zero-Emission Bus (ZEB) demonstration program for agencies with fleets larger than 200 buses. The primary focus of this rule is the reduction of oxides of nitrogen (NOx) and particulate matter (PM) emissions.

The Transit Fleet Vehicle Rule regulates emissions on medium duty transit vehicles. The District's 30-foot Van Hool buses, service, and storeroom trucks are included in this regulation, and the District must make percentage reductions in the total diesel PM emissions relative to its January 1, 2005 baseline.

The District is in full compliance with the Fleet Rule for Transit Agencies Urban Bus, but we are not currently in compliance with the Transit Fleet Vehicle Rule because the fifty-one (51) Van Hool 5000 series buses require installation of a particulate filter, and there had not been a verified exhaust aftertreatment device available for retrofit into these buses without performing extensive structural changes to the buses, which could impact manufacturer

Report No. 12-131 Page 2 of 3

structural warranties. District staff recently identified an exhaust aftertreatment device that may fit into the Van Hool buses with limited structural modification and submitted a plan to CARB for installation on one prototype bus. If successful, then the District would proceed with a plan for retrofit of the remainder of the fleet.

The CARB Public Agencies and Utilities Rule that pertained to the U.C. Berkeley buses reported in past relevant Board Memos (10-214 and 11-132) does not affect the District, as these buses were removed from service in December of 2011.

BUDGETARY/FISCAL IMPACT:

The capital costs associated with retrofitting the fifty-one (51) Van Hool buses after approval of the plan by CARB and completion of prototype testing is $1,568,408. If CARB approves the District plan a Staff Report detailing such expenditures will be submitted requesting Board approval. The District is pursuing grant opportunities to retrofit the subject buses and may need to utilize the General Fund if required.

BACKGROUND/RATIONALE:

A summary of the two CARB rules currently in place that require transit agencies to reduce transit bus PM and NOx emissions are as follows:

Fleet Rule for Transit Agencies Urban Bus: In February 2000, CARB adopted the Fleet Rule for Transit Agencies Urban Bus which regulates emissions for new heavy-duty transit buses and heavy-duty engines. The regulation also requires participation in a Zero-Emission Bus (ZEB) demonstration program for agencies with fleets larger than 200 buses.

An Urban bus is a passenger carrying vehicle owned and operated by a public transit agency. Vehicles under this rule are powered by heavy-duty diesel engines, usually 35-feet or longer, and/or greater than 33,000 pounds gross vehicle weight rating (GVWR) designed for intra-city operation. The primary focus of this rule is the reduction of oxides of nitrogen (NOx) and particulate matter (PM) emissions.

Transit Fleet Vehicle Rule: In February 2005, the Transit Fleet Vehicle Rule took effect for transit agencies. Vehicles under this rule are less than 35-feet in length, and 33,000 GVWR, but greater than 8,500 GVWR, and powered by heavy-duty diesel or alternative fuel engines. The District's 30-foot Van Hool buses, service, and storeroom trucks are included in this regulation, and the District must make percentage reductions in the total diesel PM emissions relative to its January 1, 2005 baseline.

Status of District Compliance

Technical Service staff is responsible for monitoring and reporting fleet emissions to CARB annually. The District is in full compliance with the Fleet Rule for Transit Agencies Urban Bus, but we are not currently in compliance with the Transit Fleet Vehicle Rule because the fifty-one (51) Van Hool 5000 series buses require installation of a particulate filter, and there had not been a verified exhaust aftertreatment device available for retrofit into these buses without

Report No. 12-131 Page 3 of 3

performing extensive structural changes to the buses, which could impact manufacturer structural warranties.

CARB granted the District annual extensions for the TFV rule in past years due to this issue, but they denied the District's most recent request for an extension. To comply with the TFV rule the District submitted a plan to CARB on June 12, 2012. The plan includes installation of one exhaust aftertreatment device on a prototype bus for a 12 month evaluation period to identify any installation issues and determine the effectiveness of the filter. lfthe aftertreatment device proves effective, the District would then begin the process of retrofitting the remainder of the bus fleet. As of this writing the District has not received a response from CARB to this plan.

ADVANTAGES/DISADVANTAGES:

The advantage of the plan to test a new aftertreatment device is that the District would comply with the CARB Transit Fleet Rule based on CARS's response to the District's plan.

The disadvantage of this modification is that structural modifications to the Van Hool buses could impact manufacturer structural warranties. In addition, a recent request for grant funding for this retrofit was not approved, so the District would need to identify funding for the retrofit program.

ALTERNATIVE ACTIONS:

• Do nothing- This alternative is not recommended since the District would continue to be in violation of the CARB Transit Fleet Rule, which could result in enforcement actions by CARB.

• Sell buses outside of California - This alternative is not recommended since the District is not likely to receive the value needed for replacement of the buses.

PRIOR RELEVANT BOARD ACTIONS/POLICIES:

None.

ATIACHMENTS:

1: GM Memo No. 11-132

2: GM Memo No. 10-214

3. Fleet Rule for Transit Agencies

4. Transit Fleet Vehicle Rule

Approved by:

Reviewed by:

Prepared by:

James Pachan, Chief Operating Officer

Vincent C. Ewing, General Counsel

Stuart Hoffman, Manager, Technical Services



D D D

GM Memo No. 11-132

Report No. 12-131 Attachment 1

Meeting Date: June 8, 2011

Planning Committee 0 Finance and Audit Committee D Financing Corporation 0

SUBJECT: Consider Receiving Annual Update on California Air Resources Board (CARB) Emissions

RECOMMENDED ACTION: 18] Briefing Item D Recommended Motion

Budgetary/Fiscal Impact: '

None


A CARB semi-annual update was presented to the Board on September 22, 2010 (see GM Memo 10-214, attached) and no changes have taken place since then. The AC Transit bus fleet remains in compliance per the three CARB rules for measured emission limits:

1. Fleet Rule for Transit Agencies Urban Bus (UB); 2. Transit Fleet Vehicle (TFV); and 3. Public Agencies and Utilities (PAU).

If CARB rules or emissions measured limits change in any way that can affect AC Transit operations, an update wili be provided to the Board.

Prior Relevant Board Actions/Policies:. None

Attachments: GM Memo 10-214

Approved by: Mary V. King, Interim General Manager Kathleen Kelly, Chief Operating Officer

Prepared by: Stuart Hoffman, Manager of Technical Services and Maintenance Training

Date Prepared: May 25, 2011


Committees: Operations Committee External Affairs Committee Board of Directors §

GM Memo No. 10-214

Report No. 12·131 Attachment 2

Meeting Date: September 22, 20 1 0

Planning Committee ~ Finance and Audit Committee Financing Corporation


RECOMMENDED ACTION: 1:81 Briefing Item 0 Recommended Motion

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Budget&rv/Flacallmpact:

None


Air quality Is a top environmental concern In the Bay Area. Motor vehicles are a major source of airborne particulates and smog-producing pollutants. Diesel engines In particular have long been a major source of emissions, including particulate matter (PM) and smogforming oxides of nitrogen (NOx).

The California Air Resources Board (CARB) was originally established as a combination of the Bureau of Air Sanitation and the Motor Vehicle Pollution Control Board and recognizes the Importance of reducing harmful emissions: CARB's mission Is "to promote and protect public health ... through effective and efficient reduction of air pollutants• (www.arb.ca.gC!lll. As a public transit agency, the District must comply with CARS's requirement to reduce PM and NOx air pollutant emissions.

CARB has identified three specific rules that require the District to comply with measured emission limits: ·

1. Fleet Rule for Transit Agencies Urban Bus (UB); 2. Transit Fleet Vehicle (TFV): and 3. Public Agencies and Utilities (PAU).

Stsff Is responsible for monitoring and reporting fleet emissions to CARB annually.

Fleet Rule for Transit Agencies Urban Bus:

In February 2000, CARB adopted the F/11et Rule for Transit Agencies Urban Bus which affected emission standards for new urban buses and engines. Urban Buses are powered by heavy/heavy-duty diesel engines, usually 35-feet or longer, andfor greater than 33,000 pounds gross vehicle weight rating (GVWR) designed for Intra-city operation. Emission focus for this rule Is on reducing NOx and PM emissions.

GM Memo No. 10-214 Meeting Date: September 22, 2010 Page2of3

Under the fleet rule, each transit agency was required to select a compliance path - either the "diesel" path or the "alternative fuel" path. AC Transit chose the diesel path. The regulations also Included requirements for transit agencies with 200 or more buses to demonstrate zero emissions buses, or ZBus. A ZBus Is defined as a bus or trolley that produces zero exhaust emissions. The District Is In compliance with the Urban Bus fleet average requirements by using ultra-low-sulfur diesel (ULSD), Installing exhaust aftertreatment devices on older buses, and purchasing new buses with cleaner burning engines.


In February 2005, the Transit Fleet Vehicle Rule took effect for transit agencies. Transit Fleet Vehicles are on-road vehicles, less than 35-feet In length, and 33,000 GVWR, but greater than 8,600 GVWR, and powered by heavy-duty engines fueled by diesel or alternative fuel. The District's 30-foot VanHeel buses, service and storeroom trucks, and some paratranslt vans meet this parameter. The District must make percentage reductions In the total diesel PM emissions of Its diesel transit fleet veh!cln relallve to its January 1, 2005 baseline.

The District Is not in compliance with the Transit Fleet Vehicle Rule because there Is currently no verlflsd exhaust after-treatment device capable of reducing PM and NO. that can be retrofitted !n the District's fleet of VanHeel 6000 series buses. Each year, until a verified exhaust after-treatment device becomes available, the District requests from CARB and CARB grante, In writing, an annual extension. Until a verified after-treatment device Is available, the District has no further obligation related to this rule.

Public Agencies and Utilities Rule:

On December 8, 2005, CARS approved the Public Agencies end Utilities Rule, a regulation to reduce diesel PM emissions from fleets operated by public agencies and utilities. AC Transit vehicles pertaining to this rule Include the UC Berkeley buses owned by the District. Under this rule, the District Is required to reduce diesel PM emissions through the application of Best Available Control Technology (BACT). BACT requirements are met by engine retrofitting with the highest-level PM d lese I emission control strategy (DECS). Engine emission reductions are based on engine mode! year and percentage reduction target dates. Annual reporting Is not required, but records must be kept In a centralized location at the division where the vehicle resides and labeling must be kept In the vehicle.

Currently, there are no CARB requlremente to Install any additional exhaust after-treatment devices on our urban bus fleet. Future bus purchases utilizing diesel engines will require Selective Catalyst Reduction (SCR) strategies as part of the exhaust system from engine manufacturers. These SCR systems utilize Diesel Exhaust Fluid (DEF) which Is a non-toxic liquid made up of purified water and 32.5 percent automotive grade urea. This fluid Is then sprayed Into the exhaust system during operation to reduce NOx. AC Transit will need to establish an Infrastructure for this DEF as part of the next diesel bus procurement.

GM Memo No. 10·214 Meeting Date: September 22, 2010 Page 3 of3

Under current regulations, 15% of all new annual urban bus purchases must be ZBuses. The purchase schedule begins with the model year 2011 for agencies on the diesel path and continues through 2026. However, In January 2010, CARB notified all transit agencies wHh a Regulatorv Adylsor:y that until the commercial .readiness can be assessed, CARB does not intend to enforce the zeus purchase requirement. A public hearing process Is set to take place no later than July 2012. Prior to this meeting, CARB will announce public workshops to share progress and foster stakeholder feedback.

Prior Relevant Board ActlonsiPollc!es: None

Attachments; None

Approved by: Mary v. King, Interim General Manager Kathleen Kelly, Chief Operating Officer

Prepared by: Michael Flocchlnl, Training and Education Manager Stuart Hoffman, Manager of Technical Services and Maintenance Training


Attachment 3 Fleet Rule for Transit Agencies

f·":'· ·1:

Callfomla Environmental Protecllon Agency

0Jt Air Resources Board FACT SHEET

Fleet Rule .for Transit Agencies Transit Fleet Vehicle Requirements

title 13, California Coda of Regulations, sections 2020, 2023, 2023.2 & 2023.4

Purpose Reduce public exposure to diesel particulate matter (PM) and nitrogen oxide (NOx) emissions from Transit Fleet Vehicles.

What Is a Transit Fleet Vehicle? On-road vehicles operated by a public transit agency, less than 35' in length and 33,000 gross vehicle weight rate (GVWR), but greater than 8,500 GVWR, powered by heavyduty engines fueled by diesel or alternative fuel; including service vehicles, tow trucks, dial-a-ride buses, paratransit buses, charter buses, and "commuter service" buses operated only during peak commute hours with 10 or fewer stops per day. Gasoline-powered TFVs are exempt.

PM Reduction Regulation A transit agency shall make percentage reductions in the total diesel PM emissions of its diesel transit neat vehicles (TFV) relative to its January 1, 2005, total TFV fleet diesel PM baseline by the dates shown below.

NOx Reduction Regulation A transit agency shall not operate transit fleet vehicles with a NOx fleet average exceeding specified levels by the dates shown below.

(reduction from 1/1/2005 baseline) 40% 80%

I NOx (grams/bhp·hr) II 3.2 12> 2.4 13>

11> Non-Compliance may be subject to civil penalties as specified in state taw and regulations

(2) 1997 and earlier model year engines may be retired by 12/31/2007 to comply wilh lhis requirement

(3) 2001 and earlier model year engines may be retired by 12/31/2010 to comply with this requirement

A Transit Apency Must Report TFVs owned, operated or under contract to a transit agency every January 31', starting in 2006.

To Obtain Emission Reductions: • Use Alternative Fuels Compressed natural gas (CNG), propane (LPG), ethanol, methanol,

gasoline (when used in hybrid electric buses), hydrogen, electricity, fuel cells, or advanced technologies that do not rely on diesel fuel, can be used to reduce PM and NOx emissions to meet the compliance deadlines.

• Retrofit. Repower or Replace Diesel Emissions Control Strategies (DECS), e.g., verified Diesel Particulate Filters (DPF) or verified fuels such as PuriNOx, may be installed or used on TFVs; or repowering and replacing TFVs with engines that meet 2007 heavy-duty engine exhaust emission standards may be performed.

~:~r·~· '·

"'"·

Attachment 4 Transit Fleet Vehicle Rule

California Environmental Protection Agency

0lt Air Resources Board FACT SHEET

Fleet Rule for Transit Agencies Urban Bus Requirements

title 13, California Code of Regulations, sections 1956.1, 2020, 2023, 2023.1 & 2023.4

In February 2000, the Air Resources Board adopted the Fleet Rule for Transit Agencies and more stringent exhaust emission standards for new Urban Bus (UB) engines and vehicles. The regulation also promotes advanced technologies by providing for zero-emission bus (ZEB) demonstration projects and requiring ZEB acquisitions applicable to larger transit agencies.

What Is an Urban Bus? An UB is a passenger carrying vehicle owned or operated by a public transit agency, powered by a heavy heavy-duty engine, or of a type normally powered by a heavy heavy-duty diesel engine, intended primarily for intra-city operation. A bus normally powered by a heavy heavy-duty diesel engine is usually 35 feet or longer, and/or greater than 33,000 pounds gross vehicle weight rating (GVWR).

Urban Bus Engine Standard. New UBs operated in California are required to have engines that meet the more stringent California UB engine exhaust emission standard through the 2006 model year, after which, starting with the 2007 model year, the standard aligns with the California heavy-duty engine exhaust emission standard.

Fuel Path. Transit operators are required to choose a fuel path: diesel or alternative fuel. Fuel path choice affects UB purchases and dictates emission reduction deadlines.

• Alternative Fuel Path. At least 85% of annual UB purchases shall be fueled by alternative fuel. Alternative fuel includes compressed natural gas (CNG), propane (LPG), ethanol, methanol, gasoline/electric hybrid, hydrogen, electricity, fuel cells, or advanced technologies that do not rely on diesel fuel.

Reporting Requirements. A transit agency must report every January 31'1, starting in 2003 through 2016, the UBs owned, operated, or under contract to the transit agency as of January 1 of that year.

NOx Fleet Average. As of October 1, 2002, a transit agency shall not operate a UB fleet with a NOx fleet average exceeding 4.8 g/bhp-hr.

PM Reduction Requirement. A transit agency shall make percentage reductions (below) in the total diesel PM emissions of its diesel UB fleet relative to its January 1, 2002, total UB fleet diesel PM baseline:

Fuel Path

Diesel

Alternative fuel

Reduction from 2002 Baseline as of January 1st

2004 ~ 2006 2007 2008

40%

20%

60%

40%

85%*

60%

•or meet 0.01 g/bhp-hr times the total number of diesel buses in the active fleet.

85%'

Ultra Low Sulfur Fuel. Since July 2002, transit agencies are required to use ultra low sulfur diesel which contains less than or equal to 15 parts per million sulfur content by weight .

Zero Emission Bus Purchases. Begins July, 2008, and affects fleets with greater than 200 UBs.

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