“This question is really more about the strategies a fleet operation must employ to meet regulations in effect at acquisition time, as well as applying diligent forethought to ensure the spec meets future regulations.” –Ken Gillies, truck engineering manager, GE Capital Fleet Services
If there is anything more convoluted or fraught with potentially expensive missteps facing a fleet manager today, it’s got to be complying with emission regulations – both at the state and federal level, I might add. One of the big challenges in the emissions arena is dealing with myriad rules promulgated by the California Air Resources Board (CARB) that are affecting commercial trucks in various ways.
A week or so ago, Ken Gillies – truck engineering manager at GE Capital Fleet Services – painstakingly put together detailed answers to a bunch of questions I had about how CARB’s rules impact truck spec’ing decisions; in no small part because California’s rules go above and beyond federal emission rules in many cases, posing some costly dilemmas for fleets not only based in the Golden State but for those hauling freight in and out of there as well.
The resulting story I wrote, though, had to be brief out of necessity [there isn’t THAT much space on our web site, you know!], but its brevity left a lot of unanswered questions in the minds of some readers. I’ll share one such comment with you:
“Ok, so there are changes coming. Details, details; Please provide substance! What are the changes? Your story is nothing more then [sic] scare tactics unless you provide detailed info to support the story. What are the changes? What trucks are effected (it's not JUST class 8). When do these changes to existing trucks start? When do new vehicles change?”
With that in mind, I’ve laid out the entire Q&A with GE Fleet’s Gillies below. Note, however, that he told me his answers are for general informational purposes only and fleets should not make decisions based just on this data alone. “Each [truck spec’ing] situation is unique and readers are encouraged to insure that they have discussed their compliance obligations with their own professional advisors,” Gillies stressed.
With that in mind, though, here’s his take – from a truck spec’ing perspective – on the potential fallout from CARB’s and the Environmental Protection Agency’s (EPA) various emission control regulations:
Q: CARB has been releasing a bunch of new mandated regulations for heavy-duty trucks. In essence, do you think all of these rules will basically force the creation of TWO types of commercial trucks – ones that can operate in 49 states and ones that can operate in California?
First I’d like to clarify the information I’m providing is focused on medium and heavy-duty trucks – Classes 4 through 8. Additionally, it’s important to understand that a number of the California-specific regulations mandated by CARB are narrowly focused on Class 8; sleeper-berth tractors pulling 53-foot (or longer) dry or refrigerated van trailers. This is especially important when thinking about the GHG [greenhouse gas] emission reductions measures – also referred to as “EPA SmartWay Specs.”
It’s possible some fleets may pursue the California and non-California configuration solution. However, the logistics of ensuring a non-California configuration truck doesn’t end up in California could be difficult to monitor. When considering that potential daily fines for a non-California-configured vehicle could be thousands of dollars, the incentive to develop a two-spec operation may drop considerably.
There are multiple factors to consider. For example, a fleet may have infrequent trips into California. As a result, outsourcing those trips to another carrier, or renting a 2010 emissions-equipped truck could be considered.
Q: As a truck engineering expert, will CARB's slate of rules add more cost and required upfitting to the trucks slated to meet 2010 emission rules ... or will fleets still be able to buy a truck compliant with federal 2010 emission rules and use them in California?
There are certainly up-front cost implications for the 2010 emissions-equipped truck chassis (applies to both straight trucks as well as tractors). Depending on the chassis manufacturer as well as the engine manufacturer, cost increases are ranging from about $6,000 on a medium-duty truck (Class 6 or 7) to about $9,000 for a heavy-duty class 8 tractor. Comments from the truck OEM community around cost increases are typically emphasizing fuel economy improvements gained from the 2010 emissions-equipped truck versus the 2007 emissions-equipped version as a way to mitigate some of the cost impact.
Additional up-front costs that are a bit less obvious include possible increases in wheelbase and cab-to-axle (CA) dimensions in certain configurations to allow room for the diesel exhaust fluid (DEF) tank and the dosing system. The need to re-mount the DEF tank to accommodate certain upfitting specs could affect installation time and costs. In addition, some reduction in payload will need to be addressed because the dosing system and tank with fluid will add about 175 pounds in Class 3 and 4 trucks to 350 to 400 pounds in the highway tractor configuration. For weight-sensitive bulk product transporters, this is a significant matter.
Recent truck spec’ing activities with our customers who utilize Class 3 thru 5 trucks (10,001 lbs. thru 19,500 lbs. GVWR) equipped with service and/or crane bodies show loss of some cubic capacity in certain compartments, while at the same time the truck’s empty weight increases. These operators of service body-equipped trucks frequently have limited access to scale the truck and, as a result, they run an increased risk of unknowingly exceeding the GVWR.
Trucks built after January 1, 2010 are required to comply with the federal EPA Diesel Emission standards for 2010 (applies to diesel powered trucks from 8,600 lbs. GVWR and up). Trucks built after January 1, 2010 also align with CARB regulations as they exist today.
It’s important to know the federal EPA 2010 emission regulation focuses on tailpipe emissions of particulate matter (PM) and other gases such as oxides of nitrogen (NOx). California-specific regulations that apply to Heavy Duty Vehicle Idling Emission Reductions, GHG Emissions Reduction Measure, TRU ATCM (Truck Refrigeration Unit Airborne Toxic Control Measure) also apply to diesel-fueled TRUs and TRU generator sets operating in California.
The California regulation applies to trucks that travel in California regardless if they are registered inside or outside of California and includes all carriers that transport perishable goods using diesel-powered refrigeration systems on trucks, trailers, shipping containers and railcars operating in California. Emissions reduction from certain existing trucks and buses (diesel vehicles greater than 14,000 lbs. GVWR and certain yard trucks, shuttle vehicles and out-of-state trucks and buses operated in California) are not considered in this regulation.
Fleet managers should clearly understand these regulations since a truck that complies with federal EPA 2010 standard could fall outside one or more of the California-specific regulations. California regulations have varying time schedules for implementation and in the case of the CARB’s “Reduction of Emissions from Existing Diesel Engines,” the compliance schedule extends beyond 2020.
Q: How are CARB's separate and more stringent rules affecting the spec'ing plans for national fleets?
At GE Fleet, we’ve spent significantly more time working with our customers and OEMs regarding CARB rules and spec’ing trucks to help customers make well-informed decisions.
Specification changes with wheelbase and California exhaust system routing, air tank positioning, driveline configurations, fuel tank size and placement are some of the first areas affected. Available space on the frame for mounting equipment also changes when considering auxiliary power units (APU’s) in tractor configurations.
We continually suggest options for customers to consider regarding driver comfort when drivers must use the sleeper berth without running the truck engine. Most OEMs have developed proprietary systems to heat and cool the sleeper without the need for an APU. Cost is a continual factor, and our engineering team provides our customers with cost analysis for available options.
The final step in our spec’ing process is a detailed review with the customer to be sure they are comfortable with the spec they’ve chosen.
Q: How are you helping fleets get trucks compliant with CARB rules?
A GE customer in the home heating oil delivery business has been working on plans with one of our senior engineers for over a year developing solutions to their truck needs when only 2010 Federal EPA emission engines are available. The loss of frame rail space and payload are this customer’s primary concerns.
Customers with trucks in virtually every class and application have been continually increasing their level of involvement and collaboration with our engineers since the beginning of the year. Requests vary from a simple “what’s this all mean to me?” to “I need to get orders slotted in order to get ahead of the 2010 regulations (and price increases) and also develop specs for my ongoing needs after these regulations take effect.”
We’ve found the most efficient and effective approach is a careful balance between educating while simultaneously applying that education to the actual spec development process. Immediate application of our knowledge gained has proven valuable because we’ve been able to continually improve efficiency, thereby benefitting customers with faster answers and more lead-time for their decisions. It also helps customers with additional time to interact with their companies’ operations and build higher acceptance of the changes that are coming.
In spite of the initial GHG Emission Reduction requirements taking effect January 1, 2010, the level of awareness we’ve seen is relatively low. This is understandable since the requirements impact a minority of GE’s customer base. In an effort to better prepare our customers for this particular regulation, our engineering team has been offering specs that include the EPA-compliant SmartWay specs for both tractors and trailers since early this year. The SmartWay spec is also being offered to customers who are not based in California in an effort to assist them in their efforts to reduce GHG emissions as well as reduce fuel costs. Many of our customers have embraced this dual spec offering.
For fleets that already spec engines that meet the “Idle Time Limit” regulations, there’s little effect. Similar to our SmartWay spec practice discussed previously, we also point out these regulations and various implementation levels in a majority of the states – even at the metro area level where different versions of regulations may exist.
Q: Are CARB's rules making it harder to retrofit older trucks in a cost effective manner
Yes, the cost to make the changes doesn’t appreciably improve the value of the chassis. In some cases, financing assistance to perform the retrofitting may be difficult to obtain.
Q: Are they basically forcing fleets to buy new 2010 compliant vehicles?
A fleet manager recently commented that he runs his tractors (for local and regional delivery) up to 20 years or more and this regulation does in fact “force” him to alter his company’s replacement cycle. He feels the cost burden will make it very difficult to maintain the same levels of service and the cost of the products his company carries will be negatively impacted. He expressed frustration in the state of California’s (apparent) lack of consideration for the financial impact this will have on his business and other businesses in similar operating conditions.
Most fleets use replacement cycles that are shorter than the CARB requirements for retrofitting older diesels. The impact of this regulation will be felt more by private individuals and small fleets that keep their vehicles longer.
One market segment in California that will feel a significant squeeze is the agricultural businesses operating “cab-over-engine” (COE) tractors to enable use of 57-foot trailers. The compliance schedule for these trucks will depend on the model year of the truck’s engine. Since there’s little option to replace these COE trucks with new ones because they are no longer available, retrofitting or discontinuing use of the 57-foot trailer becomes the only option. CARB is offering some financial assistance programs to help offset the cost of these retrofits. Documentation to apply for financial assistance is extensive; however, the money available to a fleet that invests in this effort can be a major benefit.
Q: Of all the regulations CARB is putting out there – including the 2010 Diesel Exhaust Emission program, Heavy Duty Vehicle Idling Emission Reduction Program, Heavy Duty Vehicle Greenhouse Gas (GHG) Emissions Reduction Measure, and Truck and Bus Regulation Reducing Emissions from Existing Diesel Vehicles measure – which ones will be the most expensive for fleet compliance?
The GHG (Smartway) program and the Truck and Bus Regulation (retrofits) will likely be the most expensive for a fleet to meet the regulations.
Q: Which one is the most difficult to comply with from an engineering perspective?
This question is really more about the strategies a fleet operation must employ to meet regulations in effect at acquisition time, as well as applying diligent forethought to ensure the spec meets future regulations. The truck engineering challenge is to help customers be well-informed and able to understand how the sliding scale of requirements impacts the spec and vehicle lifecycle.
With 18 other states strongly considering similar CARB regulations, it is important to create specs that align with CARB regulations to fullest extent possible even if the fleet doesn’t operate in California. Costs of either retrofitting or in some cases having to prematurely cycle a truck out of the fleet may drastically alter the lifecycle cost as projected at acquisition time.
Once again, our expertise is applied to aid the customer’s understanding and enable them to make well-informed decisions.
Q: Which one creates the more tricky tradeoffs to make the vehicle compliant?
The GHG Reduction regulation coupled with the Emission Reduction [rule for] existing diesel engines creates a formidable challenge. The GHG regulation impacts spec development to ensure the truck meets applicable regulations at the time the truck goes into service. Additional challenges reside in maintaining that match-up as various future dates arrive with additional regulation requirements.
The "Emission Reduction" regulation requires looking at the age of trucks currently in operation and their proposed replacement timing. I believe this effort may be the most challenging because it combines the past, present and future with the constantly changing regulations and target dates.