California proposes reefer emissions project

Aug. 1, 2004
The California Air Resources Board has directed its staff to develop a plan that will allow fleets to use various methods to meet the regulatory goals

The California Air Resources Board has directed its staff to develop a plan that will allow fleets to use various methods to meet the regulatory goals of the state's recently adopted Transport Refrigeration Unit Airborne Toxic Control Measure.

The measure is targeted at places where refrigerated trucks are concentrated — such as refrigerated warehouses. To date, it has not been applied to trailer dealerships.

Fleets are being allowed to adopt their own plan as an option to waiting for a state mandate. These proposed processes — considered Alternative Technology Compliance Plans — may require extensive and costly infrastructure installations or modifications such as electric standby for refrigeration units at distribution centers or the use of purely cryogenic or hybrid cryogenic refrigeration systems.

The process for consideration of alternative compliance plans was developed following meetings with numerous interested parties including refrigeration unit manufacturers and large fleet operators such as food distributors. The proposal allows distribution center operators to participate in demonstration projects that show real, verifiable, and enforceable reduction in refrigeration exhaust emissions to meet or exceed state limits.

To participate in such a demonstration project, distribution center operators are asked to file an application for an alternative technology compliance plan with the California Air Resources Board. The state takes pains to stress that no state funding is available for such pilot projects and that applicants seeking to participate must provide funding.

An application for such a proposal must include details for facility operating procedures, emissions monitoring, record keeping and a process for reporting on reductions. Applicants would be responsible for showing that any alternative plan would result in emission reductions that are at least equivalent to state requirements and that when full compliance is reached emissions at distribution centers would be near zero.

If a pilot project were approved for testing, the distribution center operator would have to include enough units in the test to show that the alternative plan could succeed under a range of operating conditions. Applications for participation in alternative technology projects must be submitted to the state by December 31, 2004. Application approvals or rejections will be announced by February 28, 2005. Approved pilot projects must be complete and reports submitted by June 30, 2006.

Applications must be specific and include the names and proposed roles of all participants and sponsors. They must describe the type of technology to be tested along with a detail plan and schedule for the project. Participants must show that the project will reduce exhaust emissions, especially particulates, hydrocarbons, and oxides of nitrogen. The emission reductions must be real, verifiable, and enforceable.

Proposals for demonstration projects must show that the plan would be representative of a large fleet. The application must include the number of refrigeration units proposed for the project and must include a list of refrigeration unit model numbers, the model numbers of engines powering the units, and the model year for each unit. To ensure that the tests can be verified, the application must include the vehicle identification numbers for each unit assigned to the test.

In addition, any application must describe the proposed test site in detail showing the property boundaries, parking areas, and location of refrigerated loading docks. This description must show the locations of refrigeration units in relation to the sensors used to monitor emissions. This part of the application must include a baseline showing total refrigeration unit engine hours and engine hours of units at the distribution center for comparison to data gathered during the demonstration project.

Applications for demonstration projects must provide data on delivery locations as well as the distribution center where the refrigeration units are based. It must describe where deliveries are made and estimate the number of hours that units operate at delivery sites. Applications must provide details on the number of deliveries per week, per month, and per year for each delivery site.

An application for an alternative technology project must describe how the plan is to be implemented, starting with calculation of emission baselines prior to the start of the test. This would include a schedule for infrastructure modification that begins before the state compliance date for refrigeration unit exhaust emission reductions. The plan must calculate how much emissions will be reduced during each proposed phase of the plan and show a cumulative result. In addition, the application must estimate the long-term effects of the alternative technology plan after it is fully implemented.

The state of California has already set in-use performance standards for refrigeration unit emissions that become effective in 2008 for units manufactured before 2001. The standard for units from model years following 2002 goes into effect in 2009.

Finally any application for an alternative technology compliance plan must provide a list of the materials and resources required for the project and an analysis of the plan's cost-effectiveness. All costs, capital and operating, must be included. In particular, this information must include the cost of data logging, record keeping, and reporting to the appropriate authorities.

Following completion of any demonstration project, the California Air Resources Board will evaluate the results. If the plan is successful, the state will issue an order that allows the alternative technology plan to be placed into large-scale implementation. The state will also determine if the alternative technology plan should be limited to the single site used in the test or if it can be implemented at other locations.

Applications to participate in an alternative technology compliance plan should be forwarded to the California Air Resources Board, ATTN: Dan Donohoue, Stationary Source Division, P O Box 2915, Sacramento CA 95812-2815.