ARB Proposed Truck Emission Rule

A statewide proposal to require older diesel trucks to be phased out could have a big impact on farms and other transportation-related components of the agricultural sector.

Truck Rule development continues

The California Air Resources Board (ARB) staff is continuing development of the “Regulation for In-Use On-Road Heavy-Duty Diesel-Fueled Vehicles” (truck rule), which is scheduled to be heard by the Board on Oct. 23. Although the rule has evolved since the initial drafts were released last year, the proposal will still place a large burden on the California agricultural industry in California.

The proposal would require all diesel trucks, busses and farm specialty vehicles (excluding farm tractors) operating within the state with a gross vehicle weight rating greater than 14,000 lbs to meet 2010 engine standards. The only exemption is for those vehicles under 14,000 lbs or those that are “low-use vehicles” that operate fewer than 1,000 miles and less than 100 hours a year. Certain vehicles also may be exempted from NOx requirements but still have to meet PM requirements.

Fleets with more than three vehicles will have the opportunity to average their fleet emissions, giving them additional time to meet the rule requirements.

Agricultural groups express concerns

Agricultural organizations, including FCFB, have expressed many points of concern and questions with the new rule, including:

In order to comply with particulate matter (PM) emission standards under the proposed CARB regulation, truck owners will be required to install PM filters or upgrade/retrofit engines to reduce PM emissions. The retrofits are similar to those now pre-installed on newer model pickups. PM filters cost from $10,000 - $20,000. ARB has a pre-approved list of vendors that produce aftermarket filters, however, only a handful of these vendor’s technologies are approved to meet the highest level of compliance. The industry is concerned that a lack of available supply and competition among vendors may dramatically increase the price of retrofits once the rule is promulgated. Will ARB force owners to buy aftermarket parts if there is only one supplier?
Does the technology currently exist to meet the NOx and PM standards required under the rule? Is there a device available that can be installed on a 2004-2006 model to meet 85 percent NOx reductions? Should ARB promote compliance mechanisms that do not currently exist in the marketplace?
Farmers and ranchers are concerned that PM filters or retrofitting existing engines may cause engine malfunctions and reliability issues. Farmers and ranchers use vehicles off-road and often times in remote areas that are far from cell phone or automotive service areas.
Installing PM filters or retrofits on diesel trucks intended to be used off-road presents a serious danger. In order for PM filters to work effectively, the retrofit must reach extremely high temperatures when in operation. Trucks traveling off-road or through grassland areas could consequently pose a serious fire danger due to the extreme temperature of the retrofit device.
PM filters require occasional cleaning and maintenance. Emissions not burned off in the normal operating cycle that remain in the filter are classified as a hazardous waste. Farmers and ranchers will not be able to transport filters to service stations because they are not properly licensed to transport hazardous waste materials. As part of the rule, farmers and ranchers should not be required to obtain a hazardous waste transportation permit to transport PM filters to service stations for required cleaning and maintenance.
Because farmers and ranchers drive fewer miles on average and many use trucks seasonally, they will likely be forced to purchase even more expensive retrofits than the standard retrofits. PM filters for trucks that are not used constantly and incur low miles are required to be plugged into an electrical outlet when not in use to burn off emissions. This creates a major burden for those that store or secure vehicles in fields or remote parts of the farm or ranch that do not have access to a main power source. Has ARB taken into account the purchase of these more expensive filters in the economic analysis?
Why were hours of use sufficient for reporting operation of low-use vehicles in the off-road diesel vehicle rule recently promulgated, but GPS is required in this rule?
What will be the cost of an electronic tracking system including the collection and reporting of the records by an independent entity?
In most cases, farm specialty vehicles are not required to be registered, therefore how was the emissions inventory determined to propose a NOx and PM requirement or the economic impact of replacing and monitoring these engines with GPS?
Why are specialty vehicles, like lift carriers and row dusters that have no engines, included in this emissions reduction rule?
How does ARB expect this rule to impact small business owners and farmers and ranchers that cannot take advantage of the fleet averaging option because they only own and operate one vehicle?

California Environmental Protection Agency-
Air Resources Board Website:
On-Road Heavy-Duty Diesel Vehicles (In-Use) Regulation

Air District offers funding program for diesel engine replacements or retrofits
[Click on Proposition 1B: Goods Movement Emission Reduction Program]

Air Resources Board’s Diesel Truck
Bus and Vehicle Rule - Some questions/points of concern [PDF]

A summary regarding the state's proposed diesel truck and bus rule. [PDF]

As you will see from the summary, the complete proposal is not easy to summarize as it is very complex and how it will effect the agricultural community will depend on the makeup of each fleet (age, size, number, etc.) .

We are urging farmers and farm related businesses to visit the CFBF website and fill out the surveys in order to demonstrate accurate financial costs that this regulation would have if implemented as is.

Your voices need to be heard on this issue so that ARB can better understand how this proposal could impact your operations, costs associated with replacing trucks with a brand new vehicle, as well as the number of miles traveled per year per affected trucks. Your help is a key component to emphasize just how devastating this regulation will have upon a farmer’s long-term economic viability. For additional information please contact Teresa Plascencia at (559) 237-0263 or at teresap@fcfb.org