Summary of Recent CIAQC Activities of Interest to CRA Members

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Memorandum
To: CIAQC Board
Re: Truck & Bus Regulation

Over the last four weeks CIAQC has focused much attention on CARB and the On-Road Truck Regulation. On December 16th CIAQC meet with CARB staff in Sacramento to discuss several significant implementation issues for the Truck & Bus Regulation and testify at the CARB Board Hearing---the staff met with us prior to our Board testimony in the "CIAQC Office" in the cafeteria. This followed the December 6, 2011 CIAQC letter to Governor Brown outlining the detailed concerns including retrofit filter safety, and the numerous problems with the ability of fleets to register their trucks using CARB's on-line reporting system along with and CARB's lack of outreach on the implementation of the regulation and tight deadlines that were emerging.

At the December 16th hearing CARB staff indicated to its board that it will work with CIAQC to try and address our concerns. Three days later CIAQC representatives, Lee Brown, Betty Plowman, Hank deCarbonel and a couple other members had a conference call with Erik White, Tony Brasil and staff. From that call CARB developed a list of action items it committed to address and follow-up with us on. Here is the 'to do' list from that call:

•Need clean version of the regulation (now posted at http://www.arb.ca.gov/msprog/onrdiesel/regulation.htm)
•Guidance on what brokers need from truck owners as proof of compliance (reporting certificate and or picture of engine family if not reporting)
•Alternative to having all fleets report so they can obtain certificate of reported compliance
•Corrections/updates to fleet calculator
•Reporting system related issues
•Continue to monitor reporting rates to evaluate need for reporting delay
•Confirmation of complete reporting or compliance certificate
•Data upload feature
•Process for retrofit exemptions
•By vehicle class and individual vehicles
•Provide more intensive training (ie, ARB staff and/or Sean Edgar with CleanFleets).
•Establish a more concrete division between program and enforcement staff.
•Request to CARB to consider creating a TruckStop-like web page/portal for the construction sector
 
On Friday, January 6, 2011 Mike Lewis, John Dunlap and Clayton Miller had a conference call with Cliff Rechtschaffen, Special Advisor to the Governor and Matt Rodriquez, Secretary of Cal EPA. During the 50 minute call we explained the concerns construction has with the implementation timeframe of the regulation and the quickly approaching January 31, 2012 reporting deadline for fleets that using the alternative compliance path (rather than the BACT percentage path). We covered several points about diesel particulate filters, including the lack of available data loggers required to profile each engine before it is matched with a filter, how CARB filter verifications only address emission reductions and not how they are installed, maintained and operated safely. We provided a couple of examples of safety problems with onroad filters. We did not suggest how that problem should be addressed, but mentioned that there were safety installation issues with DPFs for off-road equipment (operator visibility) and ultimately standards set by Cal OSHA addressed the issue (after CARB refused to acknowledge or act on the problem).

Messrs. Rechtschaffen and Rodriquez committed to discussing our concerns with CARB and following-up with us soon.

On Tuesday, January 10 CIAQC had its second call with Erik W., Tony B., Paul Jacobs and other CARB staff to cover the issues outlined above. During the call CARB indicated that it will extend the reporting deadline, and we just learned late this afternoon it will be extended to March 30, 2012 and the upload feature is now available in the reporting system so larger fleets can upload their vehicle information in batches. The follow-up from CARB staff on these issues of late has been about the best/most-responsive we have ever seen. The January 1, 2012 compliance deadline remains in place. There are other reporting and compliance issues that we will still need to address with CARB including the requirement to report trucks that have future compliance dates and the growing realization that many older trucks lack engine identification plates necessary for reporting and compliance---and we are pursuing these aggressively. Replacement plates are obtained from manufactures at cost reported to be $300 a piece.

We have another follow-up call with CARB for early February, and will cover these and other issues that will be discussed at the next CIAQC meeting on Tuesday, January 31.

Please let us know if you have any questions or concerns you wish to discuss before our next board meeting.