Response to House Select Committee Hearing, “Solving the Climate Crisis: Cleaning Up Heavy Duty Vehicles, Protecting Communities”
Diesel retrofits offer a number of benefits over other emissions reduction strategies, including cost effectiveness and immediate, significant reductions.
While the environmental performance of diesel engines is constantly improving, new emissions standards only apply to new engines. However, because diesel is truly the workhorse of the American economy - with engines often lasting hundreds of thousands of miles or running for hundreds of thousands of hours - a sizable fleet of equipment manufactured over two to three decades ago is still in operation. Fortunately, many of the same advances used to improve new engines can be applied to this existing fleet.
The term “retrofit” covers many technologies and activities to reduce emissions from older engines, vehicles and equipment and has typically been defined broadly. While the term is frequently used as a label describing various exhaust emissions control devices such as the diesel oxidation catalysts and particulate filters, it can also encompass a broader range of options to reduce emissions, including re-powering, rebuilding and in some instances replacing existing equipment.
Rebuild: Engines face normal wear and tear and need to be rebuilt to operate efficiently returning to the manufacturer's original specifications. During the course of a rebuild, equipment owners may choose to install new engine components that improve both the fuel economy and emissions profile. In fact, U.S. Environmental Protection Agency (EPA) rules outline emission requirements on rebuilt engines to insure emissions reductions.
Refuel: Since 2008, the use of Ultra Low Sulfur Diesel fuel (ULSD) has been mandated in the U.S. The use of ULSD greatly reduces sulfur dioxide, a key component in smog, and also allows for the operation of other emission control technologies.
Repower: Replacing an older engine with a new diesel engine that meets the most current EPA emissions criteria will greatly reduce emissions.
Replace: In certain instances, the most cost effective strategy to reduce emissions may be to replace the vehicle or equipment.
Retrofit: The installation of various emission control technologies may also improve emissions from older diesel engines. The mandated use of ULSD has paved the way for many emission control technologies to reduce criteria pollutant emissions from older diesel engines.
Over the past decade, major advances in diesel technologies have resulted in the development of cleaner diesel engines, fuels and retrofit devices that can be installed on vehicles and equipment to reduce in-use emissions by –up to 85 percent, depending on the technology and the characteristics of the vehicle or equipment.
In nearly all cases, the emission reductions are immediate. Planners don't need to wait to see if the reductions actually materialize by monitoring travel behavior - as can be required with many control measures. Diesel retrofit strategies can be particularly important in metropolitan areas where high volumes of heavy-duty trucks are prevalent and/or where major construction projects are underway for long periods of time.
Flexible and Voluntary Programs
A number of voluntary approaches to diesel emission reductions have proved successful throughout the United States that, in contrast to regulatory measures, are less onerous and cumbersome than compliance with regulatory measures. The types of equipment and vehicles retrofit under these programs can include: heavy-duty trucks, forklifts, bucket loaders, tractors, wheel loaders, refuse trucks, transit and school buses and others.
Lack of Infrastructure Requirements
In contrast to many alternative fuel measures, diesel retrofit strategies do not require installation of special infrastructure. Ultra-low sulfur diesel fuel is now available nationwide. Another advantage to diesel retrofits is the ability to easily and quickly install.
Particulate filters are capable of capturing up to 95 percent of particulate matter, or soot. According to the Manufacturers of Emission Controls Association, over 100,000 diesel particulate filters have been sold nationwide since 2001 helping to improve emissions on older and new diesel vehicles and equipment.
Exhaust gas recirculation (EGR) recirculates a portion of engine exhaust back into the engine diluting the oxygen content of the fuel-air mixture. EGR technology significantly reduces both NOx and Particulate Matter.
Selective Catalyst Reduction (SCR) is an advanced active emissions control technology system that injects a liquid-reductant agent, known as Diesel Exhaust Fluid (DEF) through a special catalyst into the exhaust stream of a diesel engine. The DEF sets off a chemical reaction that converts nitrogen oxides into nitrogen, water and tiny amounts of carbon dioxide (CO2), natural components of the air we breathe, which is then expelled through the vehicle tailpipe.
Diesel Oxidation Catalysts (DOC) are similar to converters installed on light-duty vehicles. Exhaust travels through a honeycomb like structure that attracts fine particles. Diesel oxidation catalysts are capable of eliminating Particulate Matter by 20-50 percent. The U.S. EPA estimates that almost 20,000 DOC have been installed on older vehicles and equipment since 2008 making this technology one of the more popular and cost effective retrofit options.
America needs diesel engines and cleaner air; advanced clean diesel technology offers both. Diesel power drives the economy by building our nation's infrastructure of roads and bridges, taking crops from the fields to food on the table, and providing vital transportation of people and goods in the most efficient and cost effective manner possible.
No other technology can match diesel's unique combination of energy efficiency, sheer power, reliability and durability across so many sectors of the economy. In all applications, diesel technology has experienced continuous improvement with increasing performance, lower fuel consumption and lower emissions, making today's technology much cleaner and more efficient than what was available even a few years ago.
The future looks even cleaner. Industry's continued improvements are leading to a new generation of clean diesel vehicles and equipment that will virtually eliminate regulated emissions in both on- and off-road applications. This new clean diesel technology will not only be available in new vehicles and equipment, but can be applied to existing engines, thereby multiplying its benefits. The nation's goals for accelerated improvements in air quality have led regulators to identify the modernizing and upgrading of existing diesel engines as one of the most cost-effective options for achieving emissions reductions.
The modernizing and upgrading of older diesel vehicles through one of retrofit's "five Rs" can help achieve significant, cost effective reduction of criteria pollutants including particulate matter (PM), commonly known as soot, and oxides of nitrogen.
While the air quality benefits of diesel retrofit are strong, the economic benefits are less clear. Large operators may capture the good will and economic value of good corporate citizenship more readily than small operators that face few direct economic or market pressures related to their environmental performance. The federal government provides a significant source of funding for diesel retrofit programs through several programs including: the Congestion Mitigation and Air Quality (CMAQ) Improvement Program, the Diesel Emissions Reduction Act¸ and the Environmental Quality Incentives Program (EQIP). Additionally, many states and localities provide retrofit assistance as well.
Diesel Emission Reduction Act In 2005, Congress passed legislation, the Diesel Emission Reduction Act (DERA), creating a program managed by the U.S. EPA to help diesel equipment owners retrofit older equipment. Congress appropriated $20 million for fiscal year 2014 for the DERA. As part of DERA funding activities, the EPA also manages smaller set-aside programs to improve diesel emissions in construction equipment and port equipment found at work in areas known for poor air quality. Between 2008 and 2012, the U.S. EPA estimates that DERA retrofit activities have improved emissions on over 50,000 vehicles and equipment while reducing 203,000 tons of oxides of nitrogen and 12,500 tons of particulate matter.
Please visit the EPA's DERA National Funding Assistance website to learn more about DERA and state funding assistance. Click to view our 3rd DERA Report to Congress infographic.
CMAQ Improvement Program The other primary source of federal funding for retrofits comes through the Federal Highways Administration. In 1991, as part of surface transportation reauthorization legislation, Congress created the Congestion Mitigation and Air Quality (CMAQ) program to help states with non-attainment areas improve air quality. The legislation lists a menu of possible policies that states and metropolitan planning agencies may use when applying for CMAQ funds through the Federal highways Administration (FHWA). Diesel retrofits are included in that list. The most recent surface transportation reauthorization bill, enacted into law in July 2012, allows states with non-attainment areas for particulate matter to use a portion of their CMAQ funds to retrofit older construction equipment. The provision does not mandate that states do so.
Please visit the FHWA website to learn more about the CMAQ program.
Environmental Quality Incentives Program (EQIP) Congress authorized the EQUIP in the 2002 Farm Bill. The current Farm Bill authorizes funding for the Natural Resources Conservation Service to manage a program to help agricultural equipment owners to retrofit older diesel powered equipment found at work in rural areas with poor air quality. Much like the DERA program, EQIP is subject to the annual appropriation process.
Please visit the Natural Resources Conservation Service website to learn more about the EQIP program.
In addition to federal financial assistance programs for diesel retrofits, many states also provide financial assistance to help the owners of diesel equipment purchase retrofit technologies. Below is a listing of a few of those programs. If you are an equipment owner seeking financial assistance for retrofit technologies, please contact your state department of environment or air quality.
California - Carl Moyer Program The California Air Resources Board (CARB) administers funds to help the owners of heavy-duty diesel equipment purchase retrofit or newer engines that improve emissions. Funds are administered through California's various air districts. Legislation precludes applicants from seeking funds needed to bring non-compliant equipment into compliance with California's air quality regulations for particulate matter, oxides of nitrogen (NOx) and reactive organic gas emissions (ROG). The Carl Moyer Program was reauthorized by the California legislature in 2013 and received $2 billion in funding expiring in 2023.
Thanks in part to the Carl Moyer Program, California is a large market for retrofit technologies. According to the Manufacturers of Emission Controls Association, over 55,000 diesel particulate filters have been installed on diesel vehicles and equipment in California.
To learn more about the program please visit the Carl Moyer Program website.
Texas - Texas Emissions Reduction Plan (TERP) In 2001, the Texas legislature created the TERP to help diesel equipment owners retrofit older equipment. The program is similar to the Carl Moyer Program except that TERP focuses exclusively on the potential for NOx reduction in choosing recipients. The program is funded from title fees on the sale of cars and trucks and various state truck tax revenue and is administered by the Texas Council of Environmental Quality (TCEQ).
To learn more about the program, please visit the Texas Emissions Reduction Plan (TERP) website.
New Jersey - Stop the Soot Campaign On April 11, 2011 New Jersey Governor Christie signed Executive Order #60 creating a pilot project to test the feasibility of mandating the adoption of retrofit equipment deployed on off-road equipment used in a select few public works projects located near large urban centers. At the conclusion of the project in September 2014, a report will be drafted that may recommend that the mandate be adopted at all state public works projects.
Learn more about the pilot project.
Many localities and public authorities also provide financial assistance to owners of specific types of diesel equipment to purchase retrofit technologies or new equipment. Below is a listing of a few local programs.
City of Chicago, Clean Diesel Contracting Ordinance: In March 2011, the City of Chicago passed a city ordinance requiring all contractors on city projects to receive a "Green Fleet Score" designed to reduce emissions. In order to receive an adequate score, contractors must commit to use emission control devices and adopt certain business practices including a prohibition on idling of equipment.
The City of New York: Passed Local Law 77 requiring that all contractors at the Twin Towers project deploy emissions control devices that meet certain minimum emissions standards. In an effort to help contractors and city air regulators comply and enforce the law, the New York State Energy Research and Development Authority (NYSERDA) developed the Clean Diesel Clearing House. The web tool allows contractors to learn how specific pieces of construction equipment may be deployed with emission control devices. The tool also helps regulators enforce compliance with the law. NYSERDA is tweaking the tool for other use by other jurisdictions.
Many large seaports around the country adopted requirements prohibiting older diesel powered trucks from entering maritime facilities. Port authorities provide resources in order to help truck owners purchase newer trucks or retrofit equipment. Below is a digest of requirements:
Los Angeles/Long Beach, California: All trucks entering marine terminals must be deployed with a 2007 model year engine or newer. Both ports generated a $44 million fund to help equipment owners purchase compliant equipment. Additionally, equipment owners looking to purchase equipment operating on alternative fuels may be eligible for funding through the Goods Movement Emission Reduction Funding Program.
Oakland, California: The port prohibits trucks entering facilities with engine model year 1993 or older. The port established a trucker resource center to help equipment owners identify financial resources to offset the cost of purchasing new equipment. Additionally, equipment owners purchasing alternative fueled trucks may also eligible for funding through the Goods Movement Emission Reduction Funding Program.
Seattle and Tacoma, Washington: All trucks entering marine terminals must be deployed with a 1994 model year engine or newer. The seaports established a trucker resource center to match equipment owners with possible grants and low or no interest loans for the purchase of a compliant truck.
Port of Seattle: Encourages equipment owners to contact their truck liaison to identify appropriate financial resources.
Port Authority of New York and New Jersey: The Port Authority prohibits trucks with engine model year 1993 or older from entering marine terminals. The Port Authority also established a grant program to help equipment owner finance the purchase of equipment with 2004 model year engines or newer. Eligible applicants will receive a grant that covers up to 25 percent of the purchase price of a newer truck. They may also qualify for low-interest financing on the remaining 75 percent.
Port of Houston, Texas: The Houston - Galveston Area Council announced that drayage truck owners operating in marine terminals in the area may be eligible for loans administered through the Texas Emissions Reduction Program (TERP). Unlike other seaports, the plan does not prohibit older trucks from entering marine terminals.
The U.S. Environmental Protection Agency has developed a new mapping feature to promote local environmental awareness called MyEnvironment. MyEnvironment provides users with a cross-section of environmental information including data on air, water, energy, and much more.
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