Some background to this is necessary first.

CARB has two programs in place specifically designed to reduce emissions from urban buses. One program affects emissions from new urban buses and the other program affects emissions from in-use urban buses operated by transit agencies (Fleet Rule for Transit Agencies).

In February 2000, the Board adopted a fleet rule for transit agencies operating urban buses, and more stringent emission standards for new urban bus engines and vehicles (ARB 1999; ARB 2000b).

The rules were designed to reduce emissions of NO_x and PM by setting fleet emission reduction requirements that would require the purchase of cleaner engines and the retrofit of existing engines.

By 1 January 2001, transit agencies had to choose to follow either a diesel path, or an alternative fuel path. The decision was to be non-revocable, and would establish purchasing requirements for the transit agencies through 2015.

The rule also promoted advanced technologies by adopting requirements for zero-emission bus (ZEB) demonstrations and acquisitions applicable to larger transit agencies.

New, more stringent mid- and long-term emission standards were also adopted that apply to new urban bus engines. The rule also encourages the purchase of diesel hybrid electric buses from 2004 through 2006 by diesel path agencies.

Both the EPA and California have established increasingly stringent emissions standards for heavy-duty vehicles and urban buses. The California standards for buses are, however, more stringent than the EPAs in the area of upcoming NO_x limitations for 2007.

CARB is beginning to doubt, based on their discussions with diesel engine manufacturers, that achieving this 0.2 g/bhp-hr level of NO_x emissions from diesel engines in 2007 is possible.

The California and national heavy-duty truck new engine standard for 2007, which includes urban buses for all but California, is also 0.2 g/bhp-hr. Flexibilities in the heavy-duty truck rule, however, result in the option of certifying all engines to an average NO_x standard of 1.2 g/bhp-hr between 2007 and 2009. This is what engine manufacturers have stated they plan to do, so it is unlikely, in CARB’s current opinion, that diesel engines meeting California’s urban bus NO_x standard will be available in 2007.

If that were to prove to be the case, then without some modification of the ruling, transit fleets that had chosen the diesel path would be unable to purchase new diesel buses for those three model years (2007, 2008, 2009). The assumption is that by 2010, when both the Federal and California standards are the same, diesels meeting those requirements will be available.

To avoid the of mandating the purchase of engines that don’t exist, ARB is proposing three options.

1. Keep the current new urban bus emissions standards as they are. Diesel agencies would buy no new diesel for MY 2007–2009, and make up for those deferred purchases in 2010–2012 when diesel engines are again available.

2. Realign the NO_x emission standard for 2007 through 2009 model year new urban buses with the federal standard by raising it from 0.2 g/bhp-hr to 1.2 g/bhp-hr.

3. Require all transit agencies to purchase/lease only alternative fuel buses. This option would mandate that at least 85% of a transit agency’s annual purchases be alternative-fueled through 2015.

   Although theoretically a transit agency could purchase only alternative-fuel buses from 2007–2009 and then switch back, the practicalities of supporting an alt-fuel infrastructure lead ARB staff to conclude:

   If a requirement were adopted that required all transit agencies to follow the alternative fuel path, staff believes transit agencies would be forced to purchase alternative fuel engines in 2007 and later.

CARB evaluates the options, in terms of impact on emissions, as follows:

• Option 2 (revise the NO_x standard to 1.2 g/bhp-hr) provides reductions in emissions in each year from 2007 through 2010 compared to option 1 (no change), culminating in cuts of some 1.6 tons per day in 2009. This reduction occurs because 1.2 g/bhp-hr new engines replace higher emitting older engines, whereas in option 1 no new engines are purchased by diesel path agencies until 2010 or later, and higher emitting buses remain in operation.

• However, once the deferred cleaner diesel purchases are made in 2010 and beyond, Option 1 provides slightly greater reductions than option 2 from 2012 on, reaching up to about 1.2 tpd. By deferring purchases until 2010 or after, all purchases are 0. 2 g/bhp-hr engines, whereas the buses purchased in 2007–2009 (option 2) have higher emissions (1.2 g/bhp-hr). CARB estimates that by 2025, there will be no difference in emissions because all engines remaining in the fleet are 0.2 g/bhp-hr (i.e. any 1.2 g/bhp-hr engines are over 15 years old and have been replaced).

• Option 3 (require all diesel path agencies statewide to switch to the alternative fuel path) provides the lowest emissions. Compared to option 1, option 3 provided emission reductions in each year 2007 through 2011, reaching about 2.6 tpd in 2009. Compared to option 2, option 3 will provide lower emissions until 2025, reaching a maximum of about 1.0 tpd in 2009.

  CARB does note that agencies previously on the diesel path will have to invest in new alternative fuel infrastructure, and this could result in deferred or forgone purchases, which would reduce the emission benefit of this option.

Forty-eight (63%) of the state’s 76 transit agencies that report to ARB under the fleet rule are using diesel and would be affected by a change. The remaining 28 agencies on the alternative fuel path (37%) would continue as originally conceived, as CARB believes that conforming engines will be available in the 2007–2009 period.

The proposal of the alternative fuel option evoked a strong response (not surprisingly) from transit agencies that had gone down the diesel path, and now feel that CARB is proposing to change the rules of the game at potential great cost to the agencies.

The San Jose Mercury News, reported that the Bay Area Metropolitan Transit Commission is estimating that the new rule would cost the region roughly $300 million in the short term to buy, to operate and to maintain the required CNG buses.

The San Francisco Chronicle notes that AC Transit, the agency serving Alameda County (Oakland), has already spent some $120 million on improving its diesel fleet, and is a fierce opponent of the alternative fuel option.

The Staff presentation to the Board will be available on the ARB site the day of the meeting.

Resources:

• CARB Staff Initial Statement of Reasons