OPTIONS TO ADDRESS AIR POLLUTANT AND GREENHOUSE GAS EMISSIONS FROM IN-USE HEAVY DUTY ON-ROAD AND OFF-ROAD DIESEL VEHICLES AND ENGINES
TABLE OF CONTENTS Executive Summary ....................................................................................................................... i Résumé ......................................................................................................................................... vii Acronyms ................................................................................................................................... xvii Glossary of Terms ...................................................................................................................... xix Introduction ................................................................................................................................... 1
Air pollutant and greenhouse gas emissions ........................................................................... 1 The Mobile Sources Working Group ...................................................................................... 2 Purpose of the document ......................................................................................................... 3 Organization of the document ................................................................................................. 3
Chapter One: Policy and Program Option Overview ............................................................... 5 Chapter Two: Evaluation Criteria .............................................................................................. 7 Chapter Three: Summary of Evaluation Results .................................................................... 12
Remarks on the evaluation .................................................................................................... 12 Chapter Four: Option Profiles and Evaluation Notes ............................................................. 15
1. Vehicles and Engines ..................................................................................................... 16 1.1. Regulations, Standards and Restrictions .................................................................... 16
1.1.1. Emission control system anti-tampering requirements ....................................... 16 1.1.2. Vehicle emission standards/fleet rules for in-use fleet ........................................ 20 1.1.3. Mandatory retrofit/upgrade/replacement regulations ........................................ 24
1.2. Vehicle and Equipment Programs and Practices ........................................................ 29 1.2.1. Programs to encourage use of alternative vehicles and technologies ................ 29 1.2.2. Voluntary retrofit/upgrade/replacement programs ............................................. 34 1.2.3. Scrappage programs ........................................................................................... 39
1.3. Operations and Management Programs and Practices ............................................... 42 1.3.1. Inspection and maintenance programs ............................................................... 42 1.3.2. Purchasing and right-sizing policies................................................................... 45
3.2. Operations and Management Programs and Practices ............................................... 69 3.2.1. Policies and programs on logistics, route optimization and vehicle tracking .... 69
Chapter Five: Case Studies ........................................................................................................ 87 Case Study #1 Connecticut Clean Air Construction Initiative .............................................. 87 Case Study #2 British Columbia – Diesel School Bus Retrofit Program.............................. 92 Case Study #3 Transport for London – Low Emission Zone ................................................ 95 Case Study #4 Non-Road Diesel Engine Emission Regulation Bylaw ............................... 100 Case Study #5 In-Use Off-Road Diesel Vehicle Regulation ............................................... 103
Conclusion and Recommendations ......................................................................................... 107 Policy and program recommendations ................................................................................ 107 Process guidance ................................................................................................................. 111
Appendix A Diesel Vehicle and Engine Examples ............................................................. A-1 Appendix B Policy and Program Examples ....................................................................... B-1 Appendix C References ........................................................................................................ C-1
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Executive Summary Introduction The impacts of greenhouse gas (GHG), air pollutant and black carbon emissions from on-road heavy duty diesel vehicles and off-road diesel vehicles and engines are widespread. Effects range from human health impacts to environmental impacts to impacts on climate change, which in turn has its own effects on air quality and health. In-use on-road heavy duty diesel vehicles and off-road diesel vehicles and engines are responsible for substantial air pollutant emissions, including black carbon, from the transportation sector, as well as GHG emissions. The Canadian Council of Ministers of the Environment (CCME) is the primary, minister-led intergovernmental forum for collective action on environmental issues of national and international concern. It is composed of the 14 federal, provincial and territorial member governments. The CCME Mobile Sources Working Group (MSWG) was established in 2011 to address air pollutants and GHGs from mobile sources. The group identified emissions from the in-use diesel fleet as a key area of interest. The objective of this project was to develop a document intended to assist Canadian jurisdictions (municipal, provincial/territorial and federal) in addressing emissions from the in-use diesel fleet and/or in reducing the impacts of these emissions on air quality and human health. To achieve this objective, a multi-step approach was taken: • Review existing programs/policies to address in-use diesel emissions • Identify categories of program/policy options to address in-use diesel emissions • Evaluate those option categories based on pre-determined criteria • Develop recommendations regarding options to address in-use diesel emissions and present
case studies exemplifying best practices. Policy and Program Option Overview The table presented below provides an overview of policy and program types and whether they target heavy duty on-road vehicles or off-road vehicles and engines, and criteria air contaminants (CACs) or GHGs.
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Evaluation Criteria The criteria used to evaluate various aspects of the policy and program option categories are presented below.
Evaluation Criteria Definition
Air pollutant emission reduction potential per vehicle - PM2.5
The extent to which the policy/program could potentially reduce (annual) emissions of fine particulate matter (PM2.5) from target vehicles, on a per vehicle basis.
Air pollutant emission reduction potential per vehicle - NOX or VOCs
The extent to which the policy/program could potentially reduce (annual) emissions of ozone precursors (NOX and/or VOCs) from target vehicles, on a per vehicle basis.
GHG emission reduction potential per vehicle – CO2e
The extent to which the policy/program could potentially reduce (annual) emissions of greenhouse gases (CO2e) from target vehicles, on a per vehicle basis.
Policy/Program costs (Total $ and $/year as available)
Implementation costs borne by the public sector, required to bring the policy/program into effect (total costs associated with developing and implementing the option).
Annual operating costs borne by the public sector, to maintain the policy/program.
Vehicle - Capital Costs (Total $/vehicle)
The total costs for the owner/operator to initially comply with the policy/program for target vehicles, on a per vehicle basis.
Vehicle - Operating Costs ($/vehicle/year)
The annual operating costs for the owner/operator to continue to comply with the policy/program for target vehicles, on a per vehicle basis.
Ease of implementation The degree of difficulty the policy/program presents with respect to implementation (i.e. how easy is it for regulators to implement the option, from conception to operation?).
Ease of complying The ease with which owners/operators can comply with the policy/program (i.e. what do the owners/operators need to do to comply?).
Ease of proving compliance The ease with which owners/operators can demonstrate compliance with the policy/program.
Ability to enforce The ability of the regulators to identify non-compliance and compliance evasion (e.g. engine tampering). It also considers ability to enforce effective penalties (e.g. fines for non-compliance).
Cost/benefit Cost benefit assessment is the comparison of total expected costs against total expected benefits, to determine if the benefits outweigh the costs.
On-road Off-road CACs GHGs1.1.1. Emission control system anti-tampering requirements 1.1.2. Vehicle emission standards/fleet rules for in-use fleet 1.1.3. Mandatory retrofit/upgrade/replacement regulations 1.2.1. Programs to encourage use of alternative vehicles and technologies
VOCs: MidUnknown Limited Info Low to High Savings to Low
costModerate to
DifficultDifficult Easy to Difficult East to Moderate Positive Yes Yes
Programs to encourage use of alternative vehicles and technologies
Mid to HighNOx: Mid to High
VOC: Mid to HighLow to High Limited Info Low to High Savings to Low Easy to Moderate N/A N/A N/A Positive Yes Yes
Voluntary retrofit/upgrade/replac-ement programs
Low to HighNOx: Low to Mid
VOC: MidUnknown Limited Info Low to High No cost; Savings Easy to Moderate N/A N/A N/A Positive Yes Yes
Scrappage programs MidNOx: Mid
VOC: MidMid Limited Info No cost No cost; Savings Easy to Moderate N/A N/A N/A Positive Yes No
Purchasing and right-sizing policies Low to High
NOx: Low to High
VOCs: Low to High
Low to MidImplementation:
Very LowOperating: Low
Low to High No cost; Savings Easy to Moderate N/A N/A N/A Neutral Yes No
Fuel standards LowNOx: None
VOCs: LowNone Limited Info No cost Low Difficult N/A N/A N/A Negative Yes Yes
Alternative fuels rules Low to HighNOx: Low to Mid
VOCs: MidMid to High Limited Info No cost to High Savings to Low Difficult
Moderate to Difficult Moderate Easy Positive to Neutral Yes Yes
Idling restrictions Low NOx Low
VOCs: Low Low
Implementation: Very Low
Operating: Very Low to Low
No cost Savings Easy Easy Moderate Moderate Positive Yes No
Geographic operating restrictions Mid to High
Nox: Mid to High
VOCs: No info N/A
Implementation: High
Operating: HighMedium to High Low to Medium
Moderate to Difficult Difficult Easy Easy Neutral Yes Yes
Idle reduction campaigns LowNOx Low
VOCs: Low Low
Implementation: Very low to LowOperating: Very
low to Low
No cost Savings Easy N/A N/A N/A Positive Yes No
Labelling and information policies
N/A / Not evaluated
N/A / Not evaluated
N/A / Not evaluated
Limited Info Low to High Savings Easy to Moderate N/A / Easy N/A / Easy N/A / Easy Positive No No
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Case Studies Five case studies highlighting various policy and program options are presented. The case studies were selected to illustrate a variety of initiatives, including: mandatory retrofit/upgrade/replacement regulations; geographic operating restrictions; and vehicle emission standards/fleet rules for in-use fleet. • Case study #1 – Connecticut Clean Air Construction Initiative (on- and off-road example) • Case study #2 – British Columbia Diesel School Bus Retrofit Program (on-road example) • Case study #3 – Transport for London Low Emission Zone (on-road example) • Case study #4 – Metro Vancouver Non-Road Diesel Engine Emission Regulation Bylaw
(off-road example) • Case study #5 – California In-Use Off-Road Diesel Vehicle Regulation (off-road example) Conclusions and Recommendations Policy and program recommendations are presented and consider what factors would lead a jurisdiction to make one decision over another with respect to the different options. The following recommendations are made based on medium to high potential for emissions reductions as well as no to low vehicle costs (capital and operating). On-road recommendations considering:
Emission reductions Vehicle costs • Emission control system anti-tampering
requirements • Vehicle emission standards/fleet rules for
Further policy and program recommendations are presented with consideration for the type of on-road or off-road vehicle or engine. There are numerous considerations to make when selecting and implementing a policy or program to reduce emissions from the in-use diesel fleet. Therefore, guidance is presented to assist jurisdictions in beginning the process of selecting an appropriate policy or program option. The guidance is discussed under the following elements: know your problem (CAC vs. GHG emissions); know your fleet; know and engage your stakeholders; do your research; consider capacity; and consider budget and time. Each jurisdiction will have its own priorities and challenges. As a result, there is no one standard option that will be applicable to a wide range of jurisdictions.
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Résumé Introduction Les émissions de gaz à effet de serre (GES), de polluants atmosphériques et de carbone noir provenant des véhicules lourds diesel sur route et des véhicules et moteurs diesel hors route ont des impacts étendus. Les effets observés touchent non seulement la santé humaine et l’environnement, mais aussi les changements climatiques, lesquels ont à leur tour des effets sur la qualité de l’air et la santé. Les véhicules lourds diesel sur route et les véhicules et moteurs diesel hors route sont à l’origine d’émissions de GES et d’une part importante des émissions de polluants atmosphériques (incluant le carbone noir) du secteur des transports. Le Conseil canadien des ministres de l’environnement (CCME) est le principal forum intergouvernemental qui, sous la direction des ministres de l'Environnement, mène une action concertée dans des dossiers environnementaux d'intérêt national et international. Le CCME est composé des ministres de l'Environnement des gouvernements fédéral, provinciaux et territoriaux. Formé en 2011, le Groupe de travail sur les sources mobiles (GTSM) du CCME a pour mandat de s’occuper des polluants atmosphériques et des GES de sources mobiles. Le GTSM a désigné les émissions des véhicules et moteurs diesel en service comme étant un important domaine d’intérêt. L’objectif de ce projet était de préparer un guide pour aider les autorités compétentes du Canada (municipalités, provinces/territoires, gouvernement fédéral) à lutter contre les émissions du parc de véhicules en service et/ou à réduire l’impact de ces émissions sur la qualité de l’air et la santé humaine. Pour atteindre cet objectif, nous avons adopté une approche à plusieurs étapes : • examiner les programmes et politiques en vigueur qui ciblent les émissions des véhicules et
moteurs diesel en service; • identifier les catégories de programmes et de politiques qui ciblent les émissions des
véhicules et moteurs diesel en service; • évaluer ces catégories en fonction de critères prédéterminés; • formuler des recommandations concernant les options possibles pour cibler les émissions des
véhicules et moteurs diesel en service et présenter des études de cas qui illustrent de bonnes pratiques.
Vue d’ensemble des options de politiques et de programmes Le tableau de la page suivante donne un aperçu des types de politiques et de programmes existants en indiquant s’ils ciblent les véhicules lourds sur route, les véhicules et moteurs hors route, les principaux contaminants atmosphériques (PCA) ou les GES.
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Sur route Hors route PCA GES
1. Véhicules et moteurs
1.1. Règlements, normes et restrictions
1.1.1. Critères contre l’altération des systèmes antipollution
1.1.2. Normes d’émission pour les véhicules/règles applicables au parc de véhicules en service
1.1.3. Règlements exigeant l’amélioration, la mise aux normes ou le remplacement
1.2. Programmes et pratiques pour les véhicules et l’équipement
1.2.1. Programmes destinés à encourager l’utilisation de technologies et de véhicules alternatifs
1.2.2. Programmes volontaires d’amélioration, de mise aux normes ou de remplacement
1.2.3. Programmes de mise à la ferraille 1.3. Programmes et pratiques d’exploitation et de gestion
1.3.1. Programmes d’inspection et d’entretien
1.3.2. Politiques d’achat et de dimensionnement optimal
2. Carburants
2.1. Règlements, normes et restrictions 2.1.1. Normes applicables aux carburants
2.2. Programmes et pratiques relatifs aux carburants
2.2.1. Règles relatives aux carburants de remplacement
3. Activité générale
3.1. Règlements, normes et restrictions
3.1.1. Restrictions concernant la marche au ralenti des moteurs
3.1.2. Restrictions d’utilisation des véhicules 3.1.3. Restrictions d’utilisation d’ordre géographique
3.2. Programmes et pratiques d’exploitation et de gestion
3.2.1. Politiques et programmes sur la logistique, l’optimisation des itinéraires et le suivi des véhicules
4. Mesures transversales
4.1. Éducation
4.1.1. Programmes de formation des conducteurs 4.1.2. Campagne pour la réduction de la marche au ralenti des moteurs
4.1.3. Politiques d’étiquetage et d’information
4.2. Mesures financières incitatives/dissuasives
4.2.1. Mesures financières incitatives
4.2.2. Mesures financières dissuasives
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Critères d’évaluation Les critères à utiliser pour évaluer les différents aspects des catégories de programmes et de politiques sont présentés dans le tableau ci-dessous.
Critères d’évaluation Définition
Potentiel de réduction des émissions de polluants atmosphériques par véhicule - PM2,5
Mesure dans laquelle la politique ou le programme est susceptible de réduire les émissions (annuelles) de particules fines (PM2,5) des véhicules cibles, par véhicule.
Potentiel de réduction des émissions de polluants atmosphériques par véhicule - NOX ou COV
Mesure dans laquelle la politique ou le programme est susceptible de réduire les émissions (annuelles) de précurseurs d’ozone (NOX, COV) des véhicules cibles, par véhicule.
Potentiel de réduction des émissions de GES par véhicule – équivalent CO2 (e CO2)
Mesure dans laquelle la politique ou le programme est susceptible de réduire les émissions de GES (e CO2) des véhicules cibles, par véhicule.
Coûts associés à la politique ou au programme (coûts totaux et coûts annuels, si disponibles)
Coûts de mise en œuvre que doit assumer le secteur public pour assurer l’entrée en vigueur de la politique ou du programme (coûts totaux associés à l’élaboration et à la mise en œuvre de l’option choisie). Coûts d’exploitation que doit assumer le secteur public pour maintenir la politique ou le programme en place.
Véhicule – dépenses en immobilisations (dépenses totales par véhicule)
Dépenses que doit engager le propriétaire/conducteur du véhicule pour se conformer au départ à la politique ou au programme ciblant son ou ses véhicules (dépenses par véhicule).
Véhicule – coûts d’exploitation (coûts par véhicule par année)
Coûts annuels que doit assumer le propriétaire/conducteur du véhicule pour continuer à se conformer à la politique ou au programme ciblant son ou ses véhicules (coûts par véhicule).
Facilité à mettre en œuvre Degré de difficulté que présente la politique ou le programme sur le plan de la mise en œuvre (c.-à-d. avec quelle facilité les organes de réglementation peuvent-ils mettre en œuvre l’option choisie, de la conception à l’exploitation?).
Facilité à se conformer Facilité avec laquelle les propriétaires ou conducteurs peuvent se conformer à la politique ou au programme (c.-à-d. que doivent faire les propriétaires ou conducteurs pour se conformer?).
Facilité à démontrer la conformité
Facilité avec laquelle les propriétaires ou conducteurs peuvent démontrer leur conformité avec la politique ou le programme.
Capacité de voir à l’application Capacité des organes de réglementation à repérer les cas de non-conformité et de fraudes (p. ex. altération des moteurs). Désigne également la capacité à appliquer des sanctions efficaces (p. ex. amendes pour non-conformité).
Rapport coûts-avantages Au moyen d’une évaluation coûts-avantages, comparaison des coûts totaux prévus aux avantages totaux prévus pour déterminer si les avantages dépassent les coûts.
Avantages connexes Il s’agit de déterminer si la politique ou le programme se traduit par des avantages autres que des réductions d’émissions et les avantages pour la santé qui leur sont associés.
Impacts négatifs Il s’agit de déterminer si la politique ou le programme est réellement ou apparemment à l’origine d’impacts négatifs accidentels.
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Résumé des résultats de l’évaluation sur route
CRITÈRES D’ÉVALUATION QUANTITATIFS
CRITÈRES D’ÉVALUATION QUALITATIFS
AUTRES CRITÈRES, SELON LES DONNÉES DISPONIBLES
Potentiel de réduction des émissions de
polluants atmosphé-riques par véhicule -
PM2,5
Potentiel de réduction des émissions de
polluants atmosphé-riques par
véhicule - NOX ou COV
Potentiel de réduction des émissions de
GES par véhicule -
e CO2
Coûts associés à la politique
ou au programme
(coûts totaux et coûts
annuels, si disponibles)
Véhicule – dépenses
en immobili-sations (coûts
totaux par véhicule)
Véhicule – coûts
d’exploi-tation (coûts par véhicule par année)
Facilité à mettre en
œuvre
Facilité à se
conformer
Facilité à démontrer
la conformité
Capacité de voir à
l’applica-tion
Rapport coûts-
avantages
Avanta-ges
Impacts négatifs
Critères contre l’altération des systèmes antipollution
Élévé NOx : Élévé COV : Moyen S.O. Données
limitées Faibles coûts
Nuls à faibles Difficile Modérée Facile à
difficile Facile à difficile Positif Oui Non
Normes d’émission / règles applicables au parc de véhicules en service
Moyen NOx : Moyen COV : Moyen S.O. Données
limitées Faibles à
élevés Nuls à faibles Difficile Difficile Facile à
modérée Modérée Positif Oui Non
Règlements exigeant l’amélioration, la mise aux normes ou le remplacement
Faible à élevé
NOx : Faible à moyen
COV : Moyen Moyen Données
limitées Faibles à
élevés
Économies ou faibles
coûts
Modérée à difficile Difficile Facile à
difficile Facile à modérée Positif Oui Oui
Programmes destinés à encourager l’utilisation de technologies et de véhicules alternatifs
Moyen à élevé
NOx : Moyen à élevé
COV : Moyen à élevé
Faible à élevé
Données limitées
Faibles à élevés
Économies ou faibles
coûts
Facile à modérée S.O. S.O. S.O. Positif Oui Oui
Programmes volontaires d’amélioration, de mise aux normes ou de remplacement
Faible à élevé
NOx : Faible à moyen
COV : Moyen Moyen Données
limitées Faibles à
élevés
Économies ou faibles
coûts
Facile à modérée S.O. S.O. S.O. Positif Oui Oui
Programmes de mise à la ferraille
Moyen à élevé
NOx: Moyen à élevé
COV : Moyen Moyen Données
limitées Aucun coût Aucun coût; économies
Facile à modérée S.O. S.O. S.O. Positif Oui Non
Programmes d’inspection et d’entretien
Faible à moyen
NOx : Faible COV : Faible
Faible à moyen
Données limitées Faibles Faibles à
moyens Modérée Modérée Modérée Facile Positif Oui Non
Aucun coût Économies Facile Facile Modérée Modérée Positif Oui Non
Règles relatives aux carburants de remplacement
Moyen à élevé
NOx : Moyen à élevé
COV :
Aucunes données
S.O.
Mise en œuvre : Élevés Exploitation :
Élevés
Moyens à élevés
Faibles à moyens
Modérée à difficile Difficile Facile Facile Neutre Oui Oui
Restrictions concernant la marche au ralenti des moteurs
Faible NOx : Faible
COV : Faible
Faible
Mise en œuvre : Très
faibles à faibles
Exploitation : Très faibles à
faibles
Aucun coût Économies Facile S.O. S.O. S.O. Positif Oui Non
Politiques d’étiquetage et d’information
S.O. / Non évalué
S.O. / Non évalué
S.O. / Non évalué
Données limitées
Faibles à élevés Économies Facile à
modérée S.O. / Facile S.O. / Facile
S.O. / Facile Positif Non Non
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Études de cas Cinq études de cas qui mettent en relief différentes options de politiques et de programmes sont présentées. Nous les avons sélectionnées pour illustrer un éventail d’initiatives, notamment les règlements exigeant l’amélioration, la mise aux normes ou le remplacement; les restrictions d’utilisation d’ordre géographique; et les normes d’émission pour les véhicules ou les règles applicables au parc de véhicules en service. • Étude de cas no 1 – Connecticut Clean Air Construction Initiative (exemple sur route et hors
route) • Étude de cas no 2 – British Columbia Diesel School Bus Retrofit Program (exemple sur
route) • Étude de cas no 3 – Transport for London – Low Emission Zone (exemple sur route) • Étude de cas no 4 – Metro Vancouver Non-Road Diesel Engine Emission Regulation Bylaw
(exemple hors route) • Étude de cas no 5 – California In-Use Off-Road Diesel Vehicle Regulation (exemple hors
route)
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Conclusions et recommandations Les recommandations de politiques et de programmes présentées tiennent compte des facteurs qui pousseraient une autorité compétente à prendre une décision plutôt qu’une autre au sujet des différentes options. Les recommandations ci-après sont fondées sur un potentiel moyen à élevé de réduction des émissions ainsi que sur des coûts relatifs au véhicule nuls à faibles (dépenses en immobilisations et coûts d’exploitation). Recommandations concernant les véhicules sur route considérant :
Les réductions d’émissions Les coûts associés à chaque véhicule
• Critères contre l’altération des systèmes antipollution
• Normes d’émission pour les véhicules/ règles applicables au parc de véhicules en service
• Mesures d’amélioration, de mise aux normes ou de remplacement (obligatoires ou volontaires)
• Programmes destinés à encourager l’utilisation de technologies et de véhicules alternatifs
• Programmes de mise à la ferraille
• Règles relatives aux carburants de remplacement
• Restrictions d’utilisation d’ordre géographique
• Programmes de formation des conducteurs
• Critères contre l’altération des systèmes antipollution
• Normes d’émission pour les véhicules /règles applicables au parc de véhicules en service
• Programmes de mise à la ferraille
• Programmes d’inspection et d’entretien
• Règlements sur les carburants
• Restrictions concernant la marche au ralenti des moteurs et campagnes pour la réduction de la marche au ralenti
• Recours à des restrictions d’utilisation
• Politiques et programmes sur la logistique, l’optimisation des itinéraires et le suivi des véhicules
• Programmes de formation des conducteurs
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Recommandations concernant les véhicules hors route considérant :
Les réductions d’émissions Les coûts associés à chaque véhicule
• Normes d’émission pour les véhicules/ règles applicables au parc de véhicules en service
• Mesures d’amélioration, de mise aux normes ou de remplacement (obligatoires ou volontaires)
• Programmes destinés à encourager l’utilisation de technologies et de véhicules alternatifs
• Programmes de mise à la ferraille
• Règles relatives aux carburants de remplacement
• Restrictions d’utilisation d’ordre géographique
• Normes d’émission pour les véhicules/ règles applicables au parc de véhicules en service
• Programmes de mise à la ferraille
• Règlements sur les carburants
• Restrictions concernant la marche au ralenti des moteurs et campagnes pour la réduction de la marche au ralenti
Des recommandations supplémentaires de politiques et de programmes sont présentées, qui tiennent compte du type de véhicule ou de moteur sur route ou hors route. De nombreux facteurs doivent être pris en considération au moment de sélectionner et de mettre en œuvre une politique ou un programme de réduction des émissions de véhicules ou moteurs diesel en service. Le présent document contient donc des orientations pour aider les autorités compétentes à amorcer le processus qui les conduira à faire le bon choix de politique ou de programme. Les orientations se trouvent sous les points suivants du document (en anglais seulement) : « Know your problem » (c.-à-d. émissions de PAC ou de GES); « Know your fleet »; « Know and engage your stakeholders »; « Do your research »; « Consider capacity »; et « Consider budget and time ». Les autorités compétentes ont chacune des priorités et des défis qui leur sont propres, si bien qu’il n’existe pas d’option universelle pouvant s’appliquer à un large éventail d’entre elles.
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Acronyms AC Air conditioning APU Auxiliary power unit AVL Automatic vehicle locator B5 Biodiesel blend, 5% B20 Biodiesel blend, 20% BC British Columbia CAC Criteria air contaminant CAD Canadian dollars CARB California Air Resources Board CBA Cost benefit analysis CCME Canadian Council of Ministers of the Environment CCV Closed-crankcase ventilation CDPF Catalyzed diesel particulate filter CEPA Canadian Environmental Protection Act CFR Code of Federal Regulations CH4 Methane CNG Compressed natural gas CO Carbon monoxide CO2 Carbon dioxide CO2e Carbon dioxide equivalent DERA Diesel Emissions Reduction Act DOC Diesel oxidation catalyst DPF Diesel particulate filter EGR Exhaust gas recirculation GHG Greenhouse gas GPS Global positioning system GVWR Gross vehicle weight rating HC Hydrocarbons HDV Heavy duty vehicle HDDV Heavy duty diesel vehicle HDRD Hydrogenation-derived renewable diesel hp horsepower I/M Inspection and maintenance kg Kilogram L Litre LEZ Low emission zone lbs Pounds LPG Liquefied petroleum gas MSWG Mobile Sources Working Group MY Model year NAAQS National Ambient Air Quality Standards NH3 Ammonia N2O Nitrous oxide NO Nitric oxide
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NO2 Nitrogen dioxide NOx Oxides of nitrogen (that are reactive in forming ozone) O3 Ground level ozone OBD On-board diagnostics PLACE Providing loan assistance for California equipment PM Particulate matter SCAQMD South Coast Air Quality Management District SCR Selective catalytic reduction SO2 Sulphur dioxide SOx Sulphur oxides STO Société de transport de l’Outaouais SWCV Solid waste collection vehicle ULEZ Ultra low emission zone ULSD Ultra-low sulphur diesel US United States USD United States dollars US EPA United States Environmental Protection Agency VKT Vehicle kilometres travelled VOCs Volatile organic compounds
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Glossary of Terms Air toxics Toxic air pollutants cover a broad range of pollutants that are hazardous to human health and/or the environment. Examples of air toxics include benzene (C6H6), formaldehyde, lead and mercury. Air toxics are generally considered separate from criteria air contaminants, which are major air pollutants responsible for smog and acid rain, such as particulate matter (PM), ozone (O3)1, nitrogen oxides (NOx), sulphur oxides (SOx) and volatile organic compounds (VOCs). Alternative fuel Alternative fuels are fuels that are derived from resources other than petroleum. Examples include ethanol, biodiesel, natural gas, propane, and hydrogen. Vehicles and engines can be initially designed for alternative fuels or modified from the original configuration to run on an alternative fuel. Attainment area/Non-attainment area In the United States, air quality regulations are based on the National Ambient Air Quality Standards (NAAQS), which sets thresholds for pollutants considered harmful to public health and the environment, including carbon monoxide (CO), lead, NO2, ozone, particulate matter (PM) and SO2. Geographic areas are deemed to be non-attainment areas if the area is found to exceed the threshold for one or more of the pollutants. The areas that are below the thresholds are considered attainment areas or unclassifiable (Nebraska Department of Environmental Quality, 2008). Biodiesel Biodiesel is a renewable fuel that can be blended with or substituted for diesel. Biodiesel feedstocks include plant oils, waste cooking oils, and other oils, as well as animal fats. Compared to diesel, biodiesel has the potential to reduce greenhouse gas emissions on a life cycle basis, while also reducing some tailpipe emissions, such as particulate matter (Natural Resources Canada, 2013). Black carbon Black carbon is one component (the light absorbing carbon portion) of the pollutant PM2.5, a major source of which is diesel combustion. It is also formed by incomplete combustion of other fossil fuels, biofuels, and biomass (US EPA, 2012). Black carbon, a major component of soot, is recognized to be harmful to human health and a contributor to regional warming. Black carbon absorbs a million times more solar energy than carbon dioxide per unit of mass in the atmosphere. Other impacts include further contribution to warming by decreasing the reflection of solar radiation when black carbon settles on snow and ice, and contributions to local cooling by impacting local precipitation and cloud reflectivity through interactions with cloud processes (Commission for Environmental Cooperation, 2012). The largest sources of black carbon are transportation and open burning (US EPA, 2012) (Environment Canada, 2010).
1 Ozone is not emitted directly to the environment from biogenic or anthropogenic sources; rather it is produced via complex chemical reactions in the atmosphere.
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Criteria air contaminants (CACs) Criteria air contaminants refers to a group of air pollutants that contribute to smog and acid rain, which include: sulphur oxides (SOx), nitrogen oxides (NOx), PM, VOCs, CO, and ammonia (NH3). Ground level ozone (O3) and secondary PM are also sometimes referred to as CACs. Criteria air contaminants are produced from a number of sources, including combustion of fossil fuels (Environment Canada, 2013). Engine retrofit Engine retrofits include technologies that are designed to be added to an engine exhaust system and directly reduce emissions from existing engines. Engine retrofits typically include one of the following emission control devices: diesel oxidation catalysts (DOCs), diesel particulate filters (DPFs), flow-through filters, NOx catalysts, selective catalytic reduction, and exhaust gas recirculation. Engine retrofits can also involve modifications to the crankcase to control emissions, such as closed-crankcase ventilation (CCV) (Manufacturers of Emission Controls Association, 2014). Engine upgrade For the purposes of this document, engine upgrade can refer to repowering, rebuilding or replacing an existing engine. Repowering typically involves replacing an existing engine with a new engine. Rebuilding is often part of standard maintenance practices and involves the engine being rebuilt with updated, cleaner parts and improved exhaust emission controls. Replacement involves retiring a vehicle or equipment before the end of its useful life, in order to replace it with newer equipment that meets more stringent emission standards (Manufacturers of Emission Controls Association, 2014). Greenhouse gases (GHGs) Greenhouse gases are gases that absorb infrared radiation and trap heat in the atmosphere. Greenhouse gases include CO2, CH4, N2O, and fluorinated gases (hydrofluorocarbons, perfluorocarbons, and sulphur hexafluoride). Ground level ozone (O3) Ground level ozone is a secondary pollutant formed by the chemical reaction between NOx and VOCs in sunlight and stagnant air. Ground level ozone is harmful to human health, particularly for vulnerable populations and people who have existing lung conditions, such as asthma. It can also negatively impact the environment, decreasing the productivity of some crops, and harming sensitive vegetation (Environment Canada, 2013) (US EPA, 2014). Hydrocarbons (HC) Hydrocarbons (HC) are organic compounds that consist of only hydrogen (H) and carbon (C). Examples of hydrocarbons include methane (CH4), propane (C3H8) and benzene (C6H6) and are the main components of fuels such as gasoline and diesel. Emissions of hydrocarbons from tailpipe exhaust result when air to fuel ratios used in combustion are less than stoichiometric (HC emissions due to unburned fuel escaping combustion chamber and/or resulting from partial products of combustion). Some HC may be emitted even when air to fuel ratios are slightly higher than stoichiometric (HC emissions result due to poor mixing conditions in the combustion chamber). Hydrocarbons are also released in evaporative emissions from vehicles/fuels.
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Off-road diesel vehicle and engine For the purposes of this document, this is mobile equipment that does not typically drive on road and is powered by a diesel engine. Examples include construction, mining, farming, and forestry vehicles, commercial generator sets, all-terrain vehicles, lawn and garden equipment, etc. See Appendix A for further examples of off-road vehicle and engine types. Marine, rail and aviation engines are not included in the scope of this document. On-road heavy duty diesel vehicle For the purposes of this document, this is a vehicle licensed for use on roads to transport people and/or goods, with a gross vehicle weight rating (GVWR) greater than 8,500 lbs (3,856 kg) (class 2B and above). Examples include full-size pickup trucks, long-haul tractors, school and transit buses, garbage and dump trucks, etc. See Appendix A for a listing of on-road heavy duty diesel vehicle types. Oxidation catalyst An oxidation catalyst is part of a vehicle exhaust system that enables the conversion through oxidation of harmful emissions, such as CO, the soluble organic fraction of PM and uncombusted hydrocarbons, into other, less harmful products, such as water and CO2. Renewable fuel Renewable fuels are fuels that are derived from renewable sources, such as crops, animal waste and municipal solid waste. Compared to fossil fuels, renewable fuels produce fewer life cycle GHG emissions. Specific renewable fuels can be blended into petroleum based fuels, including diesel. Smog Smog is a mixture of gases and particles, namely O3 and PM. Smog appears as a haze and is harmful to human health and the environment. Smog occurs throughout the year, in the summer due to warmer temperatures and sunlight, and in the winter due to PM contributions building up in stagnant air (Environment Canada, 2014).
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Vehicle classifications For regulatory purposes, vehicles are classified into separate categories based on GVWR. For heavy duty diesel vehicles, the following are the standard classifications:
Light heavy duty diesel
Class 2B 3,856–4,536 kg
(8501-10,000 lbs GVWR)
Class 3 4,536–6,350 kg
(10,001-14,000 lbs GVWR)
Class 4 6,531–7,257 kg
(14,001-16,000 lbs GVWR)
Class 5 7,258–8,845 kg
(16,001-19,500 lbs GVWR)
Medium heavy duty diesel
Class 6 8,846–11,793 kg
(19,501-26,000 lbs GVWR)
Class 7 11,794–14,969 kg
(26,001-33,000 lbs GVWR)
Heavy heavy duty diesel
Class 8 >14,969 kg
(greater than 33,000 lbs GVWR)
Class 8B >27,216 kg
(greater than 60,000 lbs GVWR)
Vehicle retrofit Vehicle retrofits involve retrofit technologies that are designed to improve fuel efficiency, thereby indirectly reducing GHG emissions. Vehicle retrofits typically refer to aftermarket equipment that help to decrease fuel consumption, such as aerodynamic equipment (e.g. side skirts, cab roof fairings, etc.), automatic tire inflation systems, speed limiters, auxiliary power units, etc. Volatile Organic Compounds (VOCs) Volatile organic compounds (VOCs) are organic compounds that have a high vapour pressure and contain one or more carbon (C) atoms. These compounds evaporate readily into the atmosphere and are primary precursors in the formation of O3. Environment Canada’s official definition for VOC means “any VOC that participates in atmospheric photochemical reactions.” VOCs do not include photochemically non-reactive compounds such as methane (CH4)2 (Environment Canada, 2013).
2 Environment Canada’s official definition and exclusions for VOCs can be found at: http://www.ec.gc.ca/cov-voc/default.asp?lang=En&n=105A29F5-1.
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Introduction The impacts of air pollutant, greenhouse gas (GHG) and black carbon emissions from on-road heavy duty diesel vehicles and off-road diesel vehicles and engines are widespread. Effects range from human health impacts3 (e.g. incidence of chronic mortality risk and acute respiratory system days) to environmental impacts (e.g. decreased plant productivity and deterioration of visibility) to impacts on climate change, which in turn has its own effects on air quality and health. Air pollutant and greenhouse gas emissions Greenhouse gases trap heat in the atmosphere and are affecting the climate. Greenhouse gases emitted from human activity are considered the most significant driver of climate change observed since the mid-20th century (Intergovernmental Panel on Climate Change, 2013). Many nations have implemented regulations, programs and policies to limit these emissions from various sectors of the economy. Air pollutants impact air quality, which affects the health of Canadians. Elevated concentrations of key contaminants in ambient air cause adverse health outcomes (Environment Canada, 2014). Contaminants of particular concern include ground level ozone (O3) and particulate matter (PM). While a protective gas in the upper atmosphere, ozone can have detrimental human health effects when in the lower atmosphere. Exposure to O3 has been found to cause both acute and chronic damage to the human respiratory system including increased airway reactivity, airway inflammation, and reduction in lung function and increased respiratory symptoms (Health Canada, 2008). Additionally, numerous epidemiological studies have concluded that ground level ozone adversely affects human health (Health Canada, 2013) (US EPA, 2014). Results of studying ground level ozone changes in 95 American cities also suggest a statistically significant association between short term changes in ozone and mortality (Bell, McDermott, & Zeger, 2004). Health Canada concluded that there is likely a causal relationship between acute exposure to ambient ozone and mortality, including cardiorespiratory mortality (Health Canada, 2013). Ground level ozone is not emitted directly into the air, but is generated via complex photochemical reactions involving nitrogen oxides (NOx) and volatile organic compounds (VOCs). Particulate matter concentration in ambient air also causes adverse health outcomes. Particulate matter is typically broken down into three categories: PM10, PM2.5 and PM0.1, and is classified as either primary or secondary. Approximately half is emitted directly to the atmosphere (primary PM); the other half is formed via chemical and physical reactions in the atmosphere in the presence of other gases (sulphur dioxide, nitrogen oxides, volatile organic compounds and ammonia) (secondary PM). Extensive research has linked PM to negative health effects, such as aggravated cardiac and respiratory diseases, various forms of heart disease, decreased lung
3 In 2012, the World Health Organization classified exhaust from diesel engines as carcinogenic to humans. (International Agency for Research on Cancer (IARC), World Health Organization, Press Release No. 213, IARC: Diesel Engine Exhaust Carcinogenic, June 12, 2012 http://www.iarc.fr/en/media-centre/pr/2012/pdfs/pr213_E.pdf)
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function, increased hospitalizations, and increased respiratory and cardiovascular mortality (Health Canada, 2008) (US EPA, 2014). Populations that are particularly vulnerable to adverse air quality include seniors, young children, asthmatics, those with existing chronic diseases, people with a lower socio-economic status, and those living in densely populated urban neighbourhoods (Health Canada, 2008). Nitrogen oxides, VOCs and PM are all produced from the combustion of diesel fuel. Reducing diesel emissions has been associated with health and economic benefits. For example, the United States Environmental Protection Agency (US EPA) estimated that NOx and PM emission reductions associated with initiatives under the Diesel Emissions Reduction Act (DERA) have resulted in 1,400 fewer premature deaths and fewer hospital visits, and that the economic benefits associated with this estimate will total approximately $3.4 billion to $8.2 billion (US EPA, 2012). Black carbon is one component (the light absorbing carbon portion) of the pollutant PM2.5, a major source of which is diesel combustion. It is also formed by incomplete combustion of other fossil fuels, biofuels, and biomass (US EPA, 2012). Black Carbon has a strong warming potential, influencing the climate in three ways: directly absorbing light, reducing the albedo of snow and ice, and interacting with clouds4. Targeted strategies to reduce black carbon emissions are expected to result in benefits to the climate, public health and the environment (US EPA, 2012). This document does not focus on programs or policies to reduce black carbon specifically, however reducing PM2.5 emissions from diesel engines has been identified by US EPA as one of the most promising mitigation options to address black carbon (US EPA, 2012). Therefore, policies and programs that are expected to reduce PM2.5 emissions are also assumed to result in black carbon emission reductions (and improve public health). The Mobile Sources Working Group The Canadian Council of Ministers of the Environment (CCME) is the primary, minister-led intergovernmental forum for collective action on environmental issues of national and international concern. It is composed of the 14 federal, provincial and territorial member governments. The CCME Mobile Sources Working Group (MSWG) was established in 2011 to address air pollutants and GHGs from mobile sources. The group shares information, identifies joint areas of interest, and works collaboratively on initiatives to address mobile source emissions. A key area of interest that has been identified by the group is addressing emissions from the in-use diesel fleet. Although the federal government has introduced increasingly more stringent air pollutant emission standards for newly manufactured and imported on-road and off-road diesel vehicles
4 While it is relatively well understood that direct absorption of light and reducing the albedo of snow and ice lead to climate warming, the effect of black carbon interaction with clouds is less well understood and may result in either a warming or cooling effect. (US EPA, 2012 Report to Congress on Black Carbon http://www.epa.gov/blackcarbon/2012report/fullreport.pdf)
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and engines (e.g. 2007 model year (MY) and newer on-road heavy-duty diesel vehicles are subject to very tight emission regulations, and new off-road engine emission regulations are aligned with US EPA Tier 4 standards), there are many older diesel engines that remain in use in both on-road and off-road applications. These in-use vehicles and engines are responsible for substantial air pollutant emissions, including black carbon from the transportation sector, as well as GHG emissions. The durability of diesel engines contributes to the slow turnover rate of older vehicles and equipment. Purpose of the document The MSWG has targeted the Canadian in-use diesel fleet with the goal of informing the development of strategies to address emissions from this sector. Specifically, the objective of this project was to develop a document intended to assist Canadian jurisdictions (municipal, provincial/territorial and federal) to address emissions from in-use on-road heavy duty diesel vehicles and off-road diesel vehicles and engines and/or to reduce the impacts of these emissions on air quality and human health. The following multi-step approach was taken to achieve this objective: 1) review existing programs/policies to address in-use diesel emissions; 2) identify categories of program/policy options to address in-use diesel emissions; 3) evaluate those option categories based on pre-determined criteria; 4) develop recommendations regarding options to address in-use diesel emissions and present case studies exemplifying best practices. More specifically, the scope of work included research into Canadian and relevant international policies and programs to mitigate emissions from in-use on-road heavy duty diesel vehicles and off-road diesel vehicles and engines. The literature review sought to compile a wide-ranging list of relevant policies and programs, considering on-road and off-road diesel fleets separately. Following this initial research, the identified policies and programs were used to characterize 17 distinct policy and program options for evaluation. Each of the 17 options was expanded into a descriptive profile, including a brief description and additional information as it was available on target pollutants, vehicles, jurisdiction, costs, examples, benefits and challenges. The next step was to define a set of evaluation criteria, which included both quantitative and qualitative criteria, covering the potential to reduce emissions, costs, compliance, enforcement, cost/benefit, co-benefits, and unintended negative impacts. Each policy or program option was evaluated against the criteria, and the results of the evaluation informed the recommendations presented in this document. This resulting report, Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines, is intended to assist readers in making informed decisions. It is not meant to guide readers to a particular policy or program option, but rather it is meant to provide readers with sufficient information to allow them to move forward with their own directed and detailed studies on policy or programs options that may be a good fit for their jurisdiction. Organization of the document The remainder of the document is presented in the following chapters:
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• Chapter One: Policy and Program Overview – presents an overview of the 17 policy and
program option categories to mitigate air pollutant and GHG emissions from the in-use diesel fleet, indicating whether they are applicable to on-road or off-road vehicles and engines and if they target criteria air contaminants (CACs), GHGs, or both
• Chapter Two: Evaluation Criteria – defines the quantitative and qualitative criteria used to evaluate the policy and program option categories, including definition, method of application, and evaluation scale
• Chapter Three: Summary of Evaluation Results – presents the on-road and off-road evaluation summary tables
• Chapter Four: Option Profiles and Evaluation Notes – presents detailed profiles of the 17 policy and program options, along with evaluation notes, including rationale, results and references
• Chapter Five: Case Studies – describes five case studies exemplifying best practices (two on-road policy/programs, two off-road policy/programs, and one both on- and off-road policy/program)
• Conclusion and Recommendations.
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Chapter One: Policy and Program Option Overview This Chapter provides an overview of policy and program options to mitigate air pollutant and greenhouse gas (GHG) emissions from the in-use diesel fleet. The options presented are relevant to: • On-road heavy-duty diesel vehicles with a gross vehicle weight rating greater than 3,856 kg
(8,500 pounds). Examples include full-size pickup trucks, vans, long-haul tractors, school buses, transit and intercity buses, and freight, delivery, service, cement, garbage, and dump trucks.
• Off-road diesel vehicles and engines that do not typically drive on road. Examples include equipment used for construction, mining, farming and forestry, including tractors, excavators, log skidders and heavy haulers. The off-road category does not include marine, rail or aviation engines for the purpose of this document.
Policy and program options were selected for their relevance within the Canadian context. Detailed profiles of each option are presented in Chapter Four. The document is accompanied by a list of current policies and programs in Canada, United States, and several European countries. The list (found in Appendix B) is presented to support and inform the document, and should not be considered as an exhaustive list of initiatives. For the purpose of this document, Exhibit 1 presents the categorization of policy and program options.
Exhibit 1 Categorization of policy and program options
This table provides an overview of policy and program types and whether they target on-road vehicles or off-road vehicles and engines, and CACs or GHGs. Policy and program options that target air pollutants/CACs are typically associated with the objective of improving air quality
On-road Off-road CACs GHGs1.1.1. Emission control system anti-tampering requirements 1.1.2. Vehicle emission standards/fleet rules for in-use fleet 1.1.3. Mandatory retrofit/upgrade/replacement regulations 1.2.1. Programs to encourage use of alternative vehicles and technologies
1.3.2. Purchasing and right-sizing policies 2.1. Regulations, Standards and Restrictions
2.1.1. Fuel standards
2.2. Fuel-related Programs and Practices
2.2.1. Alternative fuels rules
3.1.1. Idling restrictions
3.1.2. Vehicle use operating restrictions
3.1.3. Geographic operating restrictions
3.2. Operations and Management Programs and Practices
3.2.1. Policies and programs on logistics, route optimization and vehicle tracking
4.1.1. Driver training programs
4.1.2. Idle reduction campaigns
4.1.3. Labeling and information policies
4.2.1. Financial incentives
4.2.2. Financial disincentives
4.2. Financial Incentives/Disincentives
4. Cross-cutting
1.1. Regulations, Standards and Restrictions
1.2. Vehicle and Equipment Programs and Practices
4.1. Education
1.3. Operations and Management Programs and Practices
1. Vehicles and Engines
3.1. Regulations, Standards and Restrictions3. General
Activity
2. Fuels
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and human health by reducing exposure to CACs and toxic substances. Benefits are usually realized at the local or regional scale. Options that target GHG emissions are typically associated with reduction targets or goals of federal, provincial/territorial or municipal governments. Benefits are not necessarily local or regional in nature as the benefits of reducing GHGs are global in nature. Additional key benefits for the different types of policy and program options are included within the individual profiles and evaluation found in Chapter Four.
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Chapter Two: Evaluation Criteria This Chapter presents the criteria used to evaluate various aspects of the policy and program option categories, including emission reduction potential, costs, and ease of implementation, compliance and enforcement. Quantitative and qualitative evaluation criteria were developed. Exhibit 2 outlines the definition of each evaluation criterion, the method that was used to evaluate the program and policy option against each criterion, and the evaluation scale.
Exhibit 2 Evaluation Criteria
Evaluation Criteria Definition Method to Evaluate Options Against Criteria Evaluation Scale
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - fine particulate matter (PM2.5)
The extent to which the policy/program could potentially reduce (annual) emissions of fine particulate matter (PM2.5) from target vehicles, on a per vehicle basis.
Options were evaluated based on potential to reduce (annual) emissions of PM2.5. In cases where quantitative information regarding reduction potential (on a per vehicle basis) was available, the options were evaluated based on a scale rating from high to low. Options that did not have quantitative data available were evaluated based on expert opinion, if possible, and ranked for high, mid or low potential to reduce emissions of PM2.5.
High = reductions greater than 85% Mid = reductions in the range of 25-85% Low = reductions less than 25%
Air pollutant emission reduction potential per vehicle - ozone pre-cursors (NOx or VOCs)
The extent to which the policy/program could potentially reduce (annual) emissions of ozone precursors (NOx and/or VOCs) from target vehicles, on a per vehicle basis.
Options were evaluated based on potential to reduce (annual) NOx and/or VOCs. In cases where quantitative information regarding reduction potential (on a per vehicle basis) was available, the options were evaluated based on a scale rating from high to low. Options that did not have quantitative data available were evaluated based on expert opinion, if possible, and ranked for high, mid or low potential to reduce emissions of NOx and/or VOCs.
NOx High = reductions greater than 85% NOx Mid = reductions in the range of 25-85% NOx Low = reductions less than 25% VOCs High = reductions greater than 85% VOCs Mid = reductions in the range of 25-85% VOCs Low = reductions less than 25%
The extent to which the policy/program could potentially reduce (annual) emissions of greenhouse gases (CO2e) from target vehicles, on a per vehicle basis.
Options were evaluated based on potential to reduce (annual) emissions of GHGs (CO2e). In cases where quantitative information regarding reduction potential (on a per vehicle basis) was available, the options were evaluated based on a scale rating from high to low. Options that did not have quantitative data available were evaluated based on expert opinion, if possible, and ranked for high, mid or low potential to reduce emissions of GHGs.
High = reductions of CO2e greater than 20% Mid = reductions of CO2e in the range of 5-20% Low = reductions of CO2e less than 5%
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Evaluation Criteria Definition Method to Evaluate Options Against Criteria Evaluation Scale
Policy/Program costs (Total $ and $/year as available)
Implementation costs borne by the public sector, required to bring the policy/program into effect (total costs associated with developing and implementing the option). Annual operating costs borne by the public sector, to maintain the policy/program.
For implementation costs, options were evaluated based on total capital costs borne by the public sector. In cases where quantitative information regarding capital costs was available, the options were evaluated based on a scale ranging from high costs to no costs. For operating costs, options were evaluated based on annual operating costs borne by the public sector. In cases where quantitative information regarding operating costs was available, the options were evaluated based on a scale ranging from high costs to no costs. Options that did not have disaggregated quantitative data available were not evaluated. Instead, sample cost information (e.g. from umbrella programs, combined implementation/operating costs, etc.) were provided for illustrative purposes. These were noted as ‘Limited Info’ in the evaluation.
Implementation (Total $): High >$1 million Medium $500,000 - $1 million Low $100,000 - $500,000 Very Low <$100,000 No Cost ($0) Operating ($/year): High >$500,000 Medium $100,000 - $500,000 Low $50,000 - $100,000 Very Low <$50,000 No Cost ($0) Limited Information
Vehicle - Capital Costs (Total $/vehicle)
The total costs for the owner/operator to initially comply with the policy/program for target vehicles, on a per vehicle basis.
Options were evaluated based on capital costs borne by the owners/operators (private or public sector), on a per vehicle basis. In cases where quantitative information regarding capital costs was available, the options were evaluated based on a scale ranging from high costs to no costs or savings.
High >$50,000 Medium $15,000 - $50,000 Low <$15,000 No Cost ($0) Savings
Vehicle - Operating Costs ($/vehicle/year)
The annual operating costs for the owner/operator to continue to comply with the policy/program for target vehicles, on a per vehicle basis.
Options were evaluated based on annual operating costs borne by the owners/operators (private or public sector), on a per vehicle basis. In cases where quantitative information regarding operating costs was available, the options were evaluated based on a scale ranging from high costs to no costs or savings.
High >$20,000 Medium $5,000 - $20,000 Low <$5,000 No Cost ($0) Savings
QUALITATIVE EVALUATION CRITERIA Ease of implementation
The degree of difficulty the policy/program presents with respect to implementation (i.e. how easy is it for regulators to implement the option, from conception to operation?).
Options were evaluated based on how easy the policy/program is to implement. How easy the option is to implement is defined as the number of and/or complexity of regulatory hurdles the policy/program must go through. This has been defined as both quantity of regulatory hurdles as well as how many different parties or sectors are involved. For instance, a regulation that requires industry buy-in, public consultation, scientific environmental and health
Difficult: Many regulatory hurdles, involving multiple sectors, such as public, commercial, industrial and institutional sectors. Moderate: Some regulatory hurdles, involving more than the public sector. Easy: Few regulatory hurdles, contained within the public sector.
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Evaluation Criteria Definition Method to Evaluate Options Against Criteria Evaluation Scale
review, etc. would be considered complex, compared to an education campaign that could be developed by one department within a single government organization, which would be considered as easy.
Ease of complying The ease with which owners/operators can comply with the policy/program (i.e. what do the owners/operators need to do to comply?).
Options were evaluated based on how easy it is for owners/operators to comply with the policy/program. The evaluation was based on what is required of the owner/operator to operate their vehicle/engine in compliance with the policy/program.
Difficult: To comply, the owner/operator must invest resources (e.g. time, money), prior to operating the vehicle or engine, to meet the mandatory criteria of the policy/program (e.g. proof of retrofit, obtaining a certificate for operation or testing papers for insurance renewal, etc.). Moderate: The operator can comply with the policy/program during the operation of the vehicle or engine (e.g. inspection and maintenance program, geographical restriction, anti-idling, etc.). Easy: The owner/operator does not need to invest resources prior to operating the vehicle or engine, nor is the operator subjected to compliance requirements during operation of the vehicle/engine (e.g. no requirements for monitoring, obtaining and displaying certificates, etc., such as use of alternative fuels, anti-tampering, etc.). N/A: Option does not require compliance (such as voluntary programs, education campaigns, etc.).
Ease of proving compliance
The ease with which owners/operators can demonstrate compliance with the policy/program.
Options were evaluated based on how easy it is for owners/operators to demonstrate to the regulators that they are in compliance with the policy/program. The evaluation was based on what is required of the owner/operator to operate their vehicle or engine in compliance with the policy/program.
Difficult: It is considered difficult to prove compliance when no "proof" of compliance is required (e.g. no requirements for monitoring, no spot checks, no need to obtain/display certificates, etc., such as use of alternative fuels, anti-tampering, etc.).5 Moderate: The operator can demonstrate compliance during the operation of the vehicle or engine (e.g. through an inspection and maintenance program, operating within geographical restriction limits, not idling in an anti-idling zone, etc.). Easy: The owner/operator can demonstrate compliance before the operation of their vehicle or engine (e.g. obtain certificates, obtain testing papers required for insurance renewal, present proof of retrofit, etc.). N/A: Option does not require compliance (such as voluntary programs, education campaigns, etc.).
5 Example for clarification: Consider a program that incentivizes the purchase of flex fuel vehicles with the requirement that blended fuel must be used. Flex fuel vehicles can operate using blended fuels or conventional fuel. It would be difficult for an operator to prove compliance, that is prove they are using blended fuel
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Evaluation Criteria Definition Method to Evaluate Options Against Criteria Evaluation Scale
Ability to enforce The ability of the regulators to identify non-compliance and compliance evasion (e.g. engine tampering). It also considers ability to enforce effective penalties (e.g. fines for non-compliance).
Options were evaluated based on how easy it is for regulators to identify non-compliance with a policy/program, considering compliance systems, mechanisms, etc. The ease with which effective penalties can be enforced was also considered.
Difficult: It is considered difficult to enforce a policy/program if the owners/operators are not required to report on or demonstrate compliance prior to operating the vehicle or engine (e.g. no certificates required for display, no testing required to obtain insurance, etc.). The ability to enforce a policy/program is constrained by a lack of mechanisms to identify non-compliance. Moderate: The operation of the policy/program includes some form of enforcement mechanisms (e.g. spot-checks, etc.). Easy: The owners/operators can demonstrate compliance before or during the operation of their vehicle or engine (e.g. displaying certificates, etc.). The ability to enforce a policy/program is facilitated by existing mechanisms to identify non-compliance. N/A: Option does not require compliance (such as voluntary programs, education campaigns, etc.).
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Cost benefit
assessment is the comparison of total expected costs against total expected benefits, to determine if the benefits outweigh the costs.
Options were evaluated based on cost-benefit results from existing studies (when available) or based on an expert cost/benefit assessment. Using this method means that the cost-benefit results of each policy/program may include different types of costs and benefits (i.e. a cost benefit analysis (CBA) for one option may have included external benefits, such as air quality improvements, whereas a CBA for another option may not have). Options that did not have appropriate cost-benefit data available were assessed for cost/benefit by a technical expert based on years of experience in the field.
Yes: Policy/program results in co-benefits beyond emission reductions and health benefits. No: Policy/program does not result in co-benefits beyond emission reductions and health benefits.
100% of the time, unless for instance, the regulator carried out spot checks, required submission of fuel purchase and kilometres travelled data, etc. as part of program enforcement.
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Evaluation Criteria Definition Method to Evaluate Options Against Criteria Evaluation Scale
Negative impacts Does the policy/program cause unintended real or perceived negative impacts?
Options were evaluated based on whether they result in unintended negative impacts. These could be real or perceived negative impacts, such as:
• emissions control vs. increased fuel consumption • increased vehicle kilometres travelled (VKT) • unsafe driving practices • displaced emissions (e.g. removed from tail pipe,
but occur elsewhere in the life cycle of the fuel)
Yes: Policy/program results in unintended negative impacts (real or perceived). No: Policy/program does not result in unintended negative impacts (real or perceived).
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Chapter Three: Summary of Evaluation Results This Chapter presents the outcome of applying the evaluation criteria presented in Chapter Two to each program and policy option outlined in Chapter One and described in further detail in Chapter Four. The overall results of the evaluation are presented in the tables below, Exhibit 3 for on-road heavy-duty diesel vehicles and Exhibit 4 for off-road diesel vehicles and engines. Detailed notes and references for the evaluation are presented in Chapter Four. Remarks on the evaluation It is clear that the overall impact of each policy and program would depend on the uptake, whether uptake is limited by design, behaviour, technology, or by some other means. For example, the benefits of a mandatory retrofit program are constrained by the fact that many vehicles and engines cannot be retrofit; whereas, the benefits of a voluntary retrofit program may be constrained by access to financial incentives. This is why emission reductions are considered on a per vehicle basis, not on the policy or program as a whole. Unless otherwise noted, all emission reductions are based on vehicle emissions (“tail pipe” emissions). In some situations, it was more informative to use life cycle emission reductions, such as GHG emission reductions for biofuels. These situations are clearly noted in the detailed evaluation notes in Chapter Four. As discussed in the introduction, policies and programs that aim to reduce diesel tail pipe emissions have an associated health benefit. The reduction of diesel emissions results in reduced human exposure to air pollutants leading to health benefits. Because of this, health benefits due to reduction of diesel emissions are not listed as a co-benefit, as these are considered implicit in the evaluation. The criterion, co-benefits, refers to benefits unrelated to reductions in CAC and GHG emissions and human health, such as safer driving, reduced congestion, etc.
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
VOCs: MidUnknown Limited Info Low to High Savings to Low
costModerate to
DifficultDifficult Easy to Difficult East to Moderate Positive Yes Yes
Programs to encourage use of alternative vehicles and technologies
Mid to HighNOx: Mid to High
VOC: Mid to HighLow to High Limited Info Low to High Savings to Low Easy to Moderate N/A N/A N/A Positive Yes Yes
Voluntary retrofit/upgrade/replac-ement programs
Low to HighNOx: Low to Mid
VOC: MidUnknown Limited Info Low to High No cost; Savings Easy to Moderate N/A N/A N/A Positive Yes Yes
Scrappage programs MidNOx: Mid
VOC: MidMid Limited Info No cost No cost; Savings Easy to Moderate N/A N/A N/A Positive Yes No
Purchasing and right-sizing policies Low to High
NOx: Low to High
VOCs: Low to High
Low to MidImplementation:
Very LowOperating: Low
Low to High No cost; Savings Easy to Moderate N/A N/A N/A Neutral Yes No
Fuel standards LowNOx: None
VOCs: LowNone Limited Info No cost Low Difficult N/A N/A N/A Negative Yes Yes
Alternative fuels rules Low to HighNOx: Low to Mid
VOCs: MidMid to High Limited Info No cost to High Savings to Low Difficult
Moderate to Difficult Moderate Easy Positive to Neutral Yes Yes
Idling restrictions Low NOx Low
VOCs: Low Low
Implementation: Very Low
Operating: Very Low to Low
No cost Savings Easy Easy Moderate Moderate Positive Yes No
Geographic operating restrictions Mid to High
Nox: Mid to High
VOCs: No info N/A
Implementation: High
Operating: HighMedium to High Low to Medium
Moderate to Difficult Difficult Easy Easy Neutral Yes Yes
Idle reduction campaigns LowNOx Low
VOCs: Low Low
Implementation: Very low to LowOperating: Very
low to Low
No cost Savings Easy N/A N/A N/A Positive Yes No
Labelling and information policies
N/A / Not evaluated
N/A / Not evaluated
N/A / Not evaluated
Limited Info Low to High Savings Easy to Moderate N/A / Easy N/A / Easy N/A / Easy Positive No No
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Chapter Four: Option Profiles and Evaluation Notes This Chapter provides an overview of policy and program options to mitigate air pollutant and GHG emissions from the in-use diesel fleet. The profiles of each option have been developed based on public and unpublished documentation, as well as web-based resources. Except where otherwise noted or referenced, the main sources of information for the 17 policy and program option profiles include: • Bronson Consulting, Clearing the Air: 2012 Canadian On-road Vehicle Emissions-Reduction
Program Inventory, May 2013 [Confidential Report] • Cheminfo Services Inc., Jurisdictional Review of Off-Road Source Emission Reduction
Strategies and Best Practices, prepared for Canadian Council of Ministers of the Environment, Mobile Sources Working Group, April 17, 2014 [Confidential Report]
• Environment Canada and the United States Environmental Protection Agency, Clean Energy Dialogue: Information-Sharing Workshop on Green Financing Mechanisms to Reduce Emissions from Heavy-Duty Vehicles, Workshop Overview, January 2013 [Confidential Report]
• ICF International, The Gateway Cities Air Quality Action Plan: Early Action Plan, prepared for Gateway Cities Council of Governments and Los Angeles Metropolitan Transportation Authority, May 2012
• ICF International, Review of Select Government Sustainable Transportation Programs, Policies and Initiatives, prepared for Environment Canada and Transport Canada, 2009
• ICF International and Todd Litman (Victoria Transport Policy Institute), Transportation Sector Research, prepared for Federation of Canadian Municipalities, 2008
• Lawson, John, Observations on the Economic Case for Heavy-Duty Vehicle Retrofits, prepared under contract for Environment Canada, March 2014 [Confidential Report]
• Partners for Climate Protection, Federation of Canadian Municipalities, Enviro-fleets: Reducing emissions form municipal heavy-duty vehicles, A guide to helpful resources, June 2010
• Partners for Climate Protection, Federation of Canadian Municipalities, Enviro-fleets: Reducing municipal heavy-duty vehicle emissions, A guide to best practices, November 2010
• SNC Lavalin, Heavy Duty Diesel Vehicle Policy Options Evaluation Study, prepared for Greater Vancouver Regional District (Metro Vancouver), December 31, 2013
• The International Council on Clean Transportation, Survey of Best Practices in Emission Control of In-use Heavy-duty Diesel Vehicles, August 2013
Each profile is followed directly by the evaluation notes, including additional sources of information.
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1. Vehicles and Engines
1.1. Regulations, Standards and Restrictions
1.1.1. Emission control system anti-tampering requirements PROFILE Applicable to: • On-road heavy duty diesel vehicles6
Target Vehicles: • All diesel vehicles
Objective: • To ensure that existing emission control devices and systems in vehicles are not altered, since
removal of or tampering with (i.e. modification of) emission control systems and devices results in an increase in air pollutant emissions from in-use diesel vehicles.
Brief Description: • Regulations to prohibit the removal or modification of an emission control system or device
installed in a motor vehicle to reduce or eliminate air pollutant emissions. • If device/system replacement is necessary, this type of requirement stipulates that the
replacement must be consistent with that used as a replacement unit by the vehicle manufacturer.
• Examples of systems and devices include catalytic converters, diesel particulate filters (DPF), injection timing adjustments, turbocharger waste gate adjustments, and other engine adjustments that would affect emissions, and on‐board diagnostic systems designed to identify motor or emissions control system problems.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO
Authority Jurisdiction: • Provincial/Territorial – Develop regulations; enforcement Method of Compliance and Enforcement: • Certificate of compliance or waiver • Registration, roadside checks (e.g. snap-idle, on-board diagnostics (OBD)), random spot-
checks at inspection stations, regular inspections • Warnings, tickets, summons/orders, licence/vehicle removal – to date, limited resources and
capacity to enforce regulations (in Canada)7
6 This does not necessarily mean that anti-tampering initiatives could not be applicable to off-road vehicles and engines; however, off-road vehicles and engines are not listed, as there were none identified during the course of this study. 7 In the United States, there is enforcement at both the federal and state level, imposing substantial fines on the companies that provide the tampering services and the operators of the trucks. However, US service suppliers continue to offer kits for sale on the internet.
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Cost Bearer(s): • Single funder or shared • Public or private sector – Provincial/territorial governments develop, implement and enforce
the regulations; owners/operators pay the fines On-road examples: • British Columbia – Ministry of Transportation and Infrastructure – Motor Vehicle Act
Regulations • Ontario – Environmental Protection Act (anti-tampering provisions set out in Part III) • Quebec – Ministère du Développement durable, de l'Environnement et Lutte Contre les
Changements Climatiques (Ministry of Sustainable Development, Environment and the Fight against Climate Change) - Règlement sur la qualité de l'atmosphère (Regulation Respecting the Quality of the Atmosphere) - Règlement sur les normes environnementales applicables aux véhicules lourds (Regulations respecting environmental standards for heavy vehicles)
• Nova Scotia – Department of Transportation and Infrastructure Renewal – Motor Vehicle Act – Standards of Vehicle Equipment Regulations
• Newfoundland and Labrador – Department of Transportation and Works – Highway Traffic Act – Licensing and Equipment Regulations
• Yukon – Environment Yukon – Environment Act – Air Emissions Regulations • Northwest Territories – Department of Transportation – Motor Vehicles Act – Motor Vehicle
Equipment Regulations Option Costs: • A detailed breakdown on costs is unknown, but includes the cost of enforcement to the
regulating agency, the cost of potential fines for owners/operators found to be in non-compliance, the cost of new devices or systems that control emissions, and the cost of equipment such as that to read OBD signals.
• Costs borne by vehicle owner/operators may include fines (if vehicle has been tampered with), as well as costs associated with the provisions of any anti-tampering program designed to enforce the regulation. For example, in Ontario, the set fine for operating a diesel fuelled heavy vehicle that contravenes emissions standards is $420. In Newfoundland and Labrador, the mandatory annual safety inspection for commercial heavy-duty vehicles is $95.15.
• Costs may also be borne by companies that offer emission system tampering services/products. For example, Edge Products LLC agreed to pay a $500,000 civil penalty to the US EPA for manufacturing and selling electronic devices that allowed owners of model year 2007 and later diesel pickup trucks to remove emission controls from their vehicles.
• Since the removal of or tampering with emission control devices and systems reduces fuel use slightly, owners/operators may incur an additional cost if they are required to reinstall, replace or adjust them.
Key Benefits: • With the enforcement of anti-tampering regulations, there is a potential for immediate and
large impact of emission reductions when those vehicles that have removed or tampered with emission control devices or systems are required to re-instate the control systems.
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Key Challenges: • Enforcement, detection and tracking of tampering (extent of problem largely unknown) • Jurisdictional issues, who is responsible for enforcement and proof required for enforcement
(evidence may not always be visible) • Owners/operators understanding the magnitude of potential air quality and health benefits • Owner/operator concerns about unequal playing field (in terms of real or perceived fuel
savings from not having the devices and if not all vehicles are maintaining operation of the devices/systems).
EVALUATION NOTES
Emission control system anti-tampering requirements Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: High
The evaluation assesses reduction potential assuming that the regulations result in the identification and repair of tampered vehicles. PM2.5 emission reduction potential is based on US EPA emission standards for model year vehicles 1998-2003 and 2007+ and the assumption that diesel particulate filters (DPFs) are altered from 2007+ standards to 1998-2003 standards.
(Truck News, 2013) (US EPA, 2013)
Air pollutant emission reduction potential per vehicle - NOx or VOCs
On-Road NOx: High On-Road VOC: Mid
The evaluation assesses reduction potential assuming that the regulations result in the identification and repair of tampered vehicles. Emission reductions will depend on the type of emission control system that has been tampered with (e.g. selective catalytic reduction, exhaust gas recirculation). NOx emission reduction potential are based on US EPA emission standards for model year vehicles 1998-2003 and 2007 and the assumption that exhaust gas recirculation (EGR) systems are altered from 2007+ standards to 1998-2003 standards.
GHG emission reduction potential per vehicle - CO2e
N/A This evaluation criterion is not applicable as emission control system anti-tampering regulations do not apply to GHGs.
(Browning, 2014)
Policy/Program costs (Total $ and $/year as available)
Limited Info
Capital costs would be associated with developing the regulations and also include purchasing of tampering detecting equipment and software. Operating costs would be associated with enforcing and/or policing the regulations, which may include spot checks, staff to carry out spot checks, etc. Detailed cost information was not identified during the course of this work.
Vehicle - Capital Costs ($/vehicle)
Low Cost If owners/operators have tampered with their vehicles there would be a cost to the owner/operator to come into compliance. For example, in Ontario, the set fine for operating a diesel fuelled heavy vehicle that contravenes emission standards is $420.
(Ontario Court of Justice, 2003)
Vehicle - Operating Costs ($/vehicle)
No cost to Low Cost
There may be no operating costs to the private sector. However it is noted that if owner/operators are not in compliance, there would be costs associated with coming into compliance (such as paying fines and/or repairing the vehicle/engine to original state). There may be costs associated with inspection requirements of an anti-tampering program. In Newfoundland and Labrador, the Highway Traffic Act Licensing and Equipment Regulations contain anti-tampering provisions. The province has a mandatory annual safety inspection for commercial heavy-duty vehicles that includes inspection of the catalytic converter and fuel evaporative control system (for emission control purposes). The vehicle inspection fee for truck or truck tractor, bus or motorized home (over 4500 kg) is $95.15. Prince Edward Island's Motor Vehicle Inspection Regulations requires a yearly exhaust system inspection. The cost of this inspection is unknown at this time.
(Cope, 2004) (Bronson Consulting, 2013) (Nova Scotia Registry of Motor Vehicles , 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Difficult Emission control system anti-tampering requirements have been set at the provincial/territorial level and may have to go through a number of regulatory hurdles and involve consultation/collaboration with the public sector in addition to truck owner/operators, and possibly equipment and vehicle manufacturers.
(Cope, 2004)
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Emission control system anti-tampering requirements Criteria Eval. Notes References
Ease of complying
Moderate An owner/operator may be subjected to provisions of an anti-tampering program to ensure that devices are in working order.
(Cope, 2004) (Bronson Consulting, 2013)
Ease of proving compliance
Easy to Difficult
It may be difficult for owner/operators to prove compliance to regulators if no "proof' of compliance is required. However, if vehicles/engines are subject to anti-tampering enforcement programs under the requirement, identification of tampering may be evident and proving compliance may be easy. In Newfoundland and Labrador, the Highway Traffic Act Licensing and Equipment Regulations contain anti-tampering provisions and the province has a mandatory annual safety inspection for commercial heavy-duty vehicles (which includes exhaust equipment). Prince Edward Island's Motor Vehicle Inspection Regulations requires a yearly exhaust system inspection. These examples would allow the owner/operator to easily demonstrate to regulators that they are in compliance. It is unclear in some provinces/territories (with anti-tampering legislation) of how participants are to demonstrate compliance therefore a rating of difficult has been included.
(Cope, 2004) (Bronson Consulting, 2013)
Ability to enforce
Easy to Difficult
There are a number of techniques that could be used to enforce anti-tampering legislation, including anti-tampering programs that are built into an inspection and maintenance program, a safety inspection program or included as part of legislated resale requirements. It would be considered easy to enforce should enforcement mechanisms be built into the regulations while it would be considered difficult if no provisions are included in the requirements. A challenge for enforcement is the mechanism to detect tampering and determining proof of tampering is relatively difficult. In Newfoundland and Labrador, the Highway Traffic Act Licensing and Equipment Regulations contain anti-tampering provisions and the province has a mandatory annual safety inspection for commercial heavy-duty vehicles (which includes exhaust equipment). Prince Edward Island's Motor Vehicle Inspection Regulations requires a yearly exhaust system inspection. These examples would allow for easy identification of non-compliance by regulators. It is unclear in some provinces/territories (with anti-tampering legislation) of how non-compliance is identified and therefore a rating of difficult has been included. It is also noted that it may be possible to enforce anti-tampering regulations with respect to the 'tamperer'. There is anecdotal evidence to suggest that tampering is occurring and easily done however it is unclear how the 'tamperer' is penalized. The legislation needs to address the tamperers. The US EPA has authority to pursue tampering service providers (e.g. Edge Products LLC agreed to pay a $500,000 civil penalty to the US EPA for manufacturing and selling electronic devices that allowed owners of model year 2007 and later diesel pickup trucks to remove emission controls from their vehicles).
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Generally a few high emitters due to tampering can impact the fleet of
vehicles immensely. Capturing and correcting those vehicles can provide a large benefit. Cost for such a program is fairly low.
(Browning, 2014)
Co-benefits Yes Black carbon emission reductions expected (with reductions of PM2.5). Negative impacts
No Anti-tampering requirements do not appear to result in unintended negative impacts. However, there is anecdotal evidence to suggest that those in the industry are tampering with their vehicles/engines, despite regulations in effect as they are skeptical of the emissions benefits and believe that removing emission control devices results in better performance of their vehicles/equipment. As a result, use of certain devices may in fact increase GHG emissions.
(Truck News, 2013)
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1.1.2. Vehicle emission standards/fleet rules for in-use fleet PROFILE
Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • All diesel vehicles and engines
Objective: • To reduce emissions from on-road and off-road diesel vehicles and engines by establishing
emission limits for each substance (and vehicle).
Brief Description: • Vehicle standards are set to limit emissions from in-use diesel vehicles and engines.
Emission standards can be enacted and applied to different jurisdictions, from the national level to the local level. They may be applied on a per vehicle basis or to establish fleet average emission rates. For example, fleet rules can be passed that deal with the existing fleet by requiring them to be retrofit to meet a more stringent emission standard upon engine rebuild or cause a phase out of older models8.
• The federal government, under the Canadian Environmental Protection Act, 1999 (CEPA, 1999) sets emission standards for new vehicles, which are applicable at the point of manufacture or import into Canada9. Emissions standards for new vehicles are not considered in this document. These standards can provide guidance on possible in-use limits10. Provinces and territories are responsible for setting standards for in-use vehicles and engines.
• Emissions limits can be set on different substances, but commonly include PM, NOx, VOCs and CO.
• The standards may also establish test procedures or prescribe methods to meet emission standards, such as existing vehicles to be retrofit with diesel particulate filters.
8 California Air Resources Board (CARB) did this with their truck and bus rule and South Coast Air Quality Management District (SCAQMD) did this through a fleet rule. 9 For a complete list of federal transportation emission regulations please refer to: http://www.ec.gc.ca/Air/default.asp?Lang=En&n=DDBB166E-1. 10 Engines are required to comply with the standards for a defined useful life that depends on the engine class. However, modifications that are made after the first retail sale are not covered by the regulations.
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Method of Compliance and Enforcement: • Registration, labelling, voluntary reporting, roadside checks • Fines Cost Bearer(s): • Single funder or shared • Public or private sector provincial/territorial and municipal governments develop, implement
and enforce the regulations; owners/operators pay for technology upgrades if/as necessary, and pay the fines
On-road examples: • Newfoundland and Labrador – Air Pollution Control Regulations – Air emission standards • California – Diesel Risk Reduction Plan, Truck and Bus Regulation • Tokyo Metropolitan Government – Local in-use particulate emission standard Off-road examples: • California Air Resources Board (CARB) – In-Use Off-Road Diesel Vehicle Regulation • US Code of Federal Regulations (CFR) Title 40, Chapter I, Subchapter U, Part 1068 –
General Compliance Provisions for Highway, Stationary, and Nonroad Programs • Metro Vancouver – Non-road Diesel Emission Regulation Bylaw • Los Angeles County Metropolitan Transportation Authority – Green Construction Policy • Rhode Island Diesel Emission Reduction Act
Option Costs: • Owners/operators may have upfront costs to meet a more stringent emission standard than
the original emission standard of the vehicle/engine for their fleet vehicles. Owners/operators can meet these standards by various means including retrofits/upgrades, replacement or deeming a high emitting vehicle as a low-use vehicle. Costs would vary, for example re-allocating the fleet may include minimal costs while replacement of a vehicle/engine may have a high associated cost (depending on the type of vehicle/engine that is replaced). The following are examples of equipment types and estimated costs that may be retrofitted to reduce PM and other pollutants:
• Diesel oxidation catalysts (DOCs), $500 to $2,000 per vehicle and depend on the engine size, sales volume and installation.
• High efficiency, passive diesel particulate filers (DPFs), $8,000 to $13,000. • Actively-regenerated, high efficiency DPF system, $15,000 to $30,000. • Low pressure exhaust gas recirculation (EGR) system, $18,000 to $20,000. • Selective catalytic reduction (SCR) system, $18,000 to $30,000. • Engine replacement could be greater than $50,000.
• In some instances, owners/operators may have to meet more stringent emission limits annually or have ongoing operating costs associated with retrofits/upgrades. For example:
• In a 2006 report, the US EPA used $208 as the net present value of catalyzed diesel particulate filter maintenance costs (installed on class 8b trucks) (US EPA, 2006).
• In a report from 2000, $872.73 was used for the annual urea cost for SCR (Brodrick et al., 2000).
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• Owners/operators may also have to pay an operating fee based on the age of the vehicle/engine. For example, the Metro Vancouver Non-road Diesel Emission Regulation Bylaw charges users of non-road diesel engines, and from 2012 to 2017, the per horsepower fee increases from $4 to $20 for Tier 0 engines, and from $6 to $10 for Tier 1 engines. The regulation currently returns 80% of the registration fees paid by an equipment owner to Metro Vancouver over the prior 3 years if the equipment owner retires or retrofits the vehicle.
• Costs may also be borne by those developing and implementing the regulations/rules. For example, under the Tokyo Metropolitan Government In-Use Emission Standard, more than 8.9 billion yen ($80 million) in subsidies were dispersed in the two years leading up to the enforcement of the mandatory system at 200,000 to 400,000 yen ($1,800 to $3,600) for DOCs and DPFs, respectively.
Key Benefits: • The magnitude of impact depends on the regulation and scope (e.g. larger sub-set of vehicles,
larger impact in terms of emission reductions) • Immediate impact (effective as soon as standards apply) • As an example, with respect to the Metro Vancouver Non-road Diesel Emission Regulation
Bylaw, the structure (and return policy) has been supported by stakeholders, and has resulted in an estimated 25% of the Tier 0 off-road vehicles in Metro Vancouver being retired over the first 2 years of the regulation.
Key Challenges: • Potential challenges include meeting new regulations within the defined timeframes,
particularly for small businesses. EVALUATION NOTES
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Mid Off-Road: Mid
On-Road: Evaluation is based on quantitative information available for one on-road example, the CARB Transit Fleet Vehicle Rule, which estimates reduction in total fleet diesel PM of 80% from 2005 to 2012. Off-Road: Evaluation is based on quantitative information available for one off-road example, the Metro Vancouver Non-road Diesel Emission Regulation Bylaw. Assumptions used to estimate the emissions reductions include: Tier 0 vehicles replaced with Tier 2 vehicles for all rated horsepower (hp) engines. Emission standards used are Metro Vancouver PM emission standards.
(Cheminfo Services Inc., 2014) (SNC Lavalin, 2013) (Metro Vancouver)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
Going from a 1998 to 2007 engine in an on-road truck reduces NOx by about 75%. Replacing a Tier 0 engine with a Tier 3 diesel engine in off-road equipment reduces NOx emissions by 73%. Similar reductions can be expected in terms of VOC emissions for on-road and off-road. San Francisco Clean Construction Ordinance requires the installation of emission control technologies on off-road diesel vehicles to meet US EPA Tier 2 standards. As an example, initial estimates of the California In-Use Off-Road Diesel Vehicle Regulation indicated that approximately 180,000 off-road vehicles in over 8,000 fleets would be affected. The regulation was initially expected to reduce approximately 43 tonnes of NOx per day statewide in 2020.
GHG emission reduction potential per vehicle - CO2e
On-Road: N/A Off-Road: N/A
These types of standards/rules are not targeting GHGs (or fuel economy). Examples reviewed focus on air pollutant reductions (NOX, PM).
Policy/Program costs (Total $ and $/year as available)
Limited Info Capital costs would be associated with developing the standards/rules. Operating costs would be associated with enforcing and/or policing the regulations, which could include spot checks, staff to carry out spot checks, administrative staff to review certificates, etc. Detailed cost information was not identified during the course of this work. The information below is provided as an illustrative sample. Tokyo Metropolitan Government In-Use Emission Standard - more than $80 million in subsidies were dispersed in the two years leading up to the enforcement of the mandatory system at $1,800 to $3,600 for DOCs and DPFs, respectively. This cost is considered low for North American standards, where a DPF for a heavy duty vehicle would generally cost $8,000 or more.
(ICCT, 2013)
Vehicle - Capital Costs ($/vehicle)
Low cost to High Cost
Owners/operators may have upfront costs to meet a more stringent emission standard than the original emission standard of the vehicle/engine for their fleet vehicles. Owners/operators can meet these standards by various means including retrofits/upgrades, replacement or deeming a high emitting vehicle as a low-use vehicle. For example, re-allocating the fleet may include minimal costs while replacement of a vehicle/engine may have a high associated cost (depending on the type of vehicle/engine that is replaced). The following are examples of equipment types and costs that may be retrofitted to reduce PM and other pollutants: DOCs from $500 to $2000 per vehicle and depend on the engine size, sales volume and installation; high-efficiency, passive DPFs at $8,000 - $13,000; actively-regenerated, high-efficiency DPF system at $15,000 to $30,000; low pressure exhaust gas recirculation (EGR) system estimated at $18,000 to $20,000; selective catalytic reduction (SCR) system from $18,000 to $30,000. Engine replacement could be greater than $50,000.
(Cheminfo Services Inc., 2014) (Lawson, 2014)
Vehicle - Operating Costs ($/vehicle)
No cost to Low Cost
It is assumed that there would be no annual operating costs once owners/operators were in compliance however in some instances, owners/operators may have to meet more stringent emission limits annually or have ongoing operating costs associated with retrofits/upgrades. The US EPA used the following net present value of catalyzed diesel particulate filter maintenance costs (installed on class 8b trucks): $208. Brodrick et al. indicate the following annual urea cost for SCR: $872.73. Owners/operators may also have to pay an operating fee based on the age of the vehicle/engine.
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Difficult Vehicle emission standards/fleet rules for fleets would have to go through a number of regulatory hurdles and involve the public sector in addition to fleet owner/operators, and possibly equipment and vehicle manufacturers. For example, during the development of the Metro Vancouver Non-Road Diesel Emission Regulation Bylaw No. 1161, 2012, developers of the regulation worked extensively with industry, the California Air Resources Board, the US EPA, the medical community and other stakeholders.
(Cheminfo Services Inc., 2014)
Ease of complying
Difficult Compliance may be difficult if the vehicles/engines are not in compliance as the owners/operators may need to invest money and/or resources to bring vehicles/engines into compliance.
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
The Metro Vancouver Non-Road Diesel Emission Regulation Bylaw No. 1161, 2012 has an efficient online registration system that allows affected entities to input their information easily. Similarly, the California Air Resources Board Diesel Off-Road On-Line Reporting System helps fleet owners report vehicle inventories for compliance with the off-road diesel regulation. These examples indicate that it is possible for owners/operators to easily prove compliance. Under the Newfoundland and Labrador Air Pollution Control Regulations the minister may establish an emission inspection and maintenance program to ensure opacity standards of diesel fuelled vehicles are met. It is unclear if a mandatory inspection and maintenance program is established however according to motor vehicle inspection requirements trucks, vans and truck tractors and trailers must display a valid inspection sticker on the vehicle.
(Cheminfo Services Inc., 2014)
Ability to enforce
Moderate Existing mechanisms to identify non-compliance include registration, labelling, spot-checks, voluntary reporting, etc.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Off-road evaluation is based on one example found for San Francisco's
Clean Construction Ordinance. (Browning, 2014)
Co-benefits Yes Black carbon emission reductions expected (with reductions of PM2.5).
Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • Specific vehicles targeted by legislation –
typically commercial or municipal vehicles
Objective: • To retrofit, upgrade or replace existing in-use diesel vehicles in order to meet emission
standards or to meet emission reduction targets.
Brief Description: • Regulations pertaining to retrofits and engine upgrades and replacements typically target a
certain fleet of vehicles, age range of vehicles, or vehicles operating in a certain geographic area (e.g. ports or construction zones), requiring them to meet emission standards or reduce emissions.
• Retrofits generally target air pollutant emissions, while engine upgrades can target both air pollutants and GHGs. Retrofits refer to add-on pollution control devices to limit emissions of CACs, while engine upgrades or replacements are intended to make engines run more efficiently thereby reducing fuel use, increasing fuel savings and reducing emissions of both CACs and GHGs.
• Engine retrofits are generally required to be carried out with approved emission reduction devices (requiring a formal equipment verification process); upgrades and replacements involve entire engines being rebuilt or replaced.
• Requirements typically target older, more polluting vehicles and engines and truck classes and models or the geographic area with high emissions and/or poor air quality.
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• For some upgrade regulations fleets are required to remove and scrap older engines to meet certain fleet emission targets.
• Examples of target vehicles include school buses, solid waste collection vehicles, drayage trucks, commercial heavy duty vehicles of specific model years and classes, mobile cargo handling equipment, and construction equipment.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
Method of Compliance and Enforcement: • Spot-checks (roadside), inspections, work-site requirements, voluntary reporting • Warnings, fines
Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop, implement and enforce the regulations;
Owners/operators pay for technology upgrades if/as necessary, and pay the fines On-road examples: • BC Ministry of Transportation and Infrastructure, Commercial Vehicle Safety &
Enforcement, Diesel Retrofit - Air Action Plan – Diesel Retrofit Requirement • British Columbia – Diesel School Bus Retrofit Program • California Air Resources Board (CARB) – Drayage Truck Regulation, Truck and Bus Rule • California Air Resources Board (CARB) – Solid Waste Collection Vehicle (SWCV) Rule • Port of New York and New Jersey – Clean Air Strategy Off-road examples: • California – Cargo Handling Equipment Regulation • Connecticut – Clean Air Construction Initiative • Massachusetts – Diesel Retrofit Program • New Jersey – Clean Construction Executive Order • Switzerland Emission Regulations for In-Use Engines
Option Costs: • Depends on program and scope, but can be substantial for owners/operators that need to meet
the regulations. Costs for both the implementation and maintenance of the retrofit/rebuild/replacement technologies needs to be considered.
• Retrofits/upgrades may include a number of retrofit technologies as well as complete replacements or repowering of engines.
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• BC estimated retrofit costs for on-road heavy-duty diesel vehicles would be approximately $1,200 - $2,500 per vehicle (to meet the Diesel Retrofit Requirement) (BC Ministry of Transportation and Infrastructure, 2011).
• For the BC diesel school bus retrofits, the budget for completing the retrofit of all school-district-owned buses was $1.2 million over three fiscal years (Province of BC) and vendor contracts were issued for $0.655 million (BC Ministry of Environment, 2013).
• The following are examples of equipment types and costs to reduce PM and other pollutants (CARB , 2010):
• Diesel oxidation catalysts (DOCs), $500 to $2,000 per vehicle and depend on the engine size, sales volume and installation.
• High efficiency, passive diesel particulate filers (DPFs), $8,000 to $13,000. • Actively-regenerated, high efficiency DPF system, $15,000 to $30,000. • Low pressure exhaust gas recirculation (EGR) system, $18,000 to $20,000. • Selective catalytic reduction (SCR) system, $18,000 to $30,000. • Average cost to repower an engine is $45,000, with a range from $21,000 to $90,000.
• Operating costs are dependent on the retrofit/upgrade. For example, DOCs require little or no maintenance; DPFs require periodic maintenance to clean out non-combustible materials, such as ash; SCR systems require periodic refilling of diesel exhaust fluid; lean NOX catalyst can increase fuel consumption. For example:
• In a 2006 report, the US EPA used $208 as the net present value of catalyzed diesel particulate filter maintenance costs (installed on class 8b trucks) (US EPA, 2006).
• In a report from 2000, $872.73 was used for the annual urea cost for SCR (Brodrick et al., 2000).
• Owner/operators may also be subjected to fines. For example, failure to comply with Massachusetts Department of Transportation diesel retrofit requirement can result in non-compliance penalties. This can either be withholding contractor payments or a daily monetary deduction ($2,500 for each calendar day the deficiency continues) (Kasprak, Schattanek and Kenny, 2011).
• The US EPA has also calculated the cost effectiveness of a number of retrofits (US EPA, 2006):
• School bus DOC and catalyzed DPF retrofits ranged from $12,000 - $50,500 USD per ton of PM reduced (approximately $14,400 - $61,000 CAD per tonne PM reduced)
• Class 6&7 heavy duty diesel vehicle (HDDV) DOC and catalyzed DPF ranged from $27,600 - $69,900 USD per ton PM reduced (approximately $33,200 - $84,100 CAD per tonne PM reduced); for Class 8b trucks ranged from $11,100 - $44,100 USD per ton PM reduced (approximately $13,400 - $53,000 per tonne of PM reduced)
• 250 horsepower (hp) bulldozers DOC retrofits ranged from $18,100 - $49,700 USD per ton PM reduced (approximately $21, 800 - $59,800 CAD per tonne PM reduced)11.
11 Unless otherwise noted, conversions from USD to CAD throughout the report have been calculated using 1 USD = 1.09179 CAD. Conversions from short ton to metric tonne throughout the report have been calculated using 1 ton = 0.90718474 tonnes.
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Key Benefits: • Mandatory programs enable more robust impact predictions in terms of emission reductions.
Since retrofits and engine upgrades and replacement can reduce emissions significantly on a per vehicle basis, particularly for older vehicles and engines, there is the potential for significant emission reductions, but the emission reductions will depend on the targeted vehicle and engine population.
• Ability to target specific fleets associated with high potential for population exposure (e.g. construction fleets) or with sensitive receptors (e.g. school buses). As a result, programs that are directed at certain vehicle populations can ensure higher emission reductions in specified areas to maximize health benefits. For example, construction equipment regulations target projects that release high amounts of emissions in densely populated areas over potentially long periods of time. School bus regulations target emissions near vulnerable populations.
• Immediate impact (effective as soon as standards apply).
Key Challenges: • Additional outreach/consultation and enforcement is required. Also, new types of guidance
may be required to ensure that appropriate technologies and vendors are promoted, including a formal verification process to develop and maintain a list of verified technologies to ensure emission reductions are achieved and to maximize cost effectiveness.
• Potential for high capital costs and therefore may require significant sources of funding. • Some technologies that reduce air pollutant emissions (e.g. PM) may increase GHG
emissions due to increased fuel consumption. The fuel penalty is generally around 3%. For example, DPFs in MY 2007+ trucks require extra fuel in the regeneration procedure, thereby reducing the fuel efficiency advantage of a diesel engine (Lance, et al., 2012).
• On the other hand, when an SCR is used instead of an EGR, there is a fuel efficiency improvement. This is because EGRs, when used to reduce NOx emissions, cause less efficient combustion (because some of the air in the engine cylinder is replaced with exhaust). This tends to richen the fuel/air ratio and thus results in lower NOx, but at a fuel consumption penalty. When SCRs are used, the amount of exhaust gas recirculation needed can be reduced and thus resulting in a fuel efficiency benefit.
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Low to High Off-Road: Low to High
On-Road evaluation of low to high is based on quantitative information available for the following programs/policies, which are on a per vehicle basis: BC Diesel Retrofit Requirement - assume model year (MY) 1989-1993 retrofit with DOC (typical reduction of ~20%); CARB SWCV's Rule - assume MY 2006 & earlier retrofit to meet 2010 PM Targets; Rhode Island Diesel Emission Reduction Act - assume MY1993 upgraded to MY2007 standards. Off-Road evaluation of low to high is based on quantitative information available for the following programs/policies: New Jersey Clean Construction Ordinance - 85% PM reduction; Rhode Island Diesel Emission Reduction Act - if the entire legacy fleet of construction equipment was retrofitted with DOCs, an overall 20% reduction would occur, and if all were retrofitted with DPFs, an overall 90% reduction would likely occur.
(Lawson, 2014) (SNC Lavalin, 2013) (State of Rhode Island General Assembly, 2010) (State of Rhode Island, 2007) (University of Rhode Island, 2014) (The Port Authority of NY and NJ, 2013)
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-Road NOX: Low to Mid Off-Road NOX: Low to Mid On-Road VOC: Mid Off-Road VOC: Mid
Evaluation of NOX reductions is based on current US EPA estimates of NOX reductions of diesel retrofit devices, as documented by the National Clean Diesel Campaign website which indicates the following: SCR - typical NOX emission reduction of up to 75% EGR - typical NOX emission reduction of 25-40% Lean NOX Catalyst - typical NOX emission reduction of 5-40% Evaluation of VOC reductions is based on technical expert opinion (DOCs and DPFs will reduce VOCs by 50-80%).
(US EPA, 2013) (Browning, 2014) (The Port Authority of NY and NJ, 2013) (US EPA, 2013)
GHG emission reduction potential per vehicle - CO2e
On-Road: Mid Off-Road: unknown
It is not considered likely that a program would aim to reduce GHG emissions via retrofits as popular retrofits, such as DOC and DPF may increase GHG emissions slightly. It is reported in the Levelton et al. 2005 study that DOCs can increase GHG emissions by 1 to 2%, DPFs can increase GHG emissions by 2 to 4%. However, it is acknowledged that upgrading to a more efficient engine would have associated GHG benefits. The same study by Levelton estimates that engine replacement can reduce GHG emissions by 10%.
(Levelton Consultants Ltd. et al, 2005) (Browning, 2014)
Policy/Program costs (Total $ and $/year as available)
Limited Info Capital costs would be associated with developing the regulations. Operating costs would be associated with enforcing/policing the regulations, which could include registration requirements, roadside spot-checks, inspections, issuing warnings, fines, etc. Detailed cost information was not identified during the course of this work. The information below is provided as an illustrative sample. Approximately $1.2 million was provided in British Columbia between 2009 and 2010 for retrofits of school buses for 406 installations. Of which, $0.655 million was allocated to vendor contracts.
(Lawson, 2014) (Province of BC) (BC Ministry of Environment, 2013)
Vehicle - Capital Costs ($/vehicle)
Low to High Retrofits/upgrades may include a number of retrofit technologies as well as complete replacements or repowering of engines. Engine retrofits are considered to cost from low to medium whereas engine replacements and repowering engines may be much more and are considered high. The following are examples of equipment types and costs that may be retrofitted to reduce PM and other pollutants: DOCs from $500 to $2000 per vehicle and depend on the engine size, sales volume and installation; high-efficiency, passive DPFs at $8,000 - $13,000; actively-regenerated, high-efficiency DPF system at $15,000 to $30,000; low pressure EGR system at $18,000 to $20,000; SCR system expected to range from $18,000 to $30,000. Repowering an engine ranges from $21,000 to $90,000
(Lawson, 2014) (CARB , 2010)
Vehicle - Operating Costs ($/vehicle)
Savings potential to Low Cost
Operating costs are dependent on the retrofit/upgrade. For example, DOCs require little or no maintenance; DPFs require periodic maintenance to clean out non-combustible materials, such as ash; SCR systems require periodic refilling of diesel exhaust fluid; lean NOX catalyst can increase fuel consumption. Potential operating savings due to reduced fuel consumption for some retrofits e.g. SCRs. The US EPA used the following net present value of catalyzed DPF maintenance costs (installed on class 8b trucks): $208. Brodrick et al. indicate the following annual urea cost for SCR: $872.73. Failure to comply with Massachusetts Department of Transportation diesel retrofit requirement can result in non-compliance penalties. This can either be withholding contractor payments or a daily monetary deduction ($2,500 for each calendar day the deficiency continues).
(Lawson, 2014) (US EPA, 2013) (US EPA, 2006) (Brodrick et al., 2000) (Kasprak, Schattanek and Kenny, 2011)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Moderate to Difficult
Mandatory retrofit/upgrade regulations would have to go through a number of regulatory hurdles and involve the public sector in addition to fleet owner/operators, and possibly equipment and vehicle manufacturers.
Ease of complying
Difficult Compliance could be difficult should owners/operators need to source and install retrofits/upgrades to their vehicles/engines. An evaluation of difficult was decided based on the fact that owners/operators would need to invest resources prior to operating the vehicle/engine in order to comply.
Ease of proving compliance
Easy to Difficult Range reflects requirements of differing regulations reviewed. For example, the Massachusetts Revised Diesel Retrofit specifications require that contractors sign certification that all vehicles meet standards whereas no proof of compliance is apparent for the BC Diesel Retrofit
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
Range reflects requirements of differing regulations reviewed. For example, the Massachusetts Revised Diesel Retrofit specifications require that contractors sign certification that all vehicles meet standards whereas no proof of compliance apparent for BC Diesel Retrofit Requirement.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive The cost-effectiveness ($/tonne pollutant reduced) for a diesel retrofit
program depends on the retrofit technologies used, and the age and activity level of the vehicles/equipment. The US EPA calculated the median program cost to be $5,950 USD per ton NOx reduced (approximately $7,160 CAD per tonne NOx reduced) and the range to be $1,900 - $19,000 USD per ton NOx reduced (approximately $2,300 - $22,900 CAD per tonne NOx reduced). For illustrative purposes, below are examples of US EPA cost-effectiveness ($/tonne pollutant reduced) estimates for various specific retrofit technologies: School bus DOC approximately $14,400 - $59,000 CAD per tonne PM reduced; Class 8b truck DOC approximately $13,350 - $48,900 CAD per tonne PM reduced; Off-highway trucks DOC approximately $26,100 - $94,800 CAD per tonne PM reduced; Cranes DOC approximately $25,150 - $72,200 CAD per tonne PM reduced; Tractors and loaders upgrade kit approximately $3,100 - $5,900 CAD per tonne NOx reduced. It is reported in Cheminfo, 2014 that the California Cargo Handling Equipment Regulation would result in cost-effectiveness values of approximately $25/lb of diesel PM and $1/lb of NOx reduced.
Co-benefits Yes Potential benefits beyond emission reductions may be reduced fuel consumption and performance improvements for certain technologies. Black carbon emission reductions expected (with reductions of PM2.5).
(Lawson, 2014)
Negative impacts
Yes Some technologies that reduce air pollutants may increase GHG emissions due to increased fuel consumption.
(Lance, et al., 2012)
1.2. Vehicle and Equipment Programs and Practices
1.2.1. Programs to encourage use of alternative vehicles and technologies
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • On-road and off-road diesel vehicles,
typically with high use Objective: • To increase the use of alternative technology vehicles and technologies aimed at reducing
GHG and air pollutant emissions. Brief Description: • Programs to encourage use of alternative technology vehicles and technologies may be
targeted to certain vehicles, fleets, groups of fleets, or all vehicles (that fall under the jurisdiction). For example, some programs may apply to all fleets across a municipality, while others may only apply to certain vehicle types, such as transit buses or waste collection trucks.
• Programs may also be implemented by authorities with control over vehicle entry, such as ports and construction sites.
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• Technology and vehicle options vary substantially by fleet. Examples include transit buses with alternative technologies (e.g. hybrid diesel-electric buses, fuel cell electric buses), alternative technology waste collection vehicles (e.g. hybrid diesel-electric garbage trucks, hydraulic launch assist garbage trucks that reduce fuel consumption), idling reduction technologies (e.g. auxiliary power units, truck stop electrification equipment), and hydraulic and electric cargo handling equipment.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs Method of Compliance and Enforcement: • Self-reporting12, otherwise N/A Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop the programs, they may also provide
incentives and funding; Owners/operators pay for technology upgrades On-road examples: • Ottawa – Hybrid diesel-electric transit • City of Toronto – Hydraulic launch-assist garbage trucks • Government of British Columbia, Ministry of Transportation and Infrastructure – Truck stop
electrification • Wisconsin State Energy Office – Diesel truck idling reduction grant program Off-road examples: • Port of New York and New Jersey – Clean Air Strategy • Washington – Idle Reduction Tax Incentives and Exemptions Option Costs: • Costs range based on the type of alternative technology vehicle or technology. For example
(Center for Energy and Environmental Policy, 2007) (State of Wisconsin, 2012) (Federation of Canadian Municipalities, 2009) (US EPA, 2007):
• Automatic shutdown/turn-on system: < $1,000 • Truck auxiliary power units (APUs): Median cost of $3,100 • Direct fired heater: $2,000 - $4,000 • Thermal storage system/energy recovery system: $4,000 - $5,000
12 Enforcement can only be mandatory if grants or incentives are given.
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
• Hybrid diesel electric buses: approximate cost of $650,000 (~$150,000 more than a conventional diesel bus)
• Truck-stop electrification systems: $8,000 per space to $25,000 per space (depending on type, i.e. on-board vs. off-board solution).
• The Center for Energy and Environmental Policy reports that the economic savings from anti-idling technology can be in the range of $9,000 per year. The same study indicates that the annual operating and maintenance costs for direct fired heaters and APUs are $500 (Center for Energy and Environmental Policy, 2007).
• There may be costs associated with implementing and operating such a program. For example, the Diesel Truck Idling Reduction Grant Program (Wisconsin State Energy Office) took $5,000,000 to be distributed for grants from 2007 through 2009. The total awarded funds from 2007 to 2010 are reported to be $5,851,156, corresponding to 1,594 idling reduction units for 411 individual awards (State of Wisconsin, 2012). The 2008 BC Air Action Plan committed $28 million to improving air quality. About $4 million was dedicated to clean transportation projects such as retro-fitting school and transit buses, supporting Green Fleets BC and projects with Port Metro Vancouver13. A truck stop electrification project was funded by the Ministry of Transportation and Infrastructure with funds from a green transportation initiative in place at the same time. To date, a total of $30,000 was provided to install 3 electrified truck stops near the BC/Washington border14.
• The US EPA calculated the program costs of a number of mobile source programs. Examples include (US EPA, 2007):
• Median tuck stop electrification program cost-effectiveness $1,700 USD per ton NOx and VOC (4:1 weighting) reduced (approximately $2,000 CAD per tonne) and the range to be $1,400 - $2,000 USD per ton reduced (approximately $1,700 - $2,400 CAD per tonne)
• Median truck APUs program cost-effectiveness $3,100 USD per ton NOx and VOC (4:1 weighting) reduced (approximately $3,700 CAD per tonne) and the range to be $2,700 - $3,500 USD per ton reduced (approximately $3,250 - $4,200 CAD per tonne).
Key Benefits: • Specific emission reduction benefits vary by technology, vehicle and use. • For example, hybrid technologies are more suited to stop and go driving or to vehicles that
make frequent stops and have low maximum speeds (e.g. transit buses), due to the hybrid configuration and regenerative braking system (Transport Canada, 2009).
• Reduced noise level for certain technologies, such as hybrid and electric engines. • Potential for reduced maintenance, depending on the technology. For example, hybrid
vehicles have extended brake life due to regenerative braking. Key Challenges: • Substantial upfront/capital costs for new vehicles/equipment
13 Correspondence with BC Ministry of Environment, June 2015. 14 Correspondence with BC Ministry of Transportation & Infrastructure, January 2015.
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• Perceived reliability concerns for new technologies • Potential maintenance changes requiring additional training and equipment EVALUATION NOTES
Programs to encourage use of alternative vehicles and technologies Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-road: Mid to High Off-road: Mid to High
On-road: The evaluation is based on information regarding the Wisconsin State Energy Office Diesel Truck Idling Reduction Grant Program. This program evaluated emission reductions using the federal "Diesel Emissions Quantifier”, which estimates vehicle tailpipe emissions only. It is important to note that emission reductions will vary based on type of vehicle and/or technology and that the above reference includes reduction estimates for anti-idling technologies, which are in the mid-range. Electric vehicles would have a high tailpipe PM reduction associated with them as they would have zero tailpipe emissions. Depending on the electricity generation mix, PM emissions associated with creating the energy to power the electric vehicle would be impacted however are not considered here. Although not considered further here, it is important to note that electricity generation usually occurs outside the city, so urban PM emission reductions would be large. On-road/Off-road use of electric and hybrid electric equipment can reduce tailpipe PM emissions. For example, the Port of New York and New Jersey Clean Air Strategy estimated a 30% reduction of PM emissions from completing an installation of 39 out of 53 electric cranes and modernizing all cargo handling equipment at container terminals to models meeting EPA’s 2004 on-road emissions standards.
(State of Wisconsin, 2012) (ERG, 2014) (Browning, 2014) (The Port Authority of NY & NJ, 2009)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-road NOx: Mid to High Off-road NOx: Mid to High On-road VOC: Mid to High Off-road VOC: Mid to High
On-road: The evaluation is based on information regarding the Wisconsin State Energy Office Diesel Truck Idling Reduction Grant Program. This program evaluated emission reductions using the federal "Diesel Emissions Quantifier", which estimates vehicle tailpipe emissions only. It is important to note that emission reductions will vary based on type of vehicle and/or technology and that the above reference includes reduction estimates for anti-idling technologies, which are in the mid-range. Electric vehicles would have a high tailpipe NOx and VOC reduction associated with them as they would have zero tailpipe emissions. Depending on the electricity generation mix, NOx and VOC emissions associated with creating the energy to power the electric vehicle would be impacted however are not considered here. On-road/Off-road use of electric and hybrid electric vehicles and equipment can reduce tailpipe NOx and VOCs. For example, the Port of New York and New Jersey Clean Air Strategy estimated a 30% reduction of NOx emissions from completing an installation of 39 out of 53 electric cranes and modernizing all cargo handling equipment at container terminals to models meeting EPA’s 2004 on-road emissions standards.
(State of Wisconsin, 2012) (ERG, 2014) (Browning, 2014) (The Port Authority of NY & NJ, 2009)
GHG emission reduction potential per vehicle - CO2e
On-road and Off-road: Low to High
Anti-idling devices and APUs can reduce idle emissions and fuel use while trucks idle overnight. Hybridization or conversion to electric reduces emissions and fuel use for both on-road and off-road. On-road: For example, a 2006 study with New York City Transit showed a 12 month average improvement in fuel efficiency of 37% based on two separate bus depots (one achieved 34% improvement, the other 40% improvement). Off-road: For example, the Port of New York and New Jersey Clean Air Strategy estimated a 30% reduction of GHG emissions from completing an installation of 39 out of 53 electric cranes and modernizing all cargo handling equipment at container terminals to models meeting EPA’s 2004 on-road emissions standards.
(Browning, 2014) (The Port Authority of NY & NJ, 2009) (Barnitt, R. and Chandler, K., 2006)
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Programs to encourage use of alternative vehicles and technologies Criteria Eval. Notes References
Policy/Program costs (Total $ and $/year as available)
Limited Info Operating costs may range based on the type of program and outreach. For example, a small on-line based campaign with no incentives would be low cost whereas larger programs with operating partners and incentives would be high cost. Detailed cost information was not identified during the course of this work. The information below is provided as an illustrative sample. The Diesel Truck Idling Reduction Grant Program (Wisconsin State Energy Office) appropriated $5,000,000 to be distributed for grants from 2007 through 2009. The total awarded funds from 2007 to 2010 were reported to be $5,851,156, corresponding to 1,594 idling reduction units for 411 individual awards. The 2008 BC Air Action Plan committed $28 million to improving air quality. About $4 million was dedicated to clean transportation projects such as retro-fitting school and transit buses, supporting Green Fleets BC and projects with Port Metro Vancouver. A truck stop electrification project was funded by the Ministry of Transportation and Infrastructure with funds from a green transportation initiative in place at the same time. To date, a total of $30,000 was provided to install 3 electrified truck stops near the BC/Washington border.
(State of Wisconsin, 2012) (Province of BC) (BC Ministry of Transportation & Infrastructure, 2015)
Vehicle - Capital Costs ($/vehicle)
Low to High Costs range based on the type of alternative technology vehicle or technology. Alternative technology vehicle and technology costs have found to range from the following: Automatic Shutdown/Turn-On System: < $1,000; Truck APUs: Median cost of $3,100; Direct Fired Heater: $2,000 - $4,000; Thermal Storage System/Energy Recovery System: $4,000 - $5,000; Auxiliary Battery Powered Heating/AC with Inverter: $7,000 -$12,000; Hybrid Diesel Electric Buses: approximate cost of $650,000; Truck-Stop Electrification systems: $8,000 per space to $25,000 per space (depending on type, i.e. on-board vs. off-board solution).
(Center for Energy and Environmental Policy, 2007) (State of Wisconsin, 2012) (Federation of Canadian Municipalities, 2009) (US EPA, 2007)
Vehicle - Operating Costs ($/vehicle)
Savings to Low Cost
It is assumed there are no additional operating costs; however, it is important to note that savings may result from reduced maintenance and fuel consumption, whereas low costs may be a result of increased fuel consumption, depending on the type of vehicle and/or technology. The Center for Energy and Environmental Policy reports that the economic savings from anti-idling technology can be in the range of $9,000 per year. The same study indicates that the annual operating and maintenance costs for direct fired heaters and APUs are $500. There is anecdotal evidence to suggest that hybrid vehicles (such as diesel-electric buses) may result in increased operating costs above what was expected. For example, there have been reports in the media stating that the City of Ottawa spent $1 million more than expected on diesel fuel, and an unexpected $7 million to replace batteries on some of the hybrid buses.
(Center for Energy and Environmental Policy, 2007) (CBC, 2012) (Willing, 2013) (Willing, 2012)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy to Moderate
While there is considered to be no regulatory hurdles to overcome with a non-mandatory program, program developers/administrators may require some consultation outside of government to decide which alternative technology vehicles and technologies to include in program.
Ease of complying
N/A
Ease of proving compliance
N/A
Ability to enforce
N/A
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive For illustrative purposes, below are examples of cost-effectiveness of
various anti-idling technologies, as estimated by the Center for Energy and Environmental Policy, 2007: On-Board Truck Stop Electrification: $5.02 per ton NOX reduction; Off-Board TSE: $9.42/ton NOx reduction; Direct-Fired Heaters: $5.07/ton NOX; APU's: $9.10/ton NOX reduction
(Browning, 2014) (Center for Energy and Environmental Policy, 2007)
Co-benefits Yes Reduced noise level potential for certain technologies (hybrid and electric engines); potential for reduced maintenance, dependent on technology. Black carbon emission reductions expected (with reductions of PM2.5).
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Programs to encourage use of alternative vehicles and technologies Criteria Eval. Notes References
Negative impacts
Yes Some technologies that reduce air pollutants may increase GHG emissions due to increased fuel consumption. May result in pulling electricity from the grid (which, depending on jurisdiction may be more emissions intensive).
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • On-road and off-road higher emitting diesel vehicles and engines
Objective: • To retrofit, upgrade or replace existing in-use diesel vehicles or engines in order to meet
emission standards or to meet emission reduction targets. Brief Description: • Engine retrofits generally target air pollutant emissions, while engine upgrades can target
both air pollutants and GHGs. Engine retrofits refer to add-on pollution control devices to limit emissions of CACs, while engine upgrades or replacements are intended to make engines run more efficiently thereby reducing fuel use, increasing fuel savings and reducing emissions of both CACs and GHGs.
• Grants are made to distribute funds to local public and private entities to cover engine retrofits, upgrades and replacements for both on-road and off-road vehicles and engines. Voluntary subsidy programs encourage early rebuilding, replacement or retrofitting of higher emitting diesel engines by covering all or some of the incremental costs.
• Some programs also cover vehicle retrofits to improve fuel efficiency. • Retrofits and upgrades can be applied to vehicles or engines. For example, aerodynamic
technologies, low rolling resistance tires, and idle-reduction technologies are all examples of vehicle retrofits, certified engine configurations, or verified retrofit technologies (e.g. DPF, DOC, etc.) are examples of engine retrofits.
• For some upgrade programs, fleets are required to remove and scrap older engines to be eligible for incentives.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs Target Vehicles: • On-road and off-road higher emitting diesel vehicles and engines
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Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs • National – Develop and implement programs Method of Compliance and Enforcement: • If, as part of the retrofit/upgrade program, older vehicles or engines are required to be
destroyed, proof is generally required to show that the engine has been made unusable, such as it being drilled with holes.
• Otherwise N/A Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop the programs, they may also provide
incentives and funding; Owners/operators pay for technology upgrades On-road examples: • US EPA – Diesel Emission Reduction Act Grants • California Air Resources Board – Carl Moyer Grant Program • Metro Vancouver – DOC retrofit project • Toronto – Regenerative air street sweepers • Denver – DOC and crankcase retrofits for garbage trucks Off-road examples: • California Air Resources Board – In-Use Off-Road Mobile Agricultural Equipment
Regulation Option Costs: • Retrofits/upgrades/replacements may include a number of retrofit technologies as well as
complete replacements or repowering of engines. • The following are examples of equipment types and costs to reduce PM and other pollutants
(Lawson, 2014) (CARB , 2010): • Diesel oxidation catalysts (DOCs), $500 to $2,000 per vehicle and depend on the
engine size, sales volume and installation. • High efficiency, passive diesel particulate filers (DPFs), $8,000 to $13,000. • Actively-regenerated, high efficiency DPF system, $15,000 to $30,000. • Low pressure exhaust gas recirculation (EGR) system, $18,000 to $20,000. • Selective catalytic reduction (SCR) system, $18,000 to $30,000. • Average cost to repower an engine is $45,000, with a range from $21,000 to $90,000.
• Operating costs are dependent on the retrofit/upgrade. For example, DOCs require little or no maintenance; DPFs require periodic maintenance to clean out non-combustible materials, such as ash; SCR systems require periodic refilling of diesel exhaust fluid; lean NOx catalyst can increase fuel consumption. For example:
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• In a 2006 report, the US EPA used $208 as the net present value of catalyzed diesel particulate filter maintenance costs (installed on class 8b trucks) (US EPA, 2006)15.
• In a report from 2000, $872.73 was used for the annual urea cost for SCR (Brodrick et al., 2000).
• There may be costs associated with implementing and operating such a program, for example, from 2008 to 2010, US EPA awarded $470 million nationwide to retrofit, replace or repower more than 50,000 vehicles and equipment in a variety of industries. In 2008, $49 million was used to fund 119 projects (which retrofitted over 14,000 vehicles including 6,000 school buses and 4,500 long-haul trucks). In 2011, DERA’s reauthorization was signed through 2016 by President Barak Obama, allowing up to $100 million in annual appropriations. Specific examples of funding under the DERA program include the following:
• CALSTART, Inc. was granted over $650,000 to retrofit construction vehicles, delivery trucks and transit buses
• South Coast Air Quality Management District was granted $1 million to retrofit long haul trucks
• Idaho Department of Environmental Quality was granted over $450,000 to retrofit school buses (US EPA, 2012).
• The Carl Moyer Program through the California Air Resources Board has provided $680 million in funding for roughly 24,000 engines. Of these, 4,500 were heavy-duty on-road engines and 1,900 were off-road (Lawson, 2014).
• Cost-effectiveness ($/tonne pollutant reduced) for particular retrofit technologies can vary based on a number of factors, including the age and activity levels of the vehicles/equipment. Examples include (US EPA, 2007):
• School bus DOC $12,000 - $49,100 USD per ton PM reduced (approximately $14,400 - $59,000 CAD per tonne PM reduced)
• Class 8b truck DOC $11,100 - $40,600 USD per ton PM reduced (approximately $13,350 - $48,900 CAD per tonne PM reduced)
• Off-highway trucks DOC $21,700 - $78,800 USD per ton PM reduced (approximately $26,100 - $94,800 CAD per tonne PM reduced)
• Cranes DOC $20,900 - $60,000 USD per ton PM reduced (approximately $25,150 - $72,200 CAD per tonne PM reduced)
• Tractors and loaders upgrade kit $2,600 - $4,900 USD per ton NOx reduced (approximately $3,100 - $5,900 CAD per tonne NOx reduced) (US EPA, 2010)
• Cost-effectiveness ($/tonne pollutant reduced) for a voluntary diesel retrofit program depends on the retrofit technologies used, and the age and activity level of the vehicles/equipment. The US EPA calculated the median program cost to be $5,950 USD per ton NOx reduced (approximately $7,160 CAD per tonne NOx reduced) and the range to be $1,900 - $19,000 USD per ton NOx reduced (approximately $2,300 - $22,900 CAD per tonne NOx reduced) (US EPA, 2007).
15 This is likely if the fleet has its own cleaning equipment. To send it out to be cleaned, can cost anywhere from $300 to $600 depending on the oil buildup and whether or not it needs to be cooked as well as blown out.
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Key Benefits: • The impact of voluntary programs are generally dependent on the type and amount of the
financial incentive as well as the relative cost of ongoing operations and maintenance versus the cost of the retrofit/upgrade/rebuild and possible fuel savings.
• Specific emission reduction benefits vary by technology, vehicle and use. Key Challenges: • Costs of technologies, access to capital and sufficient funding. • Knowledge, skills, and technical capacity, including the ability to write successful grant
applications and manage grant funding. • Application of weight limitations for add-on technologies and retrofit devices can limit the
uptake, even when technically possible. • Limited retrofit technologies available for certain vehicles types (e.g. existing construction
equipment varies greatly in its size, configuration and use, and no one technology will work on more than a subset of the total, therefore there are limited options) (Clean Air Act Advisory Committee, 2006).
• Some retrofits can slightly increase fuel consumption (e.g. DPF), reducing efficiency. • Retrofit technologies to reduce emissions of PM and other CACs do not bring operating cost
reductions, therefore truck owners will not likely participate voluntarily unless the incentives pay the full costs (Lawson, 2014).
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Low to High Off-Road: Low to High
On-Road evaluation of low to high is based on quantitative information available for the following programs/policies, which are on a per vehicle basis: BC Diesel Retrofit Requirement - assume MY 1989-1993 retrofit with DOC (typical reduction of ~20%); CARB SWCV's Rule - assume MY2006 & earlier retrofit to meet 2010 PM Targets; Rhode Island Diesel Emission Reduction Act - assume MY1993 upgraded to MY2007 standards. Off-Road evaluation of low to high is based on quantitative information available for the following programs/policies: New Jersey Clean Construction Ordinance - 85% PM reduction; Rhode Island Diesel Emission Reduction Act - if the entire legacy fleet of construction equipment was retrofitted with DOCs, an overall 20% reduction would occur, and if all were retrofitted with DPFs, an overall 90% reduction would likely occur.
(Lawson, 2014) (SNC Lavalin, 2013) (State of Rhode Island General Assembly, 2010) (State of Rhode Island, 2007) (University of Rhode Island, 2014) (The Port Authority of NY and NJ, 2013)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-Road NOX: Low to Mid Off-Road NOX: Low to Mid On-Road VOC: Mid Off-Road VOC: Mid
Evaluation of NOX reductions is based on current US EPA estimates of NOX reductions of diesel retrofit devices, as documented by the National Clean Diesel Campaign (NCDC) website (http://www.epa.gov/cleandiesel/technologies/retrofits.htm) which indicates the following: SCR - typical NOX emission reduction of up to 75%; EGR - typical NOX emission reduction of 25-40%; Lean NOX Catalyst - typical NOX emission reduction of 5-40%. Evaluation of VOC reductions is based on technical expert opinion (DOCs and DPFs will reduce VOCs by 50-80%).
(US EPA, 2013) (Browning, 2014) (The Port Authority of NY and NJ, 2013)
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
GHG emission reduction potential per vehicle - CO2e
On-Road: Mid Off-Road: unknown
It is not considered likely that a program would aim to reduce GHG emissions via retrofits as popular retrofits, such as DOC and DPF are estimated to increase GHG emissions. It is reported in the Levelton et al. 2005 study that DOC can increase GHG emissions by 1 to 2%, DPF can increase GHG emissions by 2 to 4%. However, it is acknowledged that upgrading to a more efficient engine would have associated GHG benefits. The same study by Levelton estimates that engine replacement can reduce GHG emissions by 10%.
(Levelton Consultants Ltd. et al, 2005) (Browning, 2014)
Policy/Program costs (Total $ and $/year as available)
Limited Info Capital costs would be associated with developing the program. Operating costs may range based on the type of program and outreach. For example, a small on-line based campaign with no incentives would be low cost whereas larger programs with operating partners and incentives would be high cost. Detailed cost information was not identified during the course of this work. The information below is provided as an illustrative sample. The US EPA DERA program originally appropriated funding through Congress in 2008. In 2009, funding received by DERA was $300 million, nationwide. The Carl Moyer Program has provided $680 million in funding for roughly 24,000 engines. Of these, 4,500 were heavy-duty on-road engines and 1,900 were off-road.
(Missouri Department of Natural Resources ) (Lawson, 2014)
Vehicle - Capital Costs ($/vehicle)
Low to High Retrofits/upgrades may include a number of retrofit technologies as well as complete replacements of engines. Engine retrofits are considered to cost from low to medium whereas engine replacements may be much more and are considered high. The following are examples of equipment types and costs that may be retrofitted to reduce PM and other pollutants: DOCs are estimated to cost from $500 to $2000 per vehicle and depend on the engine size, sales volume and installation; high-efficiency, passive DPFs are estimated at $8,000 - $13,000; actively-regenerated, high-efficiency DPF system is estimated at $15,000 to $30,000; low pressure EGR system estimated at $18,000 to $20,000; SCR system expected to range from $18,000 to $30,000. Engine repowering average is $45,000.
(Lawson, 2014)
Vehicle - Operating Costs ($/vehicle)
Savings potential to Low Cost
Operating costs are dependent on the retrofit/upgrade. For example, DOCs require little or no maintenance; DPFs require periodic maintenance to clean out non-combustible materials, such as ash; SCR systems require periodic refilling of diesel exhaust fluid; lean NOX catalyst can increase fuel consumption. Potential operating savings due to reduced fuel consumption for some retrofits. The US EPA used the following net present value of catalyzed diesel particulate filter maintenance costs (installed on class 8b trucks): $208. Brodrick et al. indicate the following annual urea cost for SCR: $872.73.
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy to Moderate
While there are considered to be no regulatory hurdles to overcome with a non-mandatory program, program developers /administrators may require some consultation outside of government to decide what types of retrofits and upgrades to include in program. It is considered that a voluntary retrofit/upgrade program would not be as labour intensive to implement compared to a mandatory retrofit/upgrade program.
Ease of complying
N/A
Ease of proving compliance
N/A
Ability to enforce
N/A
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive The cost-effectiveness ($/tonne pollutant reduced) for a diesel
retrofit program depends on the retrofit technologies used, and the age and activity level of the vehicles/equipment. The US EPA calculated the median program cost to be $5,950 USD per ton NOx reduced (approximately $7,160 CAD per tonne NOx reduced) and the range to be $1,900 - $19,000 USD per ton NOx reduced (approximately $2,300 - $22,900 CAD per tonne NOx reduced) , For illustrative purposes, below are examples of US EPA cost-effectiveness ($/tonne pollutant reduced) estimates for various specific retrofit technologies: School bus DOC approximately $14,400 - $59,000 CAD per tonne PM reduced; Class 8b truck DOC approximately $13,350 - $48,900 CAD per tonne PM reduced; Off-highway trucks DOC approximately $26,100 - $94,800 CAD per tonne PM reduced; Cranes DOC approximately $25,150 - $72,200 CAD per tonne PM reduced; Tractors and loaders upgrade kit approximately $3,100 - $5,900 CAD per tonne NOx reduced.
(Browning, 2014) (US EPA, 2007) (US EPA, 2010)
Co-benefits Yes Black carbon emission reductions expected (with reductions of PM2.5).
Negative impacts
Yes Some technologies that reduce air pollutants may increase GHG emissions due to increased fuel consumption.
(Lance, et al., 2012)
1.2.3. Scrappage programs
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • On-road and off-road higher emitting
diesel vehicles Objective: • To replace older, higher polluting vehicles or equipment with cleaner, more efficient vehicles
that meet stricter emission standards. • For both mandatory and voluntary programs, the vehicles and equipment must be scrapped
and deemed inoperable. Brief Description: • Voluntary early retirement vehicle programs provide incentives to help scrap older, higher
polluting vehicles, based on age. Incentives for on-road heavy-duty diesel vehicles typically include cash payments, rebates or tax incentives (towards the purchase of an eligible replacement vehicle). Mandatory scrappage programs have the same objective, but do not always include incentives.
• Off-road retirement programs provide incentives to scrap higher polluting engines, based on age or emission standards (e.g. uncontrolled, previous Tiers), and to help purchase new or used equipment that meet current emission standards.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs
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Authority Jurisdiction: • Provincial – Develop and implement programs • National – Develop and implement programs Method of Compliance and Enforcement: • It is important for scrappage programs that the old vehicle or engine be destroyed. Generally
proof is given that the engine has been made unusable such as by drilling it with holes. Cost Bearer(s): • Single or shared funder • Public or private sector – Governments develop the programs and provide incentives;
programs may be implemented with the help of nongovernmental organizations, community-based marketing firms and the private sector
On-road examples: • Gateway Cities Diesel Fleet Scrappage Program for Drayage Off-road examples: • California Air Resources Board – Carl Moyer Grant Program • Summerhill Impact and Home Depot Canada – Mow Down Pollution Option Costs: • The US EPA provided $2 million USD in funding for the 2012 school bus replacement
rebate program. With this $2 million, rebates were provided to 28 recipients to replace more than 80 school buses. The rebates ranged in value from $20,000 to $30,000 USD per bus (US EPA, 2012). The US EPA awarded an additional $3 million USD for the 2nd run of the program, starting in the fall of 2014 (US EPA, 2014). For this run, 76 fleet owners in 30 states will receive rebates to replace 210 school buses (US EPA, 2015).
• The average grant award from the Gateway Cities Diesel Fleet Scrappage program was $36,300 toward the purchase of a newer replacement vehicle (PRNewswire, 2007).
• The remaining cost of the replacement truck, paid by the owners/operators was estimated to be $7,000 to $10,000. The program is sponsored by four organization: $14.74 million from the Port of Los Angeles, $2.1444 million from the US EPA, $1 million from CARB and $2.75 million from the Mobile Source Air Pollution Reduction Review Committee (administered through the South Coast Air Quality Management District) (US EPA SmartWay).
Key Benefits: • Encourages early retirement of higher emitting vehicles. • Once the vehicle is scrapped, there are immediate emission reductions and health benefits. Key Challenges: • Uptake rates may depend on availability of financial support. • The biggest challenge is reaching owners/operators. Generally they are operating on the
margin and even with incentives, they are difficult to reach.
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Mid to High Off-Road: Mid
Reductions of PM will depend on the type and model year of vehicles that are being retired as well as the type and model year of the replacement vehicles. Evaluation assumes the following: On-Road: Assumed that a MY 2000 HDDV is replaced with a MY 2007 or newer HDDV and based on the US EPA emission standards for PM. For example, the scrappage and replacement of pre-1987 diesel drayage trucks (which are typically old) with MY 1999 or newer, can result in 90% less PM emitted. Off-Road: Assumed that Tier 1 engines replaced with Tier 2 engines for all power classes and based on the US EPA emission standards for PM.
(US EPA, 2013) (US EPA, 2013) (US EPA SmartWay)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-Road NOx: Mid to High Off-Road NOx: Mid On-Road VOC: Mid Off-Road VOC: Mid
Reductions of NOX will depend on the type and model year of vehicles that are being retired as well as the type and model year of the replacement vehicles. Evaluation assumes the following: On-Road: Assumed that a MY 2000 HDDV is replaced with a MY 2007 or newer HDDV and based on the US EPA emission standards for NOx, as per the US EPA. For example, the scrappage and replacement of pre-1987 diesel drayage trucks (which are typically old) with MY 1999 or newer, can result in 50% less NOx emitted. Off-Road: The emission standards for NOX are included with NMHC for most rated power classes of CI Engines and therefore more work would be required to assess the reductions of NOX alone. On-Road/Off-Road VOCs: Evaluation is based on technical expert opinion as there are no emission standards for VOCs specifically.
(Browning, 2014) (US EPA, 2013) (US EPA SmartWay)
GHG emission reduction potential per vehicle - CO2e
On-Road: Mid Off-Road: Mid
Reductions of GHGs will depend on the type and model year of vehicles that are being retired as well as the type and model year of the replacement vehicles. Newer vehicles and equipment provide better fuel economy, especially newer vehicles meeting GHG regulations.
(Browning, 2014)
Policy/Program costs (Total $ and $/year as available)
Limited Info Capital costs would be associated with developing the program. Costs would depend on how much money is provided per vehicle scrapped and how many vehicles are scrapped via the program, as well as staff required to run the program. Alternatively, the program can be designed with a fixed operating budget and the number of vehicles capped based on this operating budget. Detailed cost information was not identified during the course of this work. The information below is provided as an illustrative sample. The US EPA provided $2 million USD in funding for the 2012 school bus replacement rebate program. With this $2 million, rebates were provided to 28 recipients to replace more than 80 school buses. The rebates ranged in value from $20,000 to $30,000 USD per bus. The US EPA anticipated awarding $3 million USD for the 2nd run of the program, starting in the fall of 2014.
(US EPA, 2014) (Province of BC)
Vehicle - Capital Costs ($/vehicle)
No cost Owners/operators would not have any up-front costs on the on-set of the program.
Vehicle - Operating Costs ($/vehicle)
No cost; savings potential
Owners/operators would not incur any annual costs; savings potential if vehicle is upgraded to more efficient model.
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy to Moderate While there is considered to be no regulatory hurdles to overcome with a non-mandatory program, program developers/administrators may require some consultation outside of government to decide what types of incentives to include in program and develop partnerships for program delivery.
Ease of complying
N/A
Ease of proving compliance
N/A
Ability to enforce N/A
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Limited information identified during the course of this work. No relevant
cost-benefit analysis identified. A number of benefits would need to be accounted for, including improved health and safety, reduced productivity losses due to congestion and reduced emissions from reduced non-recurrent congestion. Generally replacing older equipment with newer lower emission vehicles and equipment provides a substantial benefit in terms of CACs and GHGs.
(Browning, 2014)
Co-benefits Yes Possible benefits beyond emission reductions include improved health and safety and reduced productivity losses due to congestion. Black carbon emission reductions expected (with reductions of PM2.5).
(Washington, 1993)
Negative impacts No None identified
1.3. Operations and Management Programs and Practices
1.3.1. Inspection and maintenance programs
PROFILE Applicable to: • On-road heavy duty diesel vehicles16
Target Vehicles: • All on-road diesel vehicles
Objective: • To reduce air pollutant emissions by optimizing vehicle operations through regular
inspection and timely and preventative vehicle maintenance. Brief Description: • Inspection and repair programs include road side tests of HDDVs for excessive smoke
emissions, and mandatory emissions semi-annual or annual inspections, for certain vehicle classes and model years. Inspection and maintenance programs, though mostly mandatory, may also be voluntary in nature. Many inspection programs require follow-up repairs for issues identified during the tests.
• Preventative maintenance programs are essential for optimizing vehicle performance. Intervals for preventative maintenance depend on a number of factors, such as the type of vehicle, annual mileage, type of equipment, etc. At minimum, manufacturer’s specifications for maintenance should be followed. Maintenance programs are generally voluntary, applied to corporate fleets and at the discretion of the fleet manager.
• Specific maintenance programs are also used to improve fuel efficiency, such as regular tire pressure checks and use of nitrogen tire inflation systems, which also extend tire life.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO
• Greenhouse gases • GHGs
16 This does not necessarily mean that I/M programs could not be applicable to off-road vehicles and engines; however, off-road vehicles and engines are not listed, as there were none identified during the course of this study.
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Authority Jurisdiction: • Municipal – Develop and implement programs; enforcement as applicable • Provincial/Territorial – Develop and implement programs; enforcement as applicable Method of Compliance and Enforcement: • Spot-checks, inspections, registration, self-reporting • Refusal of registration, licence suspension Cost Bearer(s): • Single funder or shared • Public or private sector – Provincial/territorial and municipal governments develop,
implement and enforce the programs; Owners/operators may pay for the program often on a cost-recovery basis through inspection fees
On-road examples: • British Columbia Ministry of Transportation and Infrastructure – AirCare On-Road Program
(ACOR) • Ontario, Ministry of the Environment and Climate Change – Drive Clean Program • B.C Transit – Nitrogen Tire Inflation • Newfoundland and Labrador – Highway Traffic Act, Inspection Requirements • Prince Edward Island – Motor Vehicle Inspection Regulations • Québec, Ministry of Sustainable development, Environment and the Fight against climate
change – PIEVAL Program Option Costs: • There may be initial costs to owners/operators as initial emissions tests may be required.
Under the Ontario Drive Clean Program, each facility sets its own fees for a heavy-duty test. There is currently no inspection fee for ACOR. It is administered at weigh scales and other pull over spots by a mobile unit. The costs come in fines or repairs resulting from the inspection17.
• Vehicle owner/operators may have to undergo annual (or regular) testing and may require repairs to the vehicle. Under the Ontario Drive Clean Program, each facility sets its own fees for a heavy-duty test and there is no limit on repair costs for heavy duty vehicles (Province of Ontario, 2014). Required repairs under the BC ACOR program were estimated to be $870/repair (G.W. Taylor Consulting, et al., 2002).
• The BC AirCare inspection and maintenance (I/M) program is completely self-funded through test fees that are paid by the vehicle owners. From financial statements, it appears the rough annual operating costs are in the order of $20 million. These numbers are based on balance sheets provided in the AirCare program review report prepared for the Greater Vancouver Transportation Authority (Sierra Research Group, 2005). Correspondence with BC AirCare authorities indicated an annual operating cost of approximately $18M (this includes capital cost repayment) (Gourley). It should be noted that these figures represent the entire program, and do not reflect the cost of administering the portion of the program
17 Correspondence with BC Ministry of Environment, June 2015.
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attributed to heavy-duty vehicles only. In the year 2000, the government costs of operating ACOR were $432,000 (G.W. Taylor Consulting, et al., 2002).
• The US EPA calculated the program costs of a number of mobile source programs. Examples include (US EPA, 2007):
• Median inspection and maintenance program cost-effectiveness $2,200 USD per ton NOx and VOCs (4:1 weighting) reduced (approximately $2,650 CAD per tonne) and the range to be $2,100 - $6,800 USD per ton reduced (approximately $2,500 - $8,200 CAD per tonne).
• There is no initial inspection fee for Québec’s PIEVAL, and the on-road inspections are done by Contrôle Routier Québec. A fine of $200-400 is issued to the owner if proven guilty, and compliance is required within 30 days of receiving a repair notice from the Minister and is , validated in an accredited facility.
Key Benefits: • Inspections and follow-up repairs generally result in reduced emissions of air pollutants and
limited improved fuel consumption. GHG emission reductions are typically small compared to potential air pollutant emission reductions.
• Costs are borne by highest polluters, and programs can be directed at specific fleets based on vehicle type or age.
Key Challenges: • There are initial costs to establish and run I/M programs; however, they are typically
designed to be revenue neutral. • Negative public perception (for program, fees, preparation for tests). For example, negative
comments were received from professionals and members of the general public on the BC ACOR program. This showed the administrators of the program that more information on the program and the performance of the program would be necessary going forward (G.W. Taylor Consulting, et al., 2002).
• Using cost limits for repairs can mean that many vehicles are not fully repaired, meaning that even with the program, they may continue to run without meeting the emission limits. However, higher cost thresholds may be prohibitive for a sector of the population and trying to maximize costs to annual household incomes may pose challenging administrative burdens.
EVALUATION NOTES
Inspection and maintenance programs Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Low to Mid
Evaluation is based on emission reduction potential as documented by United Nations Environment Programme on proper inspection and maintenance of vehicles. It also notes that actual reductions depend on the fleet’s original condition. Canadian examples of emission reductions from I/M programs were not readily available for PM2.5 specifically. Ontario Drive Clean and BC AirCare test heavy duty vehicles for opacity however no estimates of PM2.5 reductions are provided. It is acknowledged however that opacity and diesel particulate are correlated and that emissions reductions of PM2.5 may be higher than 25% (resulting in the potential for a Mid evaluation).
(United Nations Environment Programme, 2009) (Province of British Columbia, 2014) (G.W. Taylor Consulting, et al., 2002) (Envirotest Canada, 2013)
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Inspection and maintenance programs Criteria Eval. Notes References
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-Road NOx: Low On-Road VOCs: Low
Evaluation is based on information from the United Nations toolkit, which also notes that actual reductions depend on the fleet’s original condition.
(United Nations Environment Programme, 2009)
GHG emission reduction potential per vehicle - CO2e
On-Road: Low to Mid
Evaluation is based on information from the United Nations toolkit, which also notes that actual reductions depend on the fleet’s original condition.
(United Nations Environment Programme, 2009)
Policy/Program costs (Total $ and $/year as available)
Limited Info High capital costs associated with developing I/M test facilities, tests, etc. Canadian examples of I/M programs are designed to be revenue neutral (no cost). Detailed cost information was not identified during the course of this work. The information below is provided as an illustrative sample. The annual operating costs for BC ACOR recovered from test fees was in the $45-47 million range.
(Sierra Research Group, 2005) (Gourley) (AirCare Review Committee, July 2010)
Vehicle - Capital Costs ($/vehicle)
Low Initial emissions test may be required. Under the Ontario Drive Clean Program, each facility sets its own fees for a Heavy-Duty test. There is no inspection fee for the BC AirCare On-road program.
(Province of Ontario, 2014)
Vehicle - Operating Costs ($/vehicle)
Low to Medium Vehicle owner/operators may have to undergo annual (or regular) testing and may require repairs to the vehicle. Under the Ontario Drive Clean Program, each facility sets its own fees for a heavy-duty test and there is no limit on repair costs for heavy duty vehicles. Required repairs under the BC ACOR program were estimated to be $870/repair.
(Province of Ontario, 2014) (Province of British Columbia, 2014) (G.W. Taylor Consulting, et al., 2002)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Moderate It is presumed that the same level of government is required for all input with respect to implementation (e.g. license plate info, registration data, etc.).
Ease of complying Moderate Compliance is considered moderate as owners/operators obtain certificates; could also be subject to spot checks.
Ease of proving compliance
Moderate Proving compliance under an I/M program is considered moderate as the owner/operators are required to demonstrate compliance by having their vehicle tested via a dedicated testing method/facility and do so during the operation of their vehicle.
Ability to enforce Easy Ability to enforce is considered easy as proof of compliance may be required for license plate renewal. Under the Ontario Drive Clean Program, pass is required for heavy-duty vehicles to renew registration or transfer ownership.
(Province of Ontario, 2014)
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive I&M catches high emitters. A few high emitters can significantly
affect fleet emissions. (Browning, 2014)
Co-benefits Yes I/M programs may result in maintenance savings for vehicle owners/operators as it may result in early detection of system failures. Black carbon emission reductions expected (with reductions of PM2.5).
Negative impacts No I/M programs are not expected to result in unintended negative impacts however it should be noted that there is anecdotal evidence to suggest that there exists negative public perception surrounding I/M programs. For example, there have been a number of news articles and campaigns that would indicate the Ontario Drive Clean program no longer serves the purpose of reducing emissions and is unnecessary. It is assumed that the prevalence of these articles and campaigns is a good indicator of the public's perception of the program.
(Mills, 2013) (Grundy, 2014) (Wolstat, 2013)
1.3.2. Purchasing and right-sizing policies
PROFILE
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Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • Diesel fleet vehicles
Objective: • To reduce emissions of corporate fleets by ensuring that fleet vehicles are adequately and
efficiently supporting operations. Brief Description: • Purchasing decisions are based in part on environmental impact analyses to reduce operating
costs and GHG emissions and often consider life cycle impacts and fuel efficiency standards. • Consideration is given to the purchase and use of appropriate vehicles that will perform the
task efficiently, using the least amount of fuel and emitting the least amount of emissions. In other words, engine sizes and vehicle weights are optimized for specific tasks.
• “Right-sizing” studies are generally performed before purchasing decisions to determine if the fleet vehicles are adequately supporting operations, considering fleet mix and size (to determine if any fleet vehicles are being underused and therefore are ultimately not required).
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO
• Greenhouse gases • GHGs Authority Jurisdiction: • Municipal – Develop and implement programs; internal enforcement as applicable • Provincial/Territorial – Develop and implement programs; internal enforcement as applicable • National – Develop and implement programs; internal enforcement as applicable Method of Compliance and Enforcement: • Purchasing approvals Cost Bearer(s): • Single funder • Public sector – Governments develop, implement and enforce (internally) the programs as
necessary On-road examples: • Brampton – Fleet Right-Sizing Review Program • Metro Vancouver – Sustainable Procurement Policy • Toronto – Green Fleet Transition Plan • Manitoba – The Climate Change and Emissions Reductions Act Off-road examples: • Government of Canada – Green Procurement • Florida – Climate Friendly Public Business Statute • North Carolina – Fuel-Efficient Vehicle Acquisition Requirements
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Option Costs: • Varies from minimal costs (e.g. retiring old or underused vehicles) to high capital costs (e.g.
purchasing new vehicles). • The US EPA calculated the program costs of a number of mobile source programs. Examples
include (US EPA, 2007): • Median conventional fuel bus replacement program cost-effectiveness $18,800 USD
per ton NOx and VOC (4:1 weighting) reduced (approximately $22,600 CAD per tonne) and the range to be $12,900 - $46,700 USD per ton reduced (approximately $15,500 - $56,200 CAD per tonne).
Key Benefits: • Overall impacts of programs are dependent on uptake, but can be significant for individual
fleets. • Specific emission reduction benefits vary by technology, vehicle and use. • Fuel savings are achieved when appropriate vehicles are used. Savings depend on type of
vehicle, fuel, distance travelled, type of service, etc. Key Challenges: • Costs can be high, depending on how right-sizing policies are implemented. • For example, by retiring old vehicles early, continued operating & maintenance costs are
immediately saved. Reallocating vehicles to different tasks requires minimal capital costs and therefore higher savings. However, vehicle replacement to more fuel efficient vehicles or better suited vehicles requires high capital costs and therefore lower overall savings and longer payback.
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EVALUATION NOTES
Purchasing and right-sizing policies Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Low to High Off-Road: Low to High
By setting purchasing policies to buy low emission vehicles and equipment, fleet emissions can be reduced. Actual emission reductions on a per vehicle basis would depend on the difference between the baseline and replacement vehicles. For example, if a fleet is downsized as a result of right-sizing, then there would be a 100% (high) reduction of emissions from the vehicles that are no longer on the road and were not replaced. As another example, if as a result of purchasing policies, a B20 blend was supplied for all on-lot fill-ups, the emission reductions would be approximately10% (low) per vehicle.
(Browning, 2014) (US Department of Energy, 2015)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-Road NOx: Low to High Off-Road NOx: Low to High On-Road VOCs: Low to High Off-Road VOCs: Low to High
By setting purchasing policies to buy low emission vehicles and equipment, fleet emissions can be reduced. Actual emission reductions on a per vehicle basis would depend on the difference between the baseline and replacement vehicles. For example, if a fleet is downsized as a result of right-sizing, then there would be a 100% (high) reduction of emissions from the vehicles that are no longer on the road and were not replaced. As another example, if a purchasing policy leads to the purchase of a Tier 1, 2, or 3 certified off-road diesel engines on rubber-tired gantry cranes with an Energy Storage System, then NOx emissions will be reduced by 30% (mid) assuming that a conventional diesel gantry crane would have otherwise been purchased.
(Browning, 2014) (University of Rhode Island, 2014) (CARB, 2014)
GHG emission reduction potential per vehicle - CO2e
On-Road: Low to Mid Off-Road: Low to Mid
Purchasing more efficient vehicles/equipment can reduce GHG emissions. Actual emission reductions on a per vehicle basis would depend on the difference between the baseline and replacement vehicles.
(Browning, 2014) (US Department of Energy , 2013)
Policy/Program costs (Total $ and $/year as available)
Limited Info Implementation: Costs are typically associated with human resources to develop and implement the policies and associated information. This is considered to be very low, though detailed cost information was not identified during the course of this work for evidence of this assumption. Operating: It is assumed that there would be low cost to operate the policy; costs may include staff to review fleet characteristics, conduct cost-benefit analysis of new purchases, research new technologies, etc. Detailed cost information was not identified during the course of this work as evidence for this assumption.
Vehicle - Capital Costs ($/vehicle)
Low to High Resources may be required to review the characteristics of the owner/operators current vehicle/engine stock. Even if external resources are used, costs are considered to be low. For example, to have E3 fleet carry out a fleet review, they charge from $2,200 to $9,200 depending on fleet size. With respect to the vehicles themselves, costs would be low if no changes were required as a result of the policy; or costs may be high if vehicles/engines need to be retrofit with new engines or other upgrades. As an example, the City of Brampton's Green Fleet Program included a right sizing study, sustainable replacement, exploring new technologies and alternative fuels, etc. From 2006 to 2009, they replaced 58% of their aging fleet (total vehicles and equipment = 845, including light duty) for over $17.7 million (therefore averaging approximately $42,000 per vehicle) (medium).
(E3 Fleet) (ICF International, 2009) (The Corporation of the City of Brampton, 2010)
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Purchasing and right-sizing policies Criteria Eval. Notes References
Vehicle - Operating Costs ($/vehicle)
No Cost; Savings
Policies should be reviewed on a regular basis. Operational costs would be associated with performing the review (as described in capital costs). With respect to operating the vehicles, it is assumed that there would be no cost to owners/operators. Savings could be realized in the form of reduced maintenance and fuel costs. As an example, the City of Brampton's Green Fleet Program which increased capital spending between 2006 to 2009 (as described above), experienced a reduction in maintenance costs of approximately $600,000 during these same years.
(ICF International, 2009) (The Corporation of the City of Brampton, 2010)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy to Moderate
While there is considered to be few regulatory hurdles to overcome (if any) with respect to developing a purchasing and right-sizing policy, developers/ administrators may require some consultation outside of government. Additionally, technical expertise and staff are required to carry out analysis on current fleets and assess what vehicles and equipment are suitable for what jobs. This is therefore considered easy (if expertise required exists within the organization) to moderate (if external expertise is required).
Ease of complying N/A Carrying out purchasing and right sizing studies is typically voluntary in nature. If however, a fleet manager is mandated to do so, a certain amount of training and technological expertise is required to carry out a successful study.
Ease of proving compliance
N/A See above
Ability to enforce N/A See above ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Neutral Minimal costs to develop policies, but benefits generally come
at a higher cost when acting on the policies (e.g. higher emission reduction return on higher cost equipment/vehicles).
(Browning, 2014)
Co-benefits Yes Reduced capital investment in the fleet in addition to emissions savings. Black carbon emission reductions expected (with reductions of PM2.5).
(Province of BC, 2015)
Negative impacts No None identified
2. Fuels
2.1. Regulations, Standards and Restrictions
2.1.1. Fuel standards
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • All diesel vehicles
Objective: • To reduce emissions from on-road vehicles and off-road diesel vehicles and engines by
establishing standards to control the quality of fuel used that affect emissions.
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Brief Description: • Regulations that include provisions to control the quality of fuels for maximums, minimums
or a range of fuel characteristics, and also allow for a performance‐based approach to fuel standards.
• Regulations that require renewable fuel content (such as biodiesel) in diesel fuel18. • In addition, federal regulations require the use of ultra-low sulphur diesel fuel (15 ppm
sulphur) in both on-road vehicles and off-road engines, which has resulted in emission reductions. While further sulphur reductions, below 15 ppm, would be possible, the gains in emission reductions would be small. It is possible to use diesel fuels with less aromatics to get a small NOx benefit, or add biodiesel to conventional diesel to reduce GHGs (Browning, 2014).
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs (particularly CO2, N2O, and CH4) Authority Jurisdiction: • Provincial/Territorial – Develop regulations; enforcement • National – Develop regulations; enforcement Method of Compliance and Enforcement: • Annual reporting, licensing • Penalties, fines Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop, implement and enforce the regulations;
Owners/operators pay the fines On-road examples: • B.C Ministry of Environment – Renewable and Low Carbon Fuel Requirements Regulation • Manitoba Ministry of Environment – Biofuels Act • Saskatchewan Ministry of the Economy – Renewable Diesel Program • Ontario – Greener Diesel Regulation • Minnesota Department of Agriculture – Biodiesel Blend Mandate • Environment Canada – Sulphur in Diesel Fuel Regulations; Renewable Fuels Regulations • US Environmental Protection Agency (EPA) – Ultra-low Sulphur Diesel (ULSD)
Regulations; Renewable Fuel Standard Off-road examples: • Minnesota – Biodiesel Blend Mandate • Ontario – Greener Diesel Regulation • Alberta – Renewable Fuels Standard
18 Blends are possible up to 100%, but don’t require engine modifications under 20%.
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• Environment Canada – Sulphur in Diesel Fuel Regulations; Renewable Fuels Regulations Option Costs: • Regulation development and administration costs depend on the regulation. • Some regulations will produce revenue as well. For example, the BC Ministry of
Environment, Renewable and Low Carbon Fuel Requirements Regulation includes a penalty whereby a supplier must pay the government if it falls short of the required biofuel volume production ($0.45/litre for diesel class fuel).
• No additional costs involved on the vehicle capital cost. This is because B5 blends can be used with existing diesel engines and some manufacturers include blends up to 20% in their warranty coverage. Hydrogenation-derived renewable diesel (HDRD) is a drop-in fuel, and can therefore be used in any blend level without engine issues.
• The incremental costs associated with low biodiesel or HDRD blends (5% or less) would not be significant, particularly on a per vehicle basis. It would result in an amount likely to be unnoticeable in comparison with the usual day-to-day price fluctuations of diesel fuel.
Key Benefits: • Regulations on fuel have a wide-reaching impact, across all diesel vehicles and engines,
immediately upon implementation of the regulation and availability of the fuel. However, it should be noted that there is significant lead time required for refinery infrastructure changes and modifications to fuel production processes.
• Regulations that require renewable fuel content (such as biodiesel) support the Canadian biodiesel industry and feedstock producers.
(Williams, 2011). • One challenge associated with mandating higher percentages of biodiesel is the potential
effect on engines and equipment. Lower quality biodiesel or biodiesel that has become oxidized can lead to deposits and clogging, such as on the injectors, in the injector pump, or of the filter (Ciolkosz, 2013). Some diesel engine warranties are voided by biodiesel mixtures over 5% biodiesel content (B5).
• Possible difficulties with renewable fuel content mandates include potential problems with adequate biodiesel supply (including sustainable sourcing), biodiesel costs, and a requirement to import biodiesel long distances (thereby generating GHGs and pollutants due to the transportation of the fuel) if insufficient biodiesel is produced locally. For example, HDRD is all currently imported.
• The cost to subsidize development of the technology and domestic industry is a challenge, since most environmentally beneficial pathways are still being developed, especially domestically.
• Low level biofuel blending is likely to have only minor impacts on air quality and (life cycle) emission reductions of biodiesel also depend on the biodiesel source and feedstock. With respect to tailpipe emissions, NOx emissions can increase (Andersson, 2011). However, with modern diesel engines (e.g. with DPF and DOC), the impact of biodiesel on NOx emissions is difficult to define. Furthermore, the impact on total hydrocarbons, CO and PM is also greatly reduced with DPF equipped engines (Williams, 2011).
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• There are other potential environmental and social costs of producing biofuels. For example, land use change, habitat impacts, water use, agricultural pesticides, etc. are all examples of potential environmental impacts.
• In addition, the full life cycle cost of biofuels is complex to verify, with respect to sustainability and GHG emission reductions.
• There may also be performance issues in cold weather (<5ºC), depending on the type of biodiesel (feedstock) and blend level (B2 or B5 are not typically impacted by cold weather). Additives can be used to improve the winter performance of higher blends of biodiesel (Nowatzki et al., 2012).
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EVALUATION NOTES
Fuel standards Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-Road: Low Off-Road: Low
Evaluation is based on technical expert opinion and the findings of the US EPA of exhaust emissions impacts, on a per vehicle basis of B20 for soybean-based biodiesel added to an average base fuel. It should be noted that the investigation concluded that emissions impacts varied depending on the type of biodiesel (soybean, rapeseed, or animal fats) and on the type of conventional diesel it is blended with. It is noted that biodiesel blends are currently used at a B5 level or less in Canada and that there is insignificant difference in PM emissions between B0 and B5 (at current usage levels in Canada) with modern diesel technologies. All notes on emissions with respect to biodiesel blends are in the context of current data in Canada. This may not reflect potential impacts of expanded renewable fuel mandates for diesel in the future. Currently in Canada, there is a relatively high use of hydrogenation-derived renewable diesel (HDRD) and HDRD is being tested by Environment Canada's Emission Research and Measurement Section for emission levels of conventional pollutants. Field trials conducted by HDRD manufacturing company, Neste Oil indicate that 100% HDRD can reduce fine particulates by 33% when compared to conventional sulphur-free diesel however this was not considered in the evaluation of PM impacts.
Evaluation of NOx reductions is based on the findings of the US EPA of exhaust emissions impacts, on a per vehicle basis of B20 for soybean-based biodiesel added to an average base fuel. NOx emissions were found to increase by approximately 2%. It should be noted that the investigation concluded that emissions impacts varied depending on the type of biodiesel (soybean, rapeseed, or animal fats) and on the type of conventional diesel it is blended with. Evaluation of VOC reductions is based on technical expert opinion. It is noted that biodiesel blends are currently used at a B5 level or less in Canada and that there is insignificant difference in NOx and VOC emissions between B0 and B5 with modern diesel technologies. Currently in Canada, there is a relatively high use of HDRD and it is being tested by Environment Canada's Emission Research and Measurement Section for emission levels of conventional pollutants. Field trials conducted by Neste Oil indicate that 100% HDRD can reduce NOx by 9% when compared to conventional sulphur-free diesel however this was not considered in the evaluation of NOx impacts.
GHG emission reduction potential per vehicle - CO2e
On-Road: None Off-Road: None
Evaluation is based on the findings of the US EPA study A Comprehensive Analysis of Biodiesel Impacts on Exhaust Emissions Draft Technical Report, which states that an unambiguous difference in exhaust CO2 emissions between biodiesel and conventional diesel was not identified. CO2 benefits attributed to biodiesel are a result of the renewability of the biodiesel itself, not exhaust CO2 emissions.
(US EPA, 2002) (Browning, 2014)
Policy/Program costs (Total $ and $/year as available)
Limited Info Capital costs would be associated with developing the regulations. Fuel costs are generally higher. Operating costs would include on-going fuel inspections, reviews, etc. to ensure regulated parties are in compliance. May require additional staff, analytical capabilities, etc. Detailed cost information was not identified during the course of this work.
(Canada Gazette, Part II, July 20, 2011 )
Vehicle - Capital Costs ($/vehicle)
No Cost It is assumed that there would be no capital costs for owner/ operators however it should be noted that there are costs to industry.
(Canada Gazette, Part II, July 20, 2011 )
19 As noted in the profile, NOx emissions can also increase.
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Fuel standards Criteria Eval. Notes References
Vehicle - Operating Costs ($/vehicle)
Low The evaluation assumes that operating costs to owners/operators using biodiesel blends are low on a per vehicle basis. The Environment Canada Regulatory Impact Analysis Statement of the Renewable Fuels Regulations (2011 Amendments) indicates the that the present value costs associated with the Amendments concerning biodiesel are the following: Incremental costs to consumers: $201.7 million, which results from increased fuel consumption due to the lower energy content of kerosene used in biodiesel blends. Considering this, renewable fuel experts acknowledge that the incremental costs associated with low biodiesel or HDRD blends (5% or less) would not be significant, particularly on a per vehicle basis. It would result in an amount likely to be unnoticeable in comparison with the usual day-to-day price fluctuations of diesel fuel.
(Canada Gazette, Part II, July 20, 2011 ) (Renewable Fuels Expert, 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Difficult Many regulatory hurdles must be overcome to implement fuel regulations and a number of stakeholders must be consulted including industry. Many technical inputs required as well.
Ease of complying
N/A N/A for vehicle operators/owners. Regulated parties are responsible for ensuring fuels meet regulations.
Ease of proving compliance
N/A N/A for vehicle operators/owners. Regulated parties are responsible for ensuring fuels meet regulations. They are frequently required to submit reports to the regulating party and have third party audits.
Ability to enforce N/A N/A for vehicle operators/owners. Typically, reports submitted by regulated parties and third party audits are verified and fuel sampling is sometimes performed.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Negative The Environment Canada Regulatory Impact Analysis Statement
(RIAS) of the Renewable Fuels Regulations (2011 Amendment) indicates the estimated present costs of the Amendments is $12.8 billion and the estimated present value of the benefits is $10.4 billion.
(Canada Gazette, Part II, July 20, 2011 )
Co-benefits Yes Other benefits may be realized in the renewable fuel sector including increase in employment and other economic activities in the sector. According to expert opinion, black carbon emission reductions expected (with reductions of PM2.5).
(Canada Gazette, Part II, July 20, 2011 )
Negative impacts Yes Unintended negative impacts are likely to include increased fuel costs to consumers.
(Canada Gazette, Part II, July 20, 2011 )
2.2. Fuel-related Programs and Practices
2.2.1. Alternative fuels rules
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • Specific vehicles targeted by the programs
Objective: • To increase the use of alternative fuels in government fleet vehicles in order to reduce
emissions20.
20 Programs that encourage the use of alternative fuels through financial incentives, such as tax exemptions on alternative fuels and loans and rebates for vehicle retrofits or upgrades were not included here.
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Brief Description: • Common programs to encourage the use of alternative fuels are implemented at the
government level either for individual fleet vehicles (e.g. all waste removal vehicles or all transit vehicles) or across the entire government fleet.
• Fuel options vary by fleet and location. Examples include biodiesel (blends from B5 to B20), hybrid biodiesel-electric, compressed natural gas, liquefied natural gas, propane, grid-based electricity, and hydrogen.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs Method of Compliance and Enforcement: • Purchasing approvals Cost Bearer(s): • Single funder or shared • Public or private sector – Provincial/territorial and municipal governments develop the
programs On-road examples: • City of Brampton – Ultra-Low Sulphur Diesel (ULSD) Biodiesel policy • City of Hamilton – Natural gas-powered transit buses • Québec, Société de transport de Montréal – Drive Electric Program • Region of Peel – Propane para-transport vehicles • Halifax Regional Municipality – Biodiesel policy Off-road examples: • Missouri – Biodiesel Use Requirements • Brampton – Biodiesel Purchasing Policy • California – Sustainable Freight Transport Initiative • Indiana – Biofuels Blend Use Requirement Option Costs: • Cost increases (incremental costs) for some fuels (e.g. biodiesel compared to diesel). • Costs of developing the infrastructure for alternative fuels. • The US EPA calculated the program costs of a number of mobile source programs. Examples
include (US EPA, 2007): • Median alternative fuel non-transit vehicles program (electric, compressed natural gas
(CNG), liquefied petroleum gas (LPG) vehicles and fueling facilities) cost-effectiveness $20,800 USD per ton NOx and VOC (4:1 weighting) reduced
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(approximately $25,000 CAD per tonne) and the range to be $4,700 - $37,000 USD per ton reduced (approximately $5,650- $44,500 CAD per tonne)
• Median alternative fuel transit vehicles and facilities program (mostly CNG) cost-effectiveness $148,000 USD per ton NOx and VOC (4:1 weighting) reduced (approximately $178,100 CAD per tonne) and the range to be $7,800 - $665,800 USD per ton reduced (approximately $9,400- $801,300 CAD per tonne).
Key Benefits: • Specific emission reduction benefits vary by technology, fuel, vehicle and use. • Cost savings for some fuel (e.g. CNG compared to diesel). Key Challenges: • Increased cost of vehicles (over diesel vehicles) (which impacts payback period) • Availability of fuels and requirements for new infrastructure to supply the fuels • Reliability of fuels, particularly in colder climates • Understanding of performance in comparison to diesel fuel. EVALUATION NOTES
Alternative fuels rules Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-road: Low to High Off-road: Low to High
Emission reductions per vehicle depend on the age of the vehicle, type of fuel and if the fuel is pure or blended. For example, with respect to biodiesel for engines manufactured before 2010, emission reductions increase with an increasing amount of biodiesel blended into diesel fuel. Reductions of PM based on a B20 biodiesel blend, compared to diesel, are 10%. Note that in Canada, biodiesel blends are currently at the B5 level or less. And therefore emission reductions are considered low. Furthermore, engines built in 2010 and later, with modern diesel engine and after-treatment technologies, emissions from diesel fuel are comparable to those from biodiesel. On the other hand, compared to diesel vehicles, LPG vehicles almost eliminate PM emissions (high reduction).
(US Department of Energy, 2015) (Federation of Canadian Municipalities, 2010) (Renewable Fuels Expert, 2014)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-road and Off-road: NOx Low to Mid On-road and Off-road: VOCs Mid
Emission reductions per vehicle depend on the age of the vehicle, type of fuel and if the fuel is pure or blended. For example, several studies have found that use of B20 biodiesel can increase NOx emissions around 2%. However, for modern diesel engines, it is difficult to find a significant difference for NOx or VOC emissions using a B5 blend compared to a regular diesel engine. Emission reductions for biodiesel are considered low. On the other hand, compared to diesel, LPG vehicles reduce NOx emissions by about 60%. Reductions of VOCs from CNG vehicles compared to heavy duty diesel vehicles have been shown to be approximately 39%. These are considered mid reductions.
(US Department of Energy, 2014) (Federation of Canadian Municipalities, 2010) (Renewable Fuels Expert, 2014)
GHG emission reduction potential per vehicle - CO2e
On-road and Off-road: Mid to High
Emission reduction benefits per vehicle for GHGs result from life cycle impacts, rather than tailpipe reductions. CO2 released from combustion of biodiesel is offset by CO2 sequestered by the growing of the feedstock. For example, life cycle emission reductions of CO2 based on pure biodiesel compared to diesel are 75% (high). Reductions of CO2 based on a B20 biodiesel blend, are about 15% (mid). As an example of another fuel, compared to diesel, an LPG forklift can reduce life cycle CO2 emissions by about 8% (mid).
(US Department of Energy, 2015) (Energetics Incorporated, 2009)
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Alternative fuels rules Criteria Eval. Notes References
Policy/Program costs (Total $ and $/year as available)
Limited Info Costs of creating a policy or requirement would involve staff time for research and drafting of the policy. Potentially external consultation would be required, depending on the complexity. Costs are likely to be very low, though detailed cost information was not identified during the course of this work as evidence for this assumption.
Vehicle - Capital Costs ($/vehicle)
No Cost to High
Capital costs depend on the type of alternative fuel and whether or not the fuel can be used in a regular diesel engine, or if the engine needs to be retrofit, or if an entire vehicle needs to be replaced. For example, biodiesel blends can be used in any diesel engine and therefore there is no associated capital cost in switching to a biodiesel blend. On the other hand, purchasing a diesel-electric hybrid transit bus would cost approximately $175,000 (high) more than a conventional diesel transit bus.
(Federation of Canadian Municipalities, 2010)
Vehicle - Operating Costs ($/vehicle)
Savings to Low
Operational costs or savings depend on a number of factors, such as the type of alternative fuel/vehicle, vehicle kilometres travelled, vehicle cost, fuel cost, fuel availability, maintenance costs, location, etc. For example, an analysis carried out for a pilot project in Halifax determined that the additional cost of using biodiesel was approximately two-tenths of a cent per litre (low). Generally speaking though, the costs between a biodiesel blend and conventional diesel are not significant and would likely be unnoticeable (no cost). On the other hand, in 2014, the average price for CNG in Ontario was 81 cents per litre, whereas for diesel the average price was 131.4 cents (savings). It is important to note that maintenance costs may increase with different types of alternative fuel vehicles.
(Federation of Canadian Municipalities, 2010) (Ontario Ministry of Energy, 2014) (TransLink, 2006) (Renewable Fuels Expert, 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Difficult This is considered difficult to implement, as it involves many different stakeholders, from the rule makers to the OEM to the owners/operators to the producers and suppliers of alternative fuels and associated infrastructure.
Ease of complying
Moderate to Difficult
For programs that encourage the use of alternative fuels that can be used in existing vehicles, such as biodiesel blends, the operator would be able to comply during the operation of the vehicle (by filling up with the fuel blend), as long as the alternative fuel is available. This is considered moderate. For alternative fuels that require retrofits, upgrades or completely new vehicles, it is more difficult for owners/operators to comply as they must invest prior to operating the vehicle.
Ease of proving compliance
Moderate If the operator can and does use the alternative fuel, then they would be considered to be in compliance.
Ability to enforce
Easy As many of the programs are directed at municipal fleets, it is easy to enforce compliance by 1) providing the appropriate vehicles and 2) providing the alternative fuel and infrastructure for on-site fuelling. For programs that encourage use of alternative fuels for private fleets, there would be no enforcement, as these would likely be voluntary and supported by financial incentives.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive to
Neutral Depends upon the alternative fuel. Some alternative fuels require expensive refueling infrastructure that can push cost-benefits to neutral.
(Browning, 2014)
Co-benefits Yes Biodiesel can provide more lubricity, possibly extending the life of the engine. Cost savings depending on the type of fuel, for example converting from diesel to CNG. Black carbon emission reductions expected (with reductions of PM2.5).
(National Renewable Energy Laboratory, 2014) (Hamberg, 2010) (Institute of Transport Research at the German Aerospace Centre, 2003)
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Alternative fuels rules Criteria Eval. Notes References
Negative impacts
Yes Diesel engine warranties are typically void beyond a certain biodiesel blend. Biodiesel blends can plug filters and cause engine problems, particularly in cold weather with a ULSD biodiesel blend (at a higher percentage e.g. B20). Some technologies have lower fuel economies and higher maintenance costs.
(National Renewable Energy Laboratory, 2014) (Hamberg, 2010) (Institute of Transport Research at the German Aerospace Centre, 2003) (Federation of Canadian Municipalities, 2010)
3. General Activity
3.1. Regulations, Standards and Restrictions
3.1.1. Idling restrictions
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and engines
Target Vehicles: • All diesel vehicles
Objective: • To reduce emissions and noise by enacting stand-alone anti-idling laws. Brief Description: • Stand-alone anti-idling bylaws are typically enacted by the provincial or municipal level of
government. • Idling restrictions are usually associated with fines that can vary substantially. The range in
the restrictions reviewed was from $50 to $750 or even imprisonment. • Restrictions are designed to reduce unnecessary idling of on-road and off-road diesel vehicles
and engines. There are often a number of exceptions (such as emergency vehicles) and the idling limits also vary, for example from 3 minutes to 15 minutes (in the restrictions reviewed).
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs Authority Jurisdiction: • Provincial/Territorial – Develop regulations; enforcement • Municipal – Develop regulations; enforcement Method of Compliance and Enforcement: • Spot-checks
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• Fines Cost Bearer(s): • Single funder or shared • Public or private sector – Provincial/territorial and municipal governments develop,
implement and enforce the regulations; Owners/operators pay the fines On-road examples: • Many Canadian municipalities have enacted stand-alone idling policies, such as Guelph,
Kingston, London, Toronto, Niagara Falls, Pickering, Windsor, and Williams Lake. • North Carolina – Environmental Management Commission - Idling Rule for Heavy Duty
Vehicles Off-road examples: • California Air Resources Board – In-use Off-road Diesel Vehicle Regulation • Many US jurisdictions have enacted idle reduction requirements, such as New Jersey, South
Carolina, Nevada, Utah, and Texas. • City of Auburn, California – Anti-Idling Ordinance • Montreal – Regulation on atmospheric emissions Option Costs: • Drafting and implementing an anti-idling bylaw requires following council procedures, but
does not involve significant costs or time. • Operational costs would include bylaw enforcement and public education and awareness of
the bylaw. • Costs to violators range (e.g. $50 to $750). Key Benefits: • Given that idling enforcement is typically limited, the impacts are expected to be limited. • Specific emission reduction benefits vary by vehicle and idling time. • When idling restrictions are implemented near vulnerable populations, this results in reduced
emissions near sensitive receptors. Key Challenges: • Enforcement requires on-site personnel. Jurisdictions may resort to targeted campaigns in
certain areas of the city, such as truck stops and school yards, in order to educate drivers about the effects of idling engines on health and air quality.
• Cold or hot weather compliance is more challenging due to perceived need for engine warm-up and use of temperature control systems.
Estimated emission rates per vehicle for idling heavy-duty diesel vehicles: PM: 1.1 - 2.6 g/hr Overnight idling for trucks can be important in cities where trucks idle while waiting for delivery the next morning. Eliminating this type of idling would still result in low annual reductions per vehicle.
(Federation of Canadian Municipalities, 2010) (Browning, 2014)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
A Class 8 (tractor-trailer) truck emits about 105 grams of nitrogen oxides (NOx) for every hour of idling. Estimated emission rates per vehicle for idling heavy-duty diesel vehicles: NOx: 55 - 144 g/hr Overnight idling for trucks can be important in cities where trucks idle while waiting for delivery the next morning. Eliminating this type of idling would still result in low annual reductions per vehicle.
(ICF International, 2012) (Federation of Canadian Municipalities, 2010) (Browning, 2014)
GHG emission reduction potential per vehicle - CO2e
On-road: Low Off-road: Low
Diesel engines consume from 1 to 4 L/hr, depending on factors such as, size of the engine, idle speed, accessory loads and power take-offs. For example, an idling truck burns ~ 3.8 L (1 US gallon) diesel fuel/hour resulting in approximately 10.3 kg CO2e. Estimated emission rates per vehicle for idling heavy-duty diesel vehicles: GHGs: 8736 g/hr
(Federation of Canadian Municipalities, 2010) (US EPA, 2014)
Policy/Program costs (Total $ and $/year as available)
Implementation: Very Low Operating: Very Low to Low
Implementation: Drafting and implementing an anti-idling bylaw requires following council procedures, but does not involve significant costs or time. Although no specific values could be obtained for this evaluation (as labour time on specific tasks is generally not tracked), it is assumed that costs are very low. Operating: Operational costs would include bylaw enforcement and public education and awareness of the bylaw. If municipal employees are carrying out these tasks, then operational costs do need to be considered (e.g. in terms of salaries). Although no specific values could be obtained for this evaluation, it is assumed that costs will range from very low to low, depending on factors such as whether new dedicated staff are hired or existing staff take on added responsibilities, etc.
(Manitoba Municipal Government)
Vehicle - Capital Costs ($/vehicle)
No Cost Manually turning off a vehicle does not cost the operator. Anti-idling technologies are not considered under this option.
Vehicle - Operating Costs ($/vehicle)
Savings Operational savings result from reduced fuel use. Magnitude of savings depends on the amount of idling time reduced and the type of vehicle. For diesel engines consume from 1 to 4 L/hr, depending on factors such as, size of the engine, idle speed, accessory loads and power take-offs.
(Natural Resources Canada, 2013)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy Municipal bylaws and provincial/state rules are assumed to be easy to develop and implement with few regulatory hurdles and contained within the public sector.
Ease of complying
Easy Complying with anti-idling regulations is simple, the only requirement is to turn off the vehicle, and no additional resources are required. There are a few challenges with complying, such as knowing that the bylaw/restriction exists. Also, depending on location, complying in cold or hot weather may be a challenge, if no auxiliary power units are used to power the heating and cooling systems. Most idling restrictions have exemptions for certain types of vehicles (e.g. transit buses, cranes providing hydraulic power, etc.) or in certain locations/times of year.
(CARB, Revised February 2014 )
Ease of proving compliance
Moderate Although it is easy to prove compliance, the vehicle is either on or off; this initiative is evaluated as moderate. This is because the operator proves compliance during the operation of the vehicle/engine. With many bylaws, warnings are handed out on a complaints basis, rather than tickets on-site. In this way, the operator cannot prove that they were not idling, at the time the complaint was made. This is why the operator receives a warning rather than a ticket, in these situations.
Ability to enforce Moderate Enforcement of idling restrictions typically requires identifying idling 'hotspots' and stationing an authority at that location to enforce the bylaw. The most common approach to enforcement with respect to anti-idling by-laws is complaints based (meaning that by-law officers will respond to public complaints of idling vehicles). Complaints
(Natural Resources Canada, 2013) (Clean Air Partnership, 2005) (CARB, Revised May 2011)
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
based enforcement presents more of a challenge as the vehicle may no longer be present or idling when the authorities arrive. This type of enforcement typically results in a warning to the operator. Enforcement blitzes are considered to be moderate as they require resources for spot-checks. For example, under the CARB In-Use Off-Road Diesel Vehicle Regulation, idling restrictions are enforced through idling inspections, conducted by observing off-road vehicles at construction sites, mines, etc. The first violation receives a $300 penalty. Subsequent penalties can range from $1,000 to $10,000.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive There are minimal costs for developing and implementing idling
restrictions compared to benefits of turning off the engine. Anti-idling bylaws can be drafted within operating budgets. Additional financial resources may need to be explicitly budgeted for education and enforcement in future years.
Co-benefits Yes Noise reduction. When idling restrictions are implemented near vulnerable populations, this results in reduced emissions near sensitive receptors. Black carbon emission reductions expected (with reductions of PM2.5).
Negative impacts No None identified
3.1.2. Vehicle use operating restrictions PROFILE Applicable to: • On-road heavy duty diesel vehicles
Target Vehicles: • Typically large trucks for speed limiters • Can be all vehicles for congestion charges, although heavy duty vehicles are often charged higher usage fees
Objective: • To reduce emissions and improve safety by imposing vehicle operating restrictions on on-
road vehicles, such as speed limitations and time of use. Brief Description: • Operating restrictions may include time of use restrictions or speed restrictions for on-road
heavy duty diesel vehicles. • The use of electronic speed limiters on large trucks reduces fuel consumption (which, in turn,
would reduce PM and NOx emissions) and improves road safety. • Congestion charges are an example of time of use restrictions whereby, vehicles are charged
varying fees depending on time of day and roads travelled. The intent is to reduce congestion and therefore reduce the amount of idling time for vehicles travelling within those zones.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
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Method of Compliance and Enforcement: • Spot-checks, inspections, real-time monitoring (e.g. automated vehicle registration
recognition systems) • Penalty charges, fines Cost Bearer(s): • Single funder or shared • Public or private sector – Provincial/territorial and municipal governments develop,
implement and enforce the regulations; Owners/operators pay for technology upgrades if/as necessary and the use charges if/as necessary, as well as pay the fines
On-road examples: • The Ministère des Transports du Québec - Speed Limit Control Measure • Ministry of Transportation of Ontario - Regulations under the Ontario Highway Traffic Act
(Ontario Regulation 396/08) - Mandatory Truck Speed Limiter Legislation • Transport for London – Congestion Charge Zone (time/day of use charges) • Norway – Charging scheme Option Costs: • Implementation costs depend on the operating restrictions being implemented. For example,
London's Congestion Charging Scheme set up cost was £80.8 million plus £80.9 million for road traffic measures associated with the scheme, for a total of £161.7 million (Greater London Authority, 2006).
• On the other hand, speed limiter restrictions may simply involve the development and implementation of a provincial regulation (which is assumed to be low, incurred as labour expenses).
• Net revenue is possible for congestion charges/time of use operating restrictions through use/service payments and penalties.
• Operating costs for speed limiters would include enforcement and monitoring costs and would be considered low to medium, depending on the size of the jurisdiction and enforcement required.
Key Benefits: • Impacts of regulations are dependent on enforcement and degree of public acceptance of
requirement and expectation of enforcement. • Reduced fuel consumption resulting from slower driving speeds and associated reduction in
emissions. • The United Kingdom has a speed limiter legislation in place and has shown a 26% decrease
in heavy truck accidents since the legislation was enacted in 1992 (Transport Canada, 2013). Key Challenges: • Compliance and enforcement efforts are integral to the effectiveness of speed limiters.
Insufficient resources for enforcement would pose a challenge.
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• Tampering of the speed limiters is a problem as well, de-activating it, increasing the speed, or adjusting tire size or gear ratios to allow true vehicle speed to exceed the speed limiter setting (Transport Canada, 2013).
• The Ontario Trucking Association (which mostly represents large fleets) supports the speed limiter rule, but owner-operators are largely against it. The Ontario legislation was challenged in 2012 by an HDDV owner-operator.
• Challenges for congestion charging may include overcoming the perceived adverse impacts on local businesses.
EVALUATION NOTES
Vehicle use operating restrictions Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-road: Low With respect to time restrictions, impacts are assumed to be in line with GHG emission reductions due to reduced travel time by avoiding operation during congestion periods. For example, results of the London congestion charge scheme showed a reduction of NOx and PM10 by 12% overall. Also, it is important to note that results of this sort are typically from ambient monitoring; therefore there are many other factors that could be contributing to the reductions, such as the weather and vehicle technology changes. Not all reductions of this sort can be attributed to the congestion charging scheme. Furthermore, as with GHGs (below), it is difficult to interpret these results on a per vehicle basis. Despite these caveats, emission reductions are assumed to be low on a per vehicle basis.
(Sadler Consultants Ltd, 2014) (Transport for London, 2008)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-road NOx: Low On-road VOCs: Low
With respect to time restrictions, impacts are assumed to be in line with GHG emission reductions due to reduced travel time by avoiding operation during congestion periods. As another example, Milan, which has a congestion charge zone combined with a low emission zone, sees results during operation of the congestion charge zone, of 10% NOx reduction overall. Also, it is important to note that results of this sort are typically from ambient monitoring; therefore there are many other factors that could be contributing to the reductions, such as the weather and vehicle technology changes. Not all reductions of this sort can be attributed to the congestion charging scheme. Furthermore, as with GHGs (below), it is difficult to interpret these results on a per vehicle basis. Despite these caveats, emission reductions are assumed to be low on a per vehicle basis.
(Sadler Consultants Ltd, 2014)
GHG emission reduction potential per vehicle - CO2e
On-road: Low to Medium
Speed governors/limiters restrict the maximum speed a heavy duty vehicle can travel. There is an optimal speed to travel for each engine with respect to fuel efficiency. For example, reducing highway speed by 8 km/hr can reduce fuel consumption by about 7% per vehicle. The objective of speed limiters is to ensure that trucks are travelling within the optimal, most fuel efficient speed range. In North America, speed governors limit HDVs to 105km/hr. Time of use/congestion charges can indirectly impact emission reductions for each vehicle. This is because, one of the objectives of this type of initiative is to reduce congestion, which means fewer vehicles on the road and those that are travelling are not idling as long in traffic congestion, therefore saving fuel and reducing emissions. For example, results of the London congestion charge scheme showed a 30% reduction in congestion, a 15% reduction in traffic volume and a 19% reduction in CO2 emissions overall. It is difficult to interpret these results on a per vehicle basis, but since the main reason behind the emission reductions is smoother driving (e.g. less braking/accelerating) and less idling, we can assume that emission reductions are in line with the driver training results.
(Tiax, 2011) (Sadler Consultants Ltd, 2014)
Policy/Program costs (Total $ and $/year as
Implementation: Low to High Operating: No
Implementation: Implementation costs depend on the operating restrictions being implemented. For example, a Congestion Charging system similar to London's would be considered high cost,
(Greater London Authority, 2006) (Transport for
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Vehicle use operating restrictions Criteria Eval. Notes References
available) Cost to Medium as it includes a multitude of factors from signage to automated vehicle recognition systems to administrative costs. For example, London's Congestion Charging Scheme set up cost was £80.8 million plus £80.9 million for road traffic measures associated with the scheme, for a total of £161.7 million. On the other hand, speed limiter restrictions may simply involve the development and implementation of a provincial regulation (which is assumed to be low, as this type of cost is typically not tracked, but would be incurred in labour expenses). Operating: Net revenue is possible for congestion charges/time of use operating restrictions through use/service payments and penalties. For example, over the first three years of London's congestion charging, the income was £591.7 million, operating cost was £288.6 million, and so net operating income was £303.1 million. Operating costs for speed limiters would include enforcement and monitoring costs and would be considered low to medium, depending on the size of the jurisdiction and enforcement required.
London, 2012) (Browning, 2014)
Vehicle - Capital Costs ($/vehicle)
Low Time of use charging does not typically have a capital cost for the operator. Speed limiters on the other hand must be purchased and installed by owners/operators. The cost of speed limiters can vary widely based on quality and functionality, but remain low on a per vehicle basis.
(Transport Canada, 2007)
Vehicle - Operating Costs ($/vehicle)
Savings potential; No Cost to Medium
Vary depending on operating restrictions. For example, no costs for speed limiters or savings on fuel consumption vs. daily service fees for time of use charging. For example, London's congestion charging £11.50/day, whereas Milan's in 2 - 5€/day. The annual costs per vehicle will increase with the frequency of entry into the zone.
(Transport for London, 2014) (Sadler Consultants Ltd, 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Difficult Speed limiters would be considered difficult to implement, as highways are provincial jurisdiction and speed limiters require the cooperation of owners/operators, law enforcement, etc. Congestion charging implementation would also be considered difficult. For example, implementing a congestion charge in a large city would be difficult, due to the infrastructure and systems required, as well as the number of stakeholders involved.
Ease of complying
Difficult Owners/operators would need to purchase and install speed limiters prior to operation. Congestion charging can require owners/operators to register their vehicles prior to use in the congestion zone, or payment prior to use. They must have the appropriate vehicle certification on them during operation (e.g. proof of meeting Euro V standards).
Ease of proving compliance
Moderate Speed limiters - the operator can prove compliance by not tampering with the unit and following the regulation. Congestion charges - automated systems identify compliance, the owner/operator has to ensure they are registered/paid. Manual systems require the operator to have the certification on hand.
Ability to enforce
Moderate Speed limiters can be tampered with. Enforcement can occur by way of law enforcement using speed radar guns or at truck inspection stations, where spot-checks can be done on the units themselves to determine if they have been altered from the factory settings. Congestion charge enforcement can be automated, matching vehicle license plates against a database, or be manual, where law enforcement officers can stop vehicles that do not properly display compliance certificates. For automated systems, non-complying vehicles would receive a penalty notice in the mail. Enforcement of payment may then be transferred to a collection agency.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Neutral Reducing operations, either hours or areas, can reduce commerce.
London has monitored the impacts within the charging area since it began, based on business surveys, employment data, property values, business turnover and profitability. Transport for London reported in 2007 that the charging seems to have had broadly neutral economic impacts.
(Browning, 2014) (Federal Highway Administration, 2013) For an example CBA, see (Eliasson, 2009)
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Vehicle use operating restrictions Criteria Eval. Notes References
Co-benefits Yes Congestion mitigation, noise reduction, and safer driving practices. Black carbon emission reductions expected (with reductions of PM2.5).
Negative impacts
Yes Speed limiters potential negative impacts have to do with owners/operators bottom line. The primary costs of reducing operating speed come from reduced productivity, possibly higher driver labour costs, and possibly higher driver turnover. These may outweigh reduced fuel costs. Congestion charges/time of use fees may have impacts on local businesses (within the charging zones).
(ICF International, 2009)
3.1.3. Geographic operating restrictions
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and
engines
Target Vehicles: • Specific vehicles targeted by the legislation –
typically on-road higher emitting, older diesel vehicles and high-use off-road equipment, such as construction vehicles
Objective: • To reduce emissions and accelerate fleet turnover by establishing a geographic area where
certain vehicles are restricted from entering. Brief Description: • A specific geographic area, such as a port or downtown core, is defined through legislation,
mandatory program, etc. • Entry to this geographic area is restricted for certain vehicles, typically older vehicles that do
not meet the newest emission standards. • In order to gain entry, newer vehicles that meet the emission standards need to be used, or
older vehicles can be retrofit with approved technologies (to bring vehicles in line with newer standards).
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO, air toxics
Authority Jurisdiction: • Municipal – Develop regulations; enforcement • Provincial/Territorial – Develop regulations; enforcement • National – Develop regulations; enforcement Method of Compliance and Enforcement: • Spot-checks, inspections, real-time monitoring (e.g. automated vehicle registration
recognition systems) • Fines
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Cost Bearer(s): • Single funder • Public sector – Governments develop, implement and enforce the regulations;
Owners/operators pay for the use charges if/as necessary, and pay the fines On-road examples: • Port of Los Angeles – Clean Truck Program • Swedish Transport Agency – Low Emission Zone • Transport for London – Low Emission Zone • Berlin – Environmental Zone • Port Metro Vancouver – Container Truck Licensing Program
Off-road examples: • Metro Vancouver – Non-road Diesel Engine Emission Regulation • Port Metro Vancouver – Non-road Diesel Emissions (NRDE) Initiative (under development) Option Costs: • Costs would vary substantially depending on area, vehicle restrictions, monitoring,
enforcement, etc. Costs also depend on how the geographic restrictions are implemented. For example, a relatively low cost approach with a low administrative burden would be to develop a regulation requiring vehicle/engine registration for a specific and limited set of vehicles that can be tied into existing vehicle registration requirements. Alternatively, higher cost options with higher burdens could require real-time monitoring on a larger number and variety of vehicles.
• As an example, prior to implementation, the estimated start-up costs for the London Low Emission Zone ranged from £2.8 million for manual enforcement with heavy duty vehicle (HDV) restrictions to £10.4 million for automatic enforcement with HDV and light van restrictions. The annual operating costs were estimated to be £3.9 million and £7 million, for the same two scenarios, respectively (City of London).
• Revenue from tickets and fines (e.g. failure to comply with Metro Vancouver Non-road Diesel Engine Emission Regulation may result in $1,000 tickets or up to $200,000 fines) (Metro Vancouver, 2012).
Key Benefits: • Impact of regulations are dependent on compliance, with sufficient enforcement, larger
emission reductions can be expected. Also the larger the geographic region, the more vehicles impacted, the larger the emission reductions.
• Improved air quality (reduced emissions), leading to improved health, particularly chronic respiratory symptoms and particularly in areas with sensitive receptors (Kelly et al., 2011).
• High compliance rates21, potentially due to aggressive enforcement and high fines. • Small reduction in noise in target areas.
21 The London Low Emission Zone has compliance rates of greater than 95%. See Transport for London, Congestion Charging and Low Emission Zone Key Fact Sheet, April 1, 2014 to June 30, 2014 (http://www.tfl.gov.uk/cdn/static/cms/documents/cclez-factsheet-april-jun14.pdf)
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• Restrictions can be designed at different levels of cost and burden, while targeting high emitters.
Key Challenges: • Potential challenges include high costs for retrofits (or new vehicles) to meet restrictions,
particularly for smaller businesses. • Older, higher polluting vehicles may be diverted to operate outside the restricted areas
(Transport for London, 2008). • Tracking and enforcing compliance may be challenging if not automated. • General public acceptance and understanding of the restrictions and rationale. EVALUATION NOTES
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-road: Mid to High Off-road: Mid to High
Emission reductions on a per vehicle basis depend on the emission standards used in the operating restrictions and the baseline vehicle (i.e. what vehicle is being replaced to meet the restrictions). For example, the Metro Vancouver non-road regulation applies to older engines, unregistered Tier 0 (older engines that do not have any emission controls) will no longer be allowed after January 1, 2015, and Tier 1 must be registered and paid for (engines that have slightly lower emissions through improved air and fuel delivery systems but do not use emission control systems). Tier 2, Tier 3 and Tier 4 engines do not require registration (engines that have emission control systems). London and Berlin LEZs requires vehicles meet Euro 4 for PM.
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-road NOx: Mid to High Off-road NOx: Mid to High VOCs: No info
See above.
GHG emission reduction potential per vehicle - CO2e
N/A Geographic operating restriction aim to change the emission standards of vehicles travelling within the zones (e.g. reduce emissions of air pollutants), not necessarily to reduce fuel consumption and GHG emissions.
Policy/Program costs (Total $ and $/year as available)
Implementation: High Operating: High
Implementation: Costs will vary drastically depending on a number of factors, such as the scope of the geographic operating scheme (e.g. a port vs. a large city) and on type of system used (e.g. manual vs. automatic). For example, the Feasibility Study for the London LEZ estimated the costs for a manually enforced scheme for trucks would have the lowest cost to set-up at an estimated £2.8 million. Whereas an automatic enforcement approach using existing congestion charging infrastructure, combined with the use of mobile and fixed cameras, was estimated to cost £6 million to £10 million to set-up. As another example, the first year (2009) of the Clean Truck Program at the Port of Los Angeles, the expenses were $54 million (with revenue of $24.8 million). Operating: Again, operating costs depend on the nature of the system, manual vs. automatic. For example, the Feasibility Study for the London LEZ estimated the costs for a manually enforced scheme for trucks would have an annual operating cost of £4 million. Whereas an automatic enforcement approach using existing congestion charging infrastructure, combined with the use of mobile and fixed cameras, was estimated to around £5 million to £7 million each year. As another example, for the second year of operation (2010) of the Clean Truck Program at the Port of Los Angeles, the expenses were $20.7 million (with revenue of $28.7 million).
(Watkiss P, 2003) (Port of Los Angeles, 2009) (Port of Los Angeles, 2010)
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
Medium to High An evaluation of medium to high refers to owners/operators that are required to retrofit (medium) or upgrade (high) their engines and vehicles in order to meet the operating restrictions. See retrofit/upgrade evaluation for cost details.
Vehicle - Operating Costs ($/vehicle)
Low to Medium Restrictions typically come with operating fees and vary from program to program. For example, Metro Vancouver bases annual fees on Tier and hp (e.g. in 2015, Tier 0 will be $10/hp and Tier 1 will be $6/hp). Port of Los Angeles Clean Truck fee is $35 per twenty-foot equivalent unit. The London low emission zones daily charges range from £100 to £200 depending on the type of vehicle.
(Metro Vancouver, 2012) (Port of Los Angeles, 2009) (Sadler Consultants Ltd, 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Moderate to Difficult
Ease depends on who is implementing the geographic operating restriction. For example, implementing a LEZ in a large city would be difficult, including infrastructure and software, registration and enforcement, etc. and involve a number of stakeholders. Whereas, implementing a restriction at a port would be considered moderate, involving a more defined area, with existing access infrastructure and fewer parties. Note difficulty may also be impacted by support for the restriction, such as industry push back.
Ease of complying
Difficult Typically, the owner/operator would have to register the vehicle prior to operating it in the restricted zone. After the vehicle is registered, the enforcement system would detect whether or not the operator is in compliance and there would be no further requirements on the owner/operator. Registration may be a simple online system; however, this evaluation of difficult is due to the fact that the owners/operators must register prior to operating within the zones or otherwise face penalties.
(Metro Vancouver, 2012)
Ease of proving compliance
Easy Proof typically requires registration of vehicle.
Ability to enforce
Easy Automated systems (e.g. London LEZ) enforce with cameras that read vehicle license plates and check the plates against a database of registered vehicles. Manual systems commonly use stickers (e.g. Berlin LEZ), to identify the emission class of vehicle, and enforcement officers.
(Sadler Consultants Ltd, 2014)
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Neutral Overall, the benefits (air quality improvements and health) of low
emission zones are likely to be similar to overall costs (including the costs to vehicle operators). However, note that none of the LEZ schemes considered in the London feasibility study were considered to be self-financing.
(Watkiss P, 2003)
Co-benefits Yes In addition to catalysing faster vehicle turnover to newer vehicles or improving vehicle emissions through retrofits, geographic operating restrictions can also contribute to congestion mitigation for on-road vehicles. Potential for direct targeting for areas with sensitive receptors. Black carbon emission reductions expected (with reductions of PM2.5).
Negative impacts
Yes Potential increase in vehicle kilometers travelled. This may occur if owners/operators want to avoid the restricted areas instead of complying with them. Older, higher polluting vehicles may also be diverted to operate outside the restricted areas.
(Transport for London, 2008)
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3.2. Operations and Management Programs and Practices
3.2.1. Policies and programs on logistics, route optimization and vehicle tracking PROFILE Applicable to: • On-road heavy duty diesel vehicles22
Target Vehicles: • On-road diesel vehicles, typically
commercial or municipal fleets Objective: • To reduce fuel consumption through logistics practices and route optimization that reduce
vehicle kilometres travelled. This will also result in emission reductions. Brief Description: • Depending on the vehicle type and use, optimized logistics practices can save fuel and time,
as well as improve productivity. In particular, efficiencies can be obtained by reducing empty travel (deadheads), reducing use of longer or congested routes, and reducing unnecessary idling.
• Vehicle use can be optimized by minimizing vehicle miles travelled with route optimization. Route optimization can be assisted through vehicle tracking systems. There are many different types of vehicle tracking technologies from basic location tracking (e.g. global positioning system (GPS)) to more robust monitoring systems (e.g. automatic vehicle locator (AVL) or telematics systems) that track location, speed, idle time and other vehicle systems data. These onboard computer systems can record data on the condition and activity of the vehicle as well as the driver. They can also allow for real-time re-routing based on traffic conditions, connect to traffic signal priority systems, etc.
• Efficient logistics practices and route optimization can be applied to a number of fleet types, such as commercial trucking operations, school buses, and municipal fleets (e.g. snow removal equipment, transit buses, and waste collection trucks).
• Logistics and route optimization software are becoming commonplace in large fleets. Target Pollutant Type: • Air pollutants
Target Pollutants: • By reducing vehicle kilometres travelled, vehicles are
operating for a shorter duration, and therefore emitting less PM, NOx, VOCs, CO air toxics
• Greenhouse gases • GHGs Authority Jurisdiction: • Municipal23 – Develop and implement programs • Provincial/Territorial • National
22 During this review, only on-road policies and programs were identified, however, these types of programs may be applicable to off-road vehicles as well. 23 During this review, only municipal programs were identified, however, these types of programs would be applicable to any fleet, including provincial/territorial and federal.
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Method of Compliance and Enforcement: • N/A Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop, implement and enforce the programs;
Owners/operators may pay for technology (in part or in full) On-road examples: • Kelowna – School bus tracking system • City of Québec – GPS for snow removal machines • Winnipeg – AVL systems in transit buses • Toronto – Route optimization policy Option Costs: • Overall cost depends on the system selected and the number of vehicles. For example, a GPS
based system that tracks vehicle data such as location, distance travelled, fuel consumption, speeding, idling, engine working hours, etc. could cost approximately $400/vehicle for hardware and installation plus approximately $35/vehicle/month for support services. System costs will go up or down depending on complexity of data capture, storage, analysis, etc.
• Another example is Quebec City’s use of GPS units and route optimization software in its fleet of snow removal machines. The units cost $800 each and installation was between $300 and $500 per unit (Federation of Canadian Municipalities, 2010).
Key Benefits: • The magnitude of benefits depends on practice and fleet type, but generally results in reduced
operating time, fuel consumption, costs, and emissions. • Depending on fleet size and distance travelled, emission reductions can be large. • For example, GPS use on snow removal machines in Quebec resulted in overall reduction in
operating time and kilometres travelled as well as improved customer service, particularly regarding scheduling enquiries and complaints.
• Real-time routing and logistics planning can also contribute to reduced congestion and increased safety for drivers.
Key Challenges: • In addition to capital costs, service costs can be high depending on the type of units used and
the type of system. For example, the largest cost for the Quebec GPS snow removal units was cell phone air time, as the GPS data is relayed over cellular networks. In the first year, the cell costs were $800,000 for approximately 1000 vehicles (Federation of Canadian Municipalities, 2010).
• Implementation with unionized operators can be challenging, given the perceived lack of privacy.
• Understanding the benefits of these systems can also be a challenge for both decision makers and operators alike
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EVALUATION NOTES
Policies and programs on logistics, route optimization and vehicle tracking Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-road: Low Assumed to be in line with GHG emission reductions due to reduced vehicle kilometres travelled.
Air pollutant emission reduction potential per vehicle - NOX or VOCs
On-road NOx: Low On-road VOCs: Low
Assumed to be in line with GHG emission reductions due to reduced vehicle kilometres travelled.
GHG emission reduction potential per vehicle - CO2e
On-road: Low to Medium
Studies on fuel savings achieved through automated vehicle tracking and routing software show 5% to 10% savings per vehicle. Industry experts and contacts with private fleets suggest that the use of routing software can reduce vehicle kilometres travelled between 7% and 25%. The estimated average opportunity is 10% (medium). Whereas, use of GPS only, is estimated to reduce vehicle kilometres travelled by approximately 4% (low).
(Federation of Canadian Municipalities, 2010) (ICF International, 2009)
Policy/Program costs (Total $ and $/year as available)
Limited Info Implementing route optimization or vehicle tracking systems into fleets are typically decisions that are taken by fleet managers, rather than as a result of higher level programs or policies. Optimizing logistics includes practices that can save fuel and time (reducing costs), as well as improve productivity (increasing revenue). Therefore, these types of initiatives are usually implemented as a business decision. In terms of policy/program costs at the government level, associated costs may include their own time spent on determining what the best systems are to integrate into their own fleets. Detailed cost information was not identified during the course of this work. Interestingly, the US Department of Transportation Federal Motor Carrier Safety Administration has proposed rules to establish minimum performance and design standards for hours-of-service electronic logging devices. This rule is structured around hours of service, but these devices also have the capacity to track factors such as distance travelled, fuel consumed, etc. With these units in place due to the proposed rule, costs of any future initiatives to track fuel, distance, etc. would be minimized.
(US Federal Register, 2014)
Vehicle - Capital Costs ($/vehicle)
Low Costs depend on the type of unit, functionality and service chosen. For example, an aftermarket GPS based system that tracks vehicle data such as location, distance travelled, fuel consumption, speeding, idling, engine working hours, etc. could cost approximately $400/vehicle for hardware and installation. A more complex system that includes routing software may be more costly, such as the GPS and route optimization software used by Quebec City's snow removal machines, which cost $800 per unit plus in-house installation costs of $300 to $500 per unit. All trucks built after 2008 come equipped with onboard computers, and some trucks also now come equipped with telematics systems, such as Volvo, Mack and Daimler. With these, the only cost associated with the units would then be the operating costs (e.g. software subscription, and data or cell fees).
(Federation of Canadian Municipalities, 2010) (Huff, 2014)
Vehicle - Operating Costs ($/vehicle)
Savings Despite operational costs, such as monthly support/service fees, cell phone fees, etc., there is generally an overall savings due to reduced fuel consumption (and improved work efficiency). However, for information, monthly software subscription fees are usually between $15 and $50.
(Federation of Canadian Municipalities, 2010) (Wheeler, 1999) (Huff, 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Moderate Perceived breach of privacy can make it moderate to implement. Owners and operators need to be on-board with the decision to implement this type of system. The most difficult part of implementation could be considered to be obtaining the initial buy-in from operators.
(Federation of Canadian Municipalities, 2010)
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Policies and programs on logistics, route optimization and vehicle tracking Criteria Eval. Notes References
Ease of complying
Moderate Some training is required for the operators to effectively use GPS and AVLS units.
Ease of proving compliance
Moderate If the system is functioning during operation of the vehicle, the operators could be considered in compliance. However, if the operator did not adhere to the system routing, warnings, etc. the operator would be deemed non-compliant. With respect to proving compliance, these types of systems can be set up to produce daily reports to managers, indicating different levels of information (from the basic fuel consumption and vehicle kilometres travelled to more comprehensive reporting on number/type of flags/warnings, route map, idling time, etc.).
Ability to enforce Easy Once the automated systems are in place (e.g. GPS, AVLS), the initiatives are easy to enforce given the real time vehicle tracking capabilities and option for daily reporting. Both technologies (GPS and AVLS) allow drivers to easily identify the best route to take, based on accurate and real-time data. Operators are ultimately in control of where and how they drive. Enforcement would have to take the form of discipline for not adhering to suggested routes, etc. or positive incentives for optimum performance.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Fleet managers need to manage fuel (as the largest expense)
and drivers (because of hours of service rules). Optimizing efficiency, minimizing fuel consumption is a business decision made to save money. Some large trucking companies, recognizing the importance of efficient logistics operations, are also moving into logistics business as well (diversifying their businesses).
(SmartWay Transport Expert, 2014)
Co-benefits Yes Route optimization with real time planning reacts to traffic situations and therefore helps to mitigate or avoid congestion. Avoiding heavy traffic may also lead to safer driving. Systems that provide feedback, such as speeding, aggressive braking notifications, etc. also encourage safer driving habits and can decrease wear and tear. Employee productivity is also improved. Reduction in operating and labour costs. Customer service improvements if vehicles related to the public at all (e.g. transit buses, snow plows, waste removal, etc.) Black carbon emission reductions expected (with reductions of PM2.5).
(Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010) (ICF International, 2009)
Negative impacts No None identified 4. Cross-cutting
4.1. Education
4.1.1. Driver training programs PROFILE Applicable to: • On-road heavy duty diesel vehicles24
Target Vehicles: • Training programs can be tailored to
different vehicles, typically high use on-road vehicles
24 During this review, only on-road policies and programs were identified, however, these types of programs may be applicable to off-road vehicles as well.
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Objective: • To train and educate fleet owners and drivers with the aim of reducing fuel consumption and
emissions through fuel-efficient driving and fleet management. Brief Description: • Training programs typically include workshops, classroom and on-road courses, or the
provision of training materials for distribution. They can be mandatory or voluntary. • Training for fleet managers generally includes establishing a fleet inventory and establishing
a fuel use baseline, developing a fuel management plan, and analyzing fleet and driver performance.
• Driver training aims to optimize vehicle use through fuel-efficient driving practices. The principles of fuel efficient driving include progressive shifting (e.g. block shifting) and maintaining a steady speed (e.g. anticipating traffic flow and breaking and accelerating smoothly and gradually).
• Driver training may also include training on specific vehicle technologies, vehicle care and inspections.
Target Pollutant Type: • Air pollutants
Target Pollutants: • PM, NOx, VOCs, CO
• Greenhouse gases • GHGs Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs • National – Develop and implement programs Method of Compliance and Enforcement: • Certification sometimes required to operate a vehicle Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop and implement the programs, they may also
provide the programs; Owners/operators may pay for the programs On-road examples: • BC – Climate Action Toolkit – Driver awareness and education training • Fraser Basin Council – E3 Fleets • Edmonton – Fuel $ense – Fuel efficiency training program for drivers • Natural Resources Canada – Fuel Management 101 workshop for fleet managers;
SmartDriver for Highway Trucking; SmartDriver for Transit; SmartWay • Nova Scotia – FleetWiser • US EPA – SmartWay Transport Partnership • Quebec Department of Energy and Natural Resources - Ecodriving
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Option Costs: • Training and education material costs are minimal with respect to the potential savings on a
per driver/vehicle basis. In addition, many established training programs are offered free of charge to large fleets.
Key Benefits: • Fuel efficient driving practices can typically improve fuel efficiency by 5% to 10%. • Other benefits include reduced noise pollution, reduced fuel and vehicle maintenance costs,
and reduced incidence of traffic accidents. Key Challenges: • Education programs typically result in lower emission reductions over the long term. • Difficult to enforce and maintain good practices after the training is complete. • Fuel efficient driving is more difficult in winter driving conditions, resulting in increased fuel
consumption. For example, tires lose pressure when the temperature drops, poor road conditions demand more traction, oils and lubricants are less effective, and auxiliary systems are used more.
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EVALUATION NOTES
Driver training programs Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
Not evaluated Driver training programs focus mainly on fuel efficiency and therefore GHG emission reductions, rather than air pollutant emission reductions. However, reduced acceleration rates and smoother driving should result in some CAC emission benefits, including PM. It is very difficult to quantify and therefore has not been evaluated.
(Browning, 2014)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
Not evaluated Driver training programs focus mainly on fuel efficiency and therefore GHG emission reductions, rather than air pollutant emission reductions. However, reduced acceleration rates and smoother driving should result in some CAC emission benefits, including NOx and VOCs. It is very difficult to quantify and therefore has not been evaluated.
(Browning, 2014)
GHG emission reduction potential per vehicle - CO2e
On-road: Medium Driver training programs focus on improving fuel efficiency. Fuel efficiency savings are in the range of 5% to 15% per vehicle when using a combination of efficient driving techniques. For example, the City of Edmonton found that for the 800 municipal operators trained in the Fuel Sense program, the average efficiency gain was 12%.
(Natural Resouces Canada, 2013) (US EPA, 2004) (US EPA, 2004) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010) (Transport Canada, 2010)
Policy/Program costs (Total $ and $/year as available)
Implementation: Very Low to High Operating: Very low to Low
Implementation: Costs to develop and implement driver training programs can vary substantially and depend on the objective and extent of the program, size of the fleet, whether it is integrated into existing training programs, how much existing material is leveraged, etc. As an example, Edmonton's Fuel Sense program incurred start-up costs of $60,000. Whereas, the national SmartDriver for Transit program, developed by Natural Resources Canada (NRCan), required $1.105 million over 5 years and included program design, certification of trainers, program pilot runs at 5 sites, and data collection before/after the pilot tests. This national program was a large investment, with the idea that it can be rolled out at much lower costs to individual jurisdictions. Operating: Costs to operate a driver training program may depend on the size of the fleet, format of the training (e.g. classroom, on-road), whether it is integrated into existing training programs, etc. As an example, Edmonton's Fuel Sense program incurs annual costs of approximately $45,000.
No Cost to Low Some driver training programs are offered free of charge. Otherwise, minimal costs can be expected to attend external training courses and costs occur in staff labour time for internal courses.
Vehicle - Operating Costs ($/vehicle)
Savings If fuel efficient driving techniques learned in the training are followed afterwards, the operator will reduce fuel consumption and save money.
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy As this initiative generally consists of a training program (in-class and on-road), the option itself is easy to implement, and depends primarily on interest and willingness. There are existing training modules, existing training materials, and existing courses, if resources are limited to create a new program.
(Natural Resouces Canada, 2013) (US EPA, 2004) (US EPA, 2004) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010)
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Driver training programs Criteria Eval. Notes References
Ease of complying Moderate to Difficult
Sometimes driver training programs are mandatory, either for existing drivers within an organization, for new hires, or for contractors. For instance, certification of completing a fuel efficient driver course may be required to bid on work or to apply for a job. This has been evaluated as moderate to difficult because of the time investment prior to operating the vehicle for training (e.g. government run training programs are typically 8 hours in length) and the ongoing commitment required to practice the skills after course completion. Edmonton's Fuel Sense program is only 4 hours in length, but requires retesting, which in the initial stages of the program, proved to be a challenge for scheduling purposes.
(Federation of Canadian Municipalities, 2010) (Natural Resouces Canada, 2013) (US EPA, 2004) (US EPA, 2004) (Federation of Canadian Municipalities, 2010) (Transport Canada, 2010)
Ease of proving compliance
Easy It is considered to be easy to prove completion of a course. If it was an external course, a certification would be obtained, if it was an internal course, the program would track driver training status.
Ability to enforce Easy Fuel efficient driving training can be enforced through on-the-job training requirements or enforced through hiring criteria.
(Federation of Canadian Municipalities, 2010) (Natural Resouces Canada, 2013) (US EPA, 2004) (US EPA, 2004) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010)
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Education and training programs are inexpensive relative to other
initiatives that can provide the same impact on fuel efficiency improvements.
(Browning, 2014)
Co-benefits Yes Fuel efficient driving techniques have an impact on fuel efficiency, as well as wear and maintenance costs for the engine, tires, and brakes. Maintaining a steady speed (e.g. use of cruise control where appropriate, anticipate traffic flow, coast where possible, brake and accelerate smoothly and gradually) can also lead to safer driving practices.
(Federation of Canadian Municipalities, 2010) (Natural Resouces Canada, 2013) (US EPA, 2004) (US EPA, 2004)
Negative impacts No None identified
4.1.2. Idle reduction campaigns
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and
engines
Target Vehicles: • On-road diesel vehicles and off-road diesel
vehicles and engines that fall within the confines of the program (e.g. community wide or targeted vehicles)
Objective: • To encourage the reduction of unnecessary engine idling.
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Brief Description: • Education and awareness campaigns directed at specific fleets or more broadly, such as
community wide or provincial initiatives. • Campaigns may involve public outreach (e.g. kiosks at community events), targeted outreach
(e.g. to certain fleets), posters and other materials (e.g. in-vehicle reminder stickers), and online resources.
• Information contained in the campaigns may include anti-idling guidelines, as well as facts on issues of health and air quality, climate change, and economy and environmental concerns.
Target Pollutant Type: • Air pollutants
Target Pollutants: • In turning off the engine, idle reduction campaigns target
tail-pipe emissions, including PM, NOx, VOCs, CO, air toxics
• Greenhouse gases • GHGs Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs • National – Develop and implement programs Method of Compliance and Enforcement: • N/A Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop and implement the programs, they may also
provide the materials; Owners/operators may pay for materials On-road examples: • Natural Resources Canada, Office of Energy Efficiency – Idle Free Zone • BC Ministry of Environment and the Ministry of Healthy Living and Sport – Provincial Idle
Reduction Initiative • Manitoba/Climate Change Connection – Anti-idling program • Sudbury – Turn it off campaign • Edmonton Transit – Limited idle policy posters Off-road examples: • US Green Building Council – Clean Construction Pilot Credit Option Costs: • Costs are minimal to run an education awareness campaign.
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Key Benefits: • Idle reduction campaigns can potentially have a broad reach in terms of number of people
and types of vehicles. Campaigns can also target sensitive receptors, such as children in school zones.
• Actual savings depend on duration of idling, for example an idling truck burns approximately 3.8 L diesel fuel/hour.
• Awareness campaigns typically result in lower emission reductions over the long term, as they depend on behaviour change.
Key Challenges: • Emission reductions may be low due to poor uptake. • Difficult to enforce and maintain good practices. EVALUATION NOTES
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
On-road: Low Off-road: Low
This option is structured around education and raising awareness. The objective is to encourage the reduction of unnecessary engine idling. The option does not explicitly target emission reductions and the impact on emissions depends on behaviour change resulting from the initiatives. The amount of emissions that could potentially be reduced through idle reduction campaigns cannot be accurately quantified (e.g. there is no way to accurately determine the number of participants that would adopt anti-idling practices or how long each individual vehicle does not spend idling). It is assumed to be low, though detailed information was not identified during the course of this work as evidence for this assumption.
(Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
See above (Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010)
GHG emission reduction potential per vehicle - CO2e
On-road: Low Off-road: Low
See above (Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010)
Policy/Program costs (Total $ and $/year as available)
Implementation: Very low to Low Operating: Very low to Low
Implementation: Education and awareness programs are considered to be inexpensive (very low to low), the amount of which would depend on the size of the campaign and type of media used. Many resources are also free of charge from governments (e.g. NRCan Idle Free Zone resources) and NGOs, helping to keep costs low. For example, Sudbury's turn it off campaign, which targeted school bus drivers (and parents, general public) at 49 schools, spent $5,893 for the campaign materials (155 signs, posts and bases). Sudbury is a relatively small municipality; it is feasible that for a larger jurisdiction, the campaign material costs could rise to the low category. Sudbury's campaign materials were restricted to posters. If campaign materials included TV or radio spots, costs could increase significantly. For example, the City of Mississauga spent $30,500 on production of materials, including media events. (Note the Mississauga campaign was targeted at the general public i.e. light duty vehicles, it is used here only as an example of this type of
campaign costs). Operating: Operational costs for implementing an idle reduction campaign are also likely to be very low to low, depending on the size of jurisdiction and the number of staff involved. Typical operational costs would include labour costs for installing signage, carrying out surveys, etc. as well as ongoing campaign material production. If campaign materials include TV or radio spots, costs could increase significantly. For example, Sudbury spent $2676 on labour, which included staff carrying out surveys at the schools. Whereas, the City of Mississauga spent $50,000 on staff time over a one year project, and an additional $50,000 for the evaluation of the campaign. (Note the Mississauga campaign was targeted at the general public i.e. light duty vehicles, it is used here only as an example).
Vehicle - Capital Costs ($/vehicle)
No Cost Manually turning off a vehicle does not cost the operator. Anti-idling technologies are not considered under this option.
Vehicle - Operating Costs ($/vehicle)
Savings Operational savings result from reduced fuel use. Magnitude of savings depends on the amount of idling time reduced and the type of vehicle. For example, diesel engines consume from 1 to 4 L/hr, depending on factors such as, size of the engine, idle speed, accessory loads and power take-offs.
(Natural Resources Canada, 2013)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy Developing and implementing an education and awareness campaign generally requires limited external consultation (e.g. possibly a consultant to help develop the campaign, but unlikely requiring public consultation and scientific assessment) and meets few regulatory hurdles, given the nature of the initiative. Depending on the choice of campaign materials, cooperation may be necessary between departments. For example, many jurisdictions will have signage bylaws that need to be adhered to. And in some situations, the Public Works department will need to be responsible for erecting the signs. Education campaigns can often be viewed as low hanging fruit and will generally be supported because of this.
(Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010) (Natural Resources Canada, 2014)
Ease of complying N/A Participating in idle reduction campaigns is typically voluntary in nature (mandatory idling restrictions are treated separately).
Ease of proving compliance
N/A See above
Ability to enforce N/A See above ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Education and awareness programs are inexpensive relative to
other initiatives that can provide the same impact on fuel efficiency improvements.
(Browning, 2014)
Co-benefits Yes When idle reduction campaigns are implemented near vulnerable populations, this results in reduced emissions near sensitive receptors. Noise reduction. Black carbon emission reductions expected (with reductions of PM2.5).
Negative impacts No None identified
4.1.3. Labelling and information policies (including guidance documents and action
plans) PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and
engines
Target Vehicles: • All on-road and off-road diesel vehicles and
engines that fall within the confines of the program
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Objective: • To inform fleet managers, fleet operators, and the general public of vehicle related policies
and activities and to provide general information regarding vehicles, engines, technologies, emissions, best practices, etc.
Brief Description: • Labelling and information policies refer to a broad range of initiatives, such as vehicle
specific labelling (e.g. fuel consumption ratings), technology verification labelling and environmental and performance test results.
• This option also includes developing guidance documents and action plans for fleets. • This type of policy is generally designed to promote awareness or guide fleet management
practices. Target Pollutant Type: • Air pollutants
Target Pollutants: • Technology labelling and performance testing typically
target PM, NOx, VOCs, CO, air toxics • Greenhouse gases • Vehicle labelling and guidance documents typically target
GHGs Authority Jurisdiction: • Municipal – Develop and implement programs; enforcement as applicable • Provincial/Territorial – Develop and implement programs; enforcement as applicable • National – Develop and implement programs; enforcement as applicable Method of Compliance and Enforcement: • Labelling Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop and implement the programs On-road examples: • Natural Resources Canada – FleetSmart • Transport Canada – ecoTechnology for Vehicles program • Town of Oakville – Sustainable Green Fleet Guide • City of Toronto – Consolidated Green Fleet Plan 2014 - 2018 • City Hamilton – Green Fleet Action Plan Off-road examples: • Alberta Environment/ Alberta Road Building and Heavy Construction Association – A Guide
to Energy Efficient Best Practices • Boston – Greater Boston Breathes Better • US EPA – National Clean Diesel Campaign
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Option Costs: • Costs depend on the type of initiative. For example, developing a green fleet plan in-house
could be a very low cost, depending on the size of the fleet, complexity of the plan, etc. On the other hand, developing a labelling program for new technologies may involve additional costs, above in-house staff time, such as technology evaluators and third party verification, which could result in higher costs.
• Operating costs depend on the type of initiative. For example, in 2008, US EPA provided $2.7 million in emerging technology grants to four projects in construction, delivery trucks, short and long haul trucks, expediting these technologies through the verification/ certification process under the US EPA National Clean Diesel Campaign. On the other hand, implementing a green fleet plan in-house could be a low cost, depending on the size of the fleet, complexity of the plan, number of initiatives, etc.
Key Benefits: • Labels and guidance documents/plans can potentially have a broad reach in terms of number
of people and types of vehicles. Key Challenges: • Emission reductions may be low if action plans are not implemented. • Labels are intended to inform decisions, but labels may not actually impact decisions and
therefore have a low impact on emission reductions. • Difficult to enforce and maintain good practices.
EVALUATION NOTES
Labelling and information policies (including guidance and action plans) Criteria Eval. Notes References
QUANTITATIVE EVALUATION CRITERIA Air pollutant emission reduction potential per vehicle - PM2.5
N/A / Not evaluated This option is typically structured around education and raising awareness. The objective is to inform fleet managers, fleet operators, and the general public of vehicle related policies and activities and to provide general information regarding vehicles, engines, technologies, emissions, best practices, etc. With the exception of green fleet action plans, information policies do not explicitly target emission reductions and the impact on emissions depends on behaviour change resulting from the initiatives. Green fleet action plans are the exception to this with the common objective of reducing fleet wide fuel use, fuel costs, and emissions. The amount of emission reductions on a per vehicle basis through the use of labelling or action plans cannot be accurately quantified. For general information policies, there is no way to accurately track purchase decisions that occurred as a result of the policies, in addition to what would have been used/purchased without it (the baseline). For action plans, information is often presented at the fleet level and not in adequate detail for a per vehicle evaluation. For example, the City of Toronto notes that they did not have the data to accurately monitor progress on fleet related air pollutants (as a result of their Green Fleet Plan).
(Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010) (City of Toronto, 2014)
Air pollutant emission reduction potential per vehicle - NOX or VOCs
N/A / Not evaluated See above (Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010)
GHG emission N/A / Not evaluated This option is typically structured around education and raising (Bronson Consulting,
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Labelling and information policies (including guidance and action plans) Criteria Eval. Notes References
reduction potential per vehicle - CO2e
awareness. The objective is to inform fleet managers, fleet operators, and the general public of vehicle related policies and activities and to provide general information regarding vehicles, engines, technologies, emissions, best practices, etc. With the exception of green fleet action plans, information policies do not explicitly target emission reductions and the impact on emissions depends on behaviour change resulting from the initiatives. Green fleet action plans are the exception to this with the common objective of reducing fleet wide fuel use, fuel costs, and emissions. The amount of emission reductions on a per vehicle basis through the use of labelling or action plans cannot be accurately quantified. For general information policies, there is no way to accurately track purchase decisions that occurred as a result of the policies, in addition to what would have been used/purchased without it (the baseline). For action plans, information is often presented at the fleet level over multiple years, with changing fleet characterization. For example, the City of Toronto notes that GHG emission reductions in 2011 compared to 1990 were 6%. They also state that over the 2008 to 2011 period, fleet emission reductions were 8% compared to a business as usual scenario. Neither of which capture absolute reductions year to year on a per vehicle basis.
2013) (Cheminfo Services Inc., 2014) (Federation of Canadian Municipalities, 2010) (Federation of Canadian Municipalities, 2010) (City of Toronto, 2014)
Policy/Program costs (Total $ and $/year as available)
Limited Info Implementation: Costs depend on the type of initiative. For example, developing a green fleet plan in-house could be very low to low, depending on the size of the fleet, complexity of the plan, etc. However, these costs are typically not tracked, as the "costs" would be associated with staff time. On the other hand, developing a labelling program for new technologies may involve additional costs, above in-house staff time, such as technology evaluators, third party verification, etc. and could be medium to high. Detailed cost information was not identified during the course of this work. Operating: Costs depend on the type of initiative. For example, implementing a green fleet plan in-house could be low, depending on the size of the fleet, complexity of the plan, number of initiatives, etc. However, these costs are typically not tracked, as the "costs" would tend to be associated with staff time. On the other hand, developing a labelling program for new technologies may involve additional costs, above in-house staff time, such as updating technologies, monitoring verifications, funding technologies, etc. and could be high. For example, in 2008, US EPA provided $2.7 million in emerging technology grants to four projects in construction, delivery trucks, short and long haul trucks, expediting these technologies through the verification/ certification process under the US EPA National Clean Diesel Campaign. Detailed cost information for evaluation was not identified during the course of this work. The information above is provided as an illustrative sample.
(US EPA, 2012)
Vehicle - Capital Costs ($/vehicle)
Low to High In terms of taking action on the information policies: Potential costs to industry are difficult to establish. Labelling and guidance initiatives can cover a wide range of information and costs depend on the type of initiative. For example, implementing the actions in a green fleet plan could be low to high, depending on the initiatives. For example, the City of Toronto's initial Green Fleet Plan 2008-2011 capital cost was $1.277 million, which is not the cost of developing the plan, but the cost of implementing the plan and would include the incremental costs associated with new green technologies.
(City of Toronto, 2014)
Vehicle - Operating Costs ($/vehicle)
Savings In terms of taking action on the information policies: Similar to capital costs, operating costs for the owners/operators depend on the type of initiative. However, if labelling, information policies, or green fleet plans are implemented, the aim is always for savings. This does not always work out, particularly when using new technologies (see notes in negative impacts). As a result, on a per vehicle basis, there may not be savings. However, fleet wide, savings can be expected. For example, the City of Toronto's initial Green Fleet Plan 2008-2011 operating net savings were $1.62 million, which may have included new dedicated staff positions, certifications, audits, etc.
(City of Toronto, 2014)
QUALITATIVE EVALUATION CRITERIA Ease of implementation
Easy to Moderate This depends on the type of initiative. For example, developing a green fleet plan may be conducted in-house in a single department or across departments for government vehicles and would be considered an easy implementation, such as the City of Toronto Consolidated Green Fleet Plan 2014-2018. However, developing a labelling program for new technologies may involve additional
(Bronson Consulting, 2013) (Cheminfo Services Inc., 2014) (Federation of Canadian
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Labelling and information policies (including guidance and action plans) Criteria Eval. Notes References
regulatory hurdles including technology evaluators, third party verification, etc. and would be considered moderate, such as the clean diesel verification under the US EPA National Clean Diesel Campaign.
Municipalities, 2010) (Federation of Canadian Municipalities, 2010) (City of Toronto, 2014)
Ease of complying N/A / Easy Participating in labelling and green fleet initiatives is typically voluntary in nature and therefore does not require compliance. However, when green fleet action plans are adopted, for example, by municipalities, the actions generally become mandatory through other rules, such as procurement policies. These are considered to be easy to comply with, as they are typically integrated into existing processes.
Ease of proving compliance
N/A / Easy See above
Ability to enforce N/A / Easy See above ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Cost/benefit Positive Education programs themselves are inexpensive relative to other
initiatives that can provide the same impact on fuel efficiency improvements. Note acting on the information policies, e.g. purchasing a hybrid bus instead of a conventional diesel bus, can lead to substantially increased upfront costs, but potential long term savings.
(Browning, 2014)
Co-benefits No No co-benefits identified with developing information policies. However, benefits are seen when implementing policies. In terms of taking action on the information policies: Fuel cost savings with increased fuel efficiency.
(City of Toronto, 2014)
Negative impacts No No negative impacts identified with developing information policies. However, care must be taken when implementing policies. In terms of taking action on the information policies: Capital and operating cost premiums of hybrid buses can outweigh actual fuel savings. New technologies and alternative technology vehicles are sometimes only available through small, start-up manufacturers. Purchases made from these types of operations increases the risk of bankruptcy and resulting lack of access to warranty provisions or repairs. Also, making ones' own modifications to OEM vehicles can void the warranty. These are considered high risks for risk adverse government agencies.
(City of Toronto, 2014) (Willing, 2012)
4.2. Financial Incentives/Disincentives
4.2.1. Financial incentives
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and
engines
Target Vehicles: • Depends on the financial incentive, but may target
specific vehicles, such as on-road higher emitting, older diesel vehicles, or may be more broadly applied to all diesel vehicles
Objective: • To provide financial incentives to encourage the uptake of less polluting, newer vehicles,
engines or technologies or to encourage behaviour that saves fuel and reduces emissions. Brief Description: • Financial incentives typically include rebates, grants, loans, and tax breaks. They are most
commonly used for voluntary or mandatory retrofit/upgrade and scrappage programs.
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• Financial incentives also include cash or other financial benefits provided as part of award and recognition programs for corporate fleets to encourage fuel savings and emission reduction through behaviour changes such as idling reduction and limitations on speed.
Target Pollutant Type: • Depends on the option category that the
financial incentive is being applied to
Target Pollutants: • Depends on the option category that the
financial incentive is being applied to Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs • National – Develop and implement programs Method of Compliance and Enforcement: • Depends on the option category that the financial incentive is being applied to. Cost Bearer(s): • Single funder or shared • Public or private sector – Governments develop the programs; Governments and
owners/operators may share the costs (through incentives, grants, rebates, etc.) On-road examples: • Alberta Climate Change Central (C3) – Trucks for Tomorrow • California Air Resources Board (CARB) – PLACE (Providing Loan Assistance for
California Equipment) • Manitoba – “GrEEEn” Trucking Program • Transport Canada – ecoFreight Program • US EPA – SmartWay Finance Clean Diesel Program • Québec - Écocamionnage Program – freight programQuébec – Carbon Tax/Carbon Market Off-road examples: • Pennsylvania – Idle Reduction Loans • Arizona – Clean Fuel Contracts for Heavy Duty Equipment • Georgia – Heavy Duty Emissions Reduction Grant Program • US EPA – Clean Construction and the Construction Equipment Rebate Program Option Costs: • Depends on the type, scale, design and uptake of the program. Key Benefits: • Leverages non-government spending, stimulates individual investment and private lender
partnerships (Treasury Board of Canada Secretariat, 2009). • Helps to accelerate the advancement and uptake of newer technologies. • Facilitates the implementation of emission reduction projects that would otherwise not have
occurred.
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Key Challenges: • Managing “free-ridership” for incentives • Coordinating initiatives and regulations • Risk of purchase price inflation to boost rebates. EVALUATION NOTES Due to the range of policies and programs that financial incentives can apply to, only a few of the evaluation criteria were applied here. ‘Financial incentives’ are not considered to be a certain type of option that can be evaluated in the same manner as the other options. Rather, financial incentives can apply to any type of the other options.
Financial incentives Criteria Eval. Notes
QUALITATIVE EVALUATION CRITERIA Ease of complying Difficult Financial incentives typically require proof of meeting the requirements of the
program and may require additional, long term efforts to comply with follow-up monitoring and evaluation requirements.
Ease of proving compliance
Easy Financial incentive programs tend to explicitly and clearly articulate the requirements of the program, including how to prove compliance (e.g. photos of an engine with holes drilled through it to ensure that the engine will not be used elsewhere) or meet requirements through verified technologies, eligible vehicles, etc.
Ability to enforce Easy Owners/operators will generally have to report to the financial incentive provider to prove compliance/eligibility and may have to provide follow-up monitoring and evaluation information (depending on the program).
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Co-benefits Yes Leverage additional (non-government) investment, higher or quicker turnover
of older vehicles, accelerates advancement and uptake of newer technologies.
Negative impacts No None identified
4.2.2. Financial disincentives
PROFILE Applicable to: • On-road heavy duty diesel vehicles • Off-road diesel vehicles and
engines
Target Vehicles: • Depends on the financial disincentive, but may
target specific vehicles, such as on-road higher emitting, older diesel vehicles, or may be more broadly applied to all diesel vehicles
Objective: • To provide financial disincentives to discourage the continued use of more polluting, older
vehicles, engines or technologies or to encourage reductions in fuel use. Brief Description: • Financial disincentives are less common, but may include taxes on diesel fuel or charges or
fees on fleet vehicles and use. Disincentives are generally designed to encourage an overall reduction in fleet fuel consumption by increasing fuel costs.
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Target Pollutant Type: • Depends on the option category that the
financial disincentive is being applied to
Target Pollutants: • Depends on the option category that the
financial disincentive is being applied to Authority Jurisdiction: • Municipal – Develop and implement programs • Provincial/Territorial – Develop and implement programs Method of Compliance and Enforcement: • Depends on the option category that the financial disincentive is being applied to. Cost Bearer(s): • Single funder • Public sector – Governments develop, implement and enforce the programs;
Owners/operators pay the fines On-road examples: • Edmonton, AB - Fuel Sense Program • British Columbia – Carbon Tax • European Union – Low Emission Zones Option Costs: • Depends on the type, scale, design and enforcement of the program. Key Benefits: • Helps to accelerate the advancement and uptake of newer technologies. Key Challenges: • Public acceptance and credibility for disincentives • Coordinating initiatives and regulations. EVALUATION NOTES Due to the range of policies and programs that financial disincentives can apply to, only a few of the evaluation criteria were applied here. ‘Financial disincentives’ are not considered to be a certain type of option that can be evaluated in the same manner as the other options. Rather, financial disincentives can apply to any type of the other options.
Financial disincentives Criteria Eval. Notes
QUALITATIVE EVALUATION CRITERIA Ease of complying N/A Financial disincentives do not require compliance, but aim to discourage certain
behaviours and use of older vehicles, technologies, etc.
Ease of proving compliance
N/A See above
Ability to enforce Easy Financial disincentives will often be integrated into existing systems, such as taxes or operating charges.
ADDITIONAL EVALUATION CRITERIA IF/AS INFORMATION IS AVAILABLE Co-benefits Yes Higher or quicker turnover of older vehicles, accelerates advancement and uptake
of newer technologies
Negative impacts No None identified
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Chapter Five: Case Studies This Chapter presents five case studies highlighting various policy and program options discussed and assessed in this report. The case studies include: • Case study #1 – Connecticut Clean Air Construction Initiative • Case study #2 – British Columbia Diesel School Bus Retrofit Program • Case study #3 – Transport for London Low Emission Zone • Case study #4 – Metro Vancouver Non-Road Diesel Engine Emission Regulation Bylaw • Case study #5 – California In-Use Off-Road Diesel Vehicle Regulation These case studies were selected to illustrate a variety of initiatives, including: mandatory retrofit/upgrade/replacement regulations; geographic operating restrictions; and vehicle emission standards/fleet rules for in-use fleet. They were also selected to represent both on- and off-road options. Case Study #1 Connecticut Clean Air Construction Initiative Program Title: Connecticut Clean Air Construction Initiative (on- and off-road example) http://www.i95newhaven.com/commute/clean_air.aspx Jurisdiction: State – State of Connecticut, Connecticut Department of Transportation (CTDOT) Objective and Description: The Connecticut Clean Air Construction Initiative was part of a pilot emissions reduction program for the State of Connecticut. The initiative operated from 2001 to 2012. The objective was to help improve air quality in Greater New Haven by implementing methods to reduce emissions during the I-95 New Haven Harbor Crossing (NHHC) Corridor Improvement Program. Equipment used on highway contracts was subject to the initiative. In October 2000, the CTDOT formed an air quality working group. The working group investigated the costs and benefits associated with implementing a diesel emission control program. It was decided that the program would combine technology solutions with inspection of highway diesel vehicles. Diesel oxidation catalysts and clean fuels were selected as they were considered to be the most widely accepted technology and fiscally responsible emission reduction options25. Three informational meetings were held in August and September, 2001 to introduce the program to area contractors. These meetings were focused on clean fuels and equipment retrofits
25 Center for Environmental Excellence by AASHTO, Air Quality Case Studies http://environment.transportation.org/environmental_issues/air_quality/case_studies.aspx
Photo Source: Connecticut Department of Transportation
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(diesel oxidation catalysts). Clean fuel vendors and equipment manufacturers attended and addressed concerns over equipment maintenance and warranties; however under the program, no adverse operational problems or maintenance costs were reported for construction equipment retrofitted with diesel oxidation catalysts26. The initiative required all contractors and sub-contractors to comply with the following: • Emission control devices and/or clean fuels required for diesel powered construction
equipment with engine horsepower (hp) ratings of 60 hp and above that are on the project or assigned to the contract for more than 30 days.
• Truck staging zones to be established for diesel powered vehicles waiting to load or unload materials. The zones to be located in areas where diesel emissions will have the least impact to adjacent workers/entities as well as the general public.
• Idling time limited to 3 minutes for delivery and dump trucks as well as other diesel powered equipment (some exceptions apply). • All work conducted in a manner that ensures there are no harmful effects to adjacent sensitive receptors (such as schools, hospitals, daycares and elderly housing). CTDOT responsible for designating sensitive receptors. • Diesel-powered engines located away from fresh air intakes, air conditioners and windows.
The notice to contractors was placed in the bid package as a requirement and wording was designed to allow for future changes in technology. The construction contractor was responsible for developing a diesel emissions mitigation plan if work was to be performed within 50 feet of sensitive receptors. The mitigation plan had to be approved before construction started and had to address the control of diesel emissions from all diesel powered construction equipment on the site. The program was a collaboration between the following entities: • Connecticut Department of Transportation (CTDOT) • Connecticut Department of Energy and Environmental Protection • Northeast States for Coordinated Air Use Management • Connecticut Department of Motor Vehicles
26 I-95 New Haven Harbor Crossing Corridor Improvement Program, Connecticut Clean Air Construction Initiative http://www.i95newhaven.com/commute/clean_air.aspx
Photo Source: Connecticut Department of Transportation
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• Connecticut Construction Industries Association CTDOT targeted both on- and off-road vehicles and equipment on Department construction sites located in sensitive air quality areas, such as New Haven County. Target Vehicles: • On-road and non-road construction equipment used in Department construction projects. Year(s) of Operation: The initiative operated from 2001 to 2012 (discontinued on September 10, 2012). Projects started prior to this date continued to retrofit construction equipment per the specifications27. Method of Compliance and Enforcement: Initial and monthly reporting by the contractors was required. Contractors had to provide a list of non-road diesel powered construction equipment prior to the start of construction. The list had to include the equipment that was to be retrofitted and/or use clean fuels, as well as the equipment number, type, make, and contractor/sub-contractor name. Information on the emission control device make, model and US EPA verification and/or type and source of fuel had to be included in the initial report as well. Monthly reporting was required during construction and had to include certified copies of clean fuel delivery slips and an indication of which vehicles received the clean fuel, as well as information on additions or deletions of non-road diesel equipment, and information on any newly retrofitted construction equipment. CTDOT developed a tracking system that tracked submittals of the equipment on site. The tracking system included information related to when the equipment was retrofit as well as any problems related to installation or sourcing (such as back order). This tracking system was very helpful and allowed CTDOT to easily provide updates at monthly meetings as well as proper documentation and communication to avoid possible non-compliance issues28. Non-compliance was enforced by means of issuing a 24 hour notice to the contractor. The notice to the contractor indicated that they must either improve the offending vehicle or remove it from 27 Personal correspondence with James Kocaba, Connecticut Department of Transportation, December 2014. 28 Personal correspondence with James Kocaba, Connecticut Department of Transportation, December 2014
Photo Source: Connecticut Department of Transportation
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the project. If the contractor did not comply, payments could be withheld for the work carried out on any item(s) on which the equipment was utilized, for the duration of the time period that the equipment was out of compliance. Over the course of six years, CTDOT issued approximately 10 non-compliance notices however they did not need to withhold any payments as contractors removed the equipment after non-compliance notices were issued29. There were also periodic site inspections. Projects were inspected once per week or once every two weeks30. Over one hundred pieces of non-road construction equipment were retrofit with diesel oxidation catalysts as a result of the initiative31. Results (emission reductions): Estimates of emission reductions during the I-95 NHHC Corridor Improvement Program32: • 20 tons/year for carbon monoxide • 2 tons/year for fine particulate matter (due to clean fuels or oxidation catalysts) • 8 tons/year for hydrocarbons (due to oxidation catalysts only) Costs: Costs for equipment retrofits or using clean fuels were included in the cost of the contract, as bid by each contractor. Having the retrofit costs included in the general cost of the contract likely increased overall bid prices and financial burden to the public, however program staff could not speak to specific incremental cost estimates or costs to develop and run the program33. Key Benefits and Challenges: • Real emission reductions were achieved during this 12-year construction project through a
populated corridor, and the equipment upgrades undertaken for this project would be expected to result in additional emission reductions on future projects.
• Over half of the timeframe of the program, compliance testing identified only 10 incidences of non-compliance, which resulted in removal of the equipment.
• Made use of established US EPA list of verified retrofit technologies. • Program staff believes that the initiative was valuable, successful and beneficial to the urban
neighbourhoods and construction workers in New Haven. Lessons Learned: At the onset of designing a program like this it is beneficial to invite as many of the major players as possible as they will add insight. It is important to realize that compromise will be required by all parties. A series of informational meetings helped the program designers/implementers accomplish their objectives and they learned that partners need to work
29 Personal correspondence with James Kocaba, Connecticut Department of Transportation, December 2014 30 Personal correspondence with James Kocaba, Connecticut Department of Transportation, December 2014 31 I-95 New Haven Harbor Crossing Corridor Improvement Program Connecticut Clean Air Construction Initiative http://www.i95newhaven.com/commute/clean_air.aspx 32 I-95 New Haven Harbor Crossing Corridor Improvement Program, Connecticut Clean Air Construction Initiative http://www.i95newhaven.com/commute/clean_air.aspx 33 Personal correspondence with James Kocaba, Connecticut Department of Transportation, December 2014.
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together to inform and educate contractors. The most positive aspect of initiating the program was the creation of an air quality working group. The working group met every six weeks for almost one year before the bid documents had to be ready for the first contract. After the start of construction, it is important to keep the communication network going; partners will be able to help resolve problems as they arise and evolve. It is important also to continue to research new technologies that may be relevant and approved. It is important to continue to track accomplishments and any glitches that may arise as this can help modify procedures to improve the operating procedures. It was critical to include the requirement for emission control equipment in the contract’s bid package34.
34 Weaver, Donna. March 2006. Connecticut Department of Transportation. Connecticut Clean Air Construction Initiative. http://www.epa.gov/region1/eco/gb3/pdfs/CT-DOT-Boston-3-06.pdf
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Case Study #2 British Columbia – Diesel School Bus Retrofit Program Program Title: British Columbia – Diesel School Bus Retrofit Program (on-road example) http://www.bcairquality.ca/topics/schoolbus/ Jurisdiction: Province – British Columbia Objective and Description: The British Columbia (BC) government developed the BC Air Action Plan, released in June 2008, to help reduce air pollution from all sources, including transportation, industry and communities. The plan set out 28 actions to reduce air pollution and committed $28.5 million over three years to implement the plan, in partnership with industry, communities, and other levels of government. Under Clean Transportation, the BC Air Action Plan highlighted 9 actions to make heavy duty vehicles cleaner. One of these (#7) was to address school bus emissions. The BC government planned to invest in clean energy school buses, including the purchase of 80 new school buses (province-wide) and the retrofit of all existing school buses with clean diesel technologies/emission reduction devices (e.g. diesel oxidation catalyst (DOC) filters)35. The objective of the Diesel School Bus retrofit Program was to reduce particulate matter (PM) emissions from school buses that are owned by school-districts through retrofits. Only US EPA and/or CARB certified devices were eligible and included36: • Exhaust retrofit devices – diesel oxidation catalyst (DOC) or flow-through filter (FTF) • Engine retrofit – closed-crankcase ventilation (CCV). In addition to technical compatibility between the retrofit device and bus engine, the type of retrofit device for each bus was to be determined based on potential to reduce exposure of occupants to PM and potential for largest emission reductions possible over the lifetime of the bus. Target Vehicles: School buses Year(s) or Operation: Actions were intended to be underway by 2009 and the program was completed in 201037.
35 BC Air Action Plan http://www.bcairsmart.ca/docs/bcairactionplan.pdf 36 BC Air Quality, Diesel School Bus Retrofit Program http://www.bcairquality.ca/topics/schoolbus/ 37 Personal communication with Glen Okrainetz, Manager of Ambient Air Quality Program, BC Ministry of the Environment, December 19, 2014
Photo Source: BC Air Quality, Diesel School Bus Retrofit Program
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Method of Compliance and Enforcement: The program was only for publically owned school buses. A request for proposals was issued for provision of the technology and three service providers were contracted by the province to install the technologies38. The service providers worked directly with the school boards to determine school bus eligibility, appropriate technology for each bus/engine, etc. and to install the retrofit technologies. Results (emission reductions): Emission reduction results were not measured or estimated for the program. However, 406 installations were completed, including39: • 193 DOCs • 167 CCVs • 46 level 2 devices (data logging equipment). Costs: The government planned to invest more than $10 million through the Ministry of Education for the 80 new buses and retrofits of existing buses40. With respect to the diesel school bus retrofits only, the budget for completing the retrofit of all school-district-owned buses was $1.2 million over three fiscal years41 and vendor contracts were issued for $0.655 million42. Key Benefits and Challenges: In addition to reducing emissions to the atmosphere, retrofitting school buses targets exposure reduction in a population sensitive to the health effects of air pollutants. Exposure studies have shown that even under idling conditions, on-board exposure to pollutants can be significantly reduced via retrofitting43. Another benefit is that diesel emissions around the school, i.e. in the schoolyard, would also be reduced, affecting exposures of children who are not on-board the bus. As documented in a 2010 report, over 400 emission control devices had been installed and there were no complaints or negative feedback about operational or maintenance issues44. Lessons Learned:45 One of the key lessons learned from the diesel school bus retrofit program was to know your engines. For BC, this meant engaging an expert on the technologies, allowing time for data 38 BC Ministry of Environment, Diesel Retro-fit Programs in British Columbia, a presentation for the Green Financing Mechanisms Workshop, January 29, 2013 39 BC Ministry of Environment, Diesel Retro-fit Programs in British Columbia, a presentation for the Green Financing Mechanisms Workshop, January 29, 2013 40 BC Air Action Plan http://www.bcairsmart.ca/docs/bcairactionplan.pdf 41 BC Air Quality, Diesel School Bus Retrofit Program http://www.bcairquality.ca/topics/schoolbus/ 42 BC Ministry of Environment, Diesel Retro-fit Programs in British Columbia, a presentation for the Green Financing Mechanisms Workshop, January 29, 2013 43 Clean Air Partnership. Healthy School Buses: Parent & Teacher Factsheet. http://healthyandsustainable.files.wordpress.com/2011/09/factsheet-parent-teacher-eng.pdf 44 Kim Perrotta. School Buses, Air Pollution & Children’s Health: Follow-up Report. Prepared for the Clean Air Partnership in collaboration with the Ontario Public Health Association (OPHA). Toronto, Ontario: 2010. http://www.cleanairpartnership.org/files/School%20Bus%20FINAL%20Oct%201.pdf 45 BC Ministry of Environment, Diesel Retro-fit Programs in British Columbia, a presentation for the Green Financing Mechanisms Workshop, January 29, 2013
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logging requirements, and allowing flexibility in the field to adjust device selection based on each individual engine. Another lesson learned was to know your clients. The province worked with the bus maintenance supervisors, including working with them to identify the timing of the installations. Finally, the province suggests knowing your vendor through frequent communications, having clear expectations and maintaining good documentation. Depending on the size of the project, it is also helpful to use a dedicated employee or hired contractor to monitor the project.
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Case Study #3 Transport for London – Low Emission Zone Program Title: Transport for London – Low Emission Zone (on-road example) https://www.tfl.gov.uk/modes/driving/low-emission-zone Jurisdiction: Municipality – City of London, United Kingdom Objective and Description: Low emission zones (LEZs) are common in European countries and are implemented to improve air quality. There are currently 11 countries in Europe that have implemented LEZs. Low emission zones are areas where vehicle access is restricted based on emissions, typically targeting particulate matter (PM) and nitrogen dioxide (NO2). Each jurisdiction is responsible for
the design of their own LEZ, but all affect heavy duty goods vehicles, most buses and coaches, and some also affect vans, cars and motorcycles. LEZs typically operate 24 hours a day, year round. Most existing LEZs use manual enforcement mechanisms, such as visual inspection of window LEZ stickers by company inspectors, parking officers, or police officers at routine roadside checks46. The London LEZ, which covers most of Greater London (approximately 1600 km2), operates 24 hours a day, 365 days a year. The London LEZ restrictions are based on
Euro vehicle emission standards. For each day that a vehicle is driven (or parked) within the zone without meeting the emissions standards, a daily charge is applied. The charge is based on the type of vehicle. The London LEZ has been in place since February 4, 2008 and is being implemented in stages. As of January 3, 2012, the newest compliance requirements are as follows: • Euro IV PM emission standard for trucks over 3.5 tonnes (GVWR) and buses and coaches
over 5 tonnes (GVWR) • Euro III PM emission standard for large vans from 1.205 tonnes (unladen) to 3.5 tonnes
(GVWR) and minibuses weighing 5 tonnes or less (GVWR)47
46 Urban Access Regulations in Europe, Overview http://urbanaccessregulations.eu/what-are-lezs 47 Urban Access Regulations in Europe, London http://urbanaccessregulations.eu/countries-mainmenu-147/united-kingdom-mainmenu-205/london
Photo Source: Transport for London, Low Emission Zone
Photo Source: Transport for London, Low Emission Zone
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• Eligible retrofits (e.g. fitting an approved filter to the vehicles exhaust) that have been certified (under Low Emissions Certificate certification scheme) can also be used to bring a vehicle into compliance48.
Starting in 2015, Transport for London buses will have to meet stricter NOx emission standards, by meeting Euro VI emission standards and use of hybrid buses together with Selective Catalyst Reduction (SCR) system retrofits49. Furthermore, consultations are underway to introduce an ultra low emission zone (ULEZ), including restrictions for vehicles that are not currently impacted and additional restrictions for those that are. Restrictions under consideration for ULEZ 2020 are: • Euro 3 emission standards for motorcycles, mopeds, etc. • Euro 4 emission standards for petrol cars, vans and minibuses • Euro 6 emission standards for diesel cars, vans and minibuses • Euro VI emission standards for trucks, buses and coaches • Transport for London double-decker buses would be hybrid, and all single deck buses would
be zero emission vehicles • And for 2018, taxis and private hire vehicles would be required to be zero emission vehicles
(and taxi age limit (for all taxis across London) reduced from 15 to 10 years)50. Target Vehicles: • Commercial and private on-road vehicles are included in the London LEZ. • Specific vehicles include diesel trucks over 3.5 tonnes, buses, coaches, large vans, and
trucks), refuse collection vehicles, snow plows, gritters, road sweepers, concrete mixers, tippers, removal trucks, fire engines, extended-cab dual purpose pickup trucks, some light duty vehicles, motor caravans, ambulances, and large hearses (over 2.5 tonnes).
• Cars, motorcycles, and small vans (fewer than 1.205 tonnes unladen) are not included. • Vehicles designed mainly for off-road use (e.g. agricultural equipment, mobile cranes, road
and building construction machinery, etc.) are exempt. • Historic vehicles (built before 1973) and vehicles operated by the Ministry of Defence are
also exempt51. Year(s) of Operation: February 2008 to present
48 Transport for London, Ways to meet the standards https://www.tfl.gov.uk/modes/driving/low-emission-zone/ways-to-meet-the-standards 49 Urban Access Regulations in Europe, London http://urbanaccessregulations.eu/countries-mainmenu-147/united-kingdom-mainmenu-205/london 50 Urban Access Regulations in Europe, London http://urbanaccessregulations.eu/countries-mainmenu-147/united-kingdom-mainmenu-205/london 51 Urban Access Regulations in Europe, London http://urbanaccessregulations.eu/countries-mainmenu-147/united-kingdom-mainmenu-205/london
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Method of Compliance and Enforcement: All vehicles travelling within the LEZ must register with Transport for London. Enforcement is automated through the use of fixed and mobile cameras that read vehicle license plates, which are then checked against the registration database. The database indicates whether the vehicle meets the emissions standards, has paid the daily charge, or is exempt (or registered for a discount). If the vehicle is found to be out of compliance (i.e. does not meet any of those three checks), a penalty charge may be applied (a warning letter is issued for the first offence), the amount based on the type of vehicle. Daily charges can be paid in advance, on the day of travel, or up to one business day after travel within the LEZ. Daily charges range from £100 to £200. If the daily charge is required and not paid, a Penalty Charge is issued to the registered owner of the vehicle. The penalty charges range from £500 to £1000 (with the option to pay 50% of the charge if paid within the first 14 days)52. The enforcement process escalates from a warning letter to the penalty charge notice, to a charge certificate and then order for recovery and finally, a bailiff. The charges increase with each step53. Results (emission reductions): • Rate of fleet turnover for the affected vehicle classes increased when the LEZ was first
introduced, resulting in an extra 20% of vehicles replaced by lower-emission vehicles. The London LEZ catalysed a reduction in non-compliant vehicles and impacted the types of vehicles used within the zone54.
• Studies indicate that within the first 5 years of the LEZ, ambient air quality measurements of PM within the zone dropped 2.46 – 3.07% compared to a PM reduction of only 1% for areas just outside of the LEZ. No marked differences were found for NOx concentrations inside and outside the LEZ55.
• For the year 2008 (which includes phase 1 and 2 of the implementation), observed data indicated a 3.7% savings of PM2.5 for road traffic exhaust emissions and a 2.4% reduction to total road traffic emissions in London. Observed data indicated a 2% savings of NOx for road traffic exhaust emissions56.
• Additional modelling data suggests that the emissions savings result in average concentration reductions of NO2 by 0.12 µg/m3; of PM2.5 by 0.03 µg/m3; and of black carbon by 40-50%57
52 Urban Access Regulations in Europe, London http://urbanaccessregulations.eu/countries-mainmenu-147/united-kingdom-mainmenu-205/london 53 Transport for London, Enforcement Process https://www.tfl.gov.uk/modes/driving/low-emission-zone/penalty-charges/enforcement-process 54 “Science for Environment Policy”: European Commission DG Environment News Alert Service, edited by SCU, The University of the West of England, Bristol http://ec.europa.eu/environment/integration/research/newsalert/pdf/338na3_en.pdf 55 Ellison, R.B., Greaves, S.P., & Hensher, D.A. (2013). Five years of London’s low emission zone: Effects on vehicle fleet composition and air quality. Transportation Research Part D: Transport and Environment, Vol. 23, pp. 25-33. http://www.atrf.info/papers/2012/2012_Ellison_Greaves_Hensher.pdf; http://www.worldtransitresearch.info/research/4831/ 56 Transport for London (2010). Travel in London: Report 3. https://www.tfl.gov.uk/cdn/static/cms/documents/travel-in-london-report-3.pdf 57 Urban Access Regulations in Europe, Impact of LEZs http://urbanaccessregulations.eu/low-emission-zones-main/impact-of-lezs
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(between 2006 and 2009). This is an average across Greater London. In the more heavily polluted areas, PM10 reductions reached up to 0.5 µg/m3, whereas NO2 reductions peaked up to 0.16 µg/m3 a small distance away from major roads (reflecting the NOx/NO2 conversion dynamics)58.
• London’s LEZ has helped to improve air quality in Greater London, but there remains the challenge to meet air quality limits set by the European Union (EU), in particular, those for NOx levels59. The ULEZ is designed to further target NOx emissions60.
Costs: Implementation costs for the LEZ when first introduced (February 2008) were £36.8 million. This included costs such as marketing, legal and consultancy fees, and consultation and impacts monitoring, as well as costs of the required infrastructure to support the scheme. Vans and minibuses were rolled into the scheme in January 2012, when emissions standards were tightened. For this change, start-up costs were £8.6 million61. Annual operating costs are shown below in millions of pounds sterling (£):62 2009 2010 2011 2012 2013 2014
8.2 4.9 4.9 5.9 5.0 5.0 It is interesting to note that the capital costs for the ULEZ are estimated to be £30 million, including policy development, consultation, marketing, and enhancing road user charging operations. The annual operating costs of the ULEZ are estimated to be £6 million, including handling enquiries, registrations, payments, as well as enforcement and website maintenance63. Key Benefits and Challenges: • Improved air quality. Overall emission levels and absolute air quality concentrations are only
modestly impacted by this type of initiative. However, by successfully reducing air pollutant emissions from heavy vehicles, the LEZ contributes to reducing exceedances of EU air quality targets, particularly PM.
• Associated health impacts. The targeted emissions (NOx and PM) have adverse impacts on human health. For example, NO2 causes inflammation of the airways and long-term exposure increases the symptoms of bronchitis in vulnerable populations. Long-term exposure to PM increases the risk of developing cardiovascular and respiratory diseases. Furthermore, diesel exhaust has been classified as carcinogenic, as exposure has been associated with an
58 Transport for London (2010). Travel in London: Report 3. https://www.tfl.gov.uk/cdn/static/cms/documents/travel-in-london-report-3.pdf 59 Jacobs U.K. Limited, Ultra Low Emission Zone Integrated Impact Assessment, October 2014 https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia-report_final.pdf 60 Transport for London, Ultra Low Emission Zone consultation, Supplementary information, October 2014 https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-supplementary-information---final-291014.pdf 61 Personal correspondence with Simon Scarfe, Strategy Planner, Transport for London, January 2015 62 Personal correspondence with Simon Scarfe, Strategy Planner, Transport for London, January 2015 63 Transport for London, Ultra Low Emission Zone consultation, Supplementary information, October 2014 https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-supplementary-information---final-291014.pdf
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increased risk for lung cancer. Reduced emissions and therefore reduced exposure, especially in dense urban areas, has a positive impact on human health.
• Meeting EU air quality limits. Annual average concentrations of PM10 and PM2.5 are within the legal limits for the City of London. However, health benefits can still be realized by further reducing PM concentrations. The challenge with respect to legal implications still remains for NO2, the concentrations of which still exceed the EU legal limit64.
• The compliance rate is very high; however, with respect to the challenge of collecting penalty charges, Transport for London follows a multi-step process to provide adequate opportunity for drivers to pay the penalty charges. The last step for vehicles registered in Great Britain is use of County Court certified bailiffs. For vehicles registered outside of Great Britain, recovery of unpaid penalties is undertaken by a European debt recovery agency.
Lessons Learned: • To facilitate smooth implementation, prepare and set up operational procedures and systems
well in advance of the launch date. For example, London had a number of procedures, facilities, and infrastructure already in place, such as vehicle operator certification, and call centre and processes to handle public complaints/enquiries65.
64 Transport for London, Ultra Low Emission Zone consultation, Supplementary information, October 2014 https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-supplementary-information---final-291014.pdf 65 Transport for London, London Low Emission Zone, Impacts Monitoring, Baseline Report, July 2008 https://www.tfl.gov.uk/cdn/static/cms/documents/lez-impacts-monitoring-baseline-report-2008-07.pdf
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Case Study #4 Non-Road Diesel Engine Emission Regulation Bylaw Program Title: Non-Road Diesel Engine Emission Regulation Bylaw No. 1161, 2012 (off-road example) http://www.metrovancouver.org/services/Permits-regulations-enforcement/non-road-diesel/Pages/default.aspx Jurisdiction: Municipality – Metro Vancouver Objective and Description: In order to reduce PM emissions within its geographical boundaries, Metro Vancouver promulgated the Non-Road Diesel Engine Emission Regulation in 2012. The regulation requires that older non-road diesel engines operating within Metro Vancouver pay a registration fee, with the goal of equipment owners replacing older engines with newer ones. Specifically, the regulation applies to anyone who discharges or allows the discharge of any air contaminant into the environment from Tier 0 or Tier 1 non-road diesel engines (as defined by the US EPA). Operators of Tier 1 or Tier 0 engines must register their engines, registration fees depend upon how much their engines pollute, and for how long the engine is being registered for. Registrants can register their engines for use (and therefore pay fees) annually, monthly, or daily. Additionally, low use vehicles can register under an alternative (and lower cost) registration fee system. Registration fees are based on the number of days the engine is registered for use, the horsepower of the engine, and the year the engine was produced. The per horsepower element of the fee structure is provided in the table below.
Fee reductions are applied to engines for approved emission reduction measures. Specifically, 80% of the registration fees paid by an equipment owner to Metro Vancouver over the prior three years are returned to the owner if the equipment is retired or retrofit to a minimum Tier 2 level.
The following case study information is extracted (with permission) directly from the following report: Cheminfo Services Inc., Jurisdictional Review of Off-Road Source Emission Reduction Strategies and Best Practices, prepared for Canadian Council of Ministers of the Environment, Mobile Sources Working Group, April 17, 2014 [Confidential Report].
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The fee reductions are based primarily on the tier of the motor involved and the percentage of reduction in the particulate matter emission rate as a result of the measure. Stakeholders include owners/operators of off-road diesel engines in Metro Vancouver, and engine/retrofit equipment manufacturers. Target Vehicles: Off-road diesel vehicles and engines Year(s) or Operation: Regulation was brought into force in 2012 Method of Compliance and Enforcement: The regulation uses registration fees on Tier 0 and Tier 1 vehicles (based on horsepower and the amount of time the vehicle will be registered for) as the economic instrument, and 80% of these fees can be recouped if a retrofit (or retirement) is completed for the engine within three years. Results (emission reductions): No information that discusses emissions savings or program costs specifically for off-road vehicles was found. The structure of this regulation received support by stakeholders. It is estimated that the Regulation resulted in 25% of the Tier 0 off-road vehicles in Metro Vancouver being retired over the first two years of the regulation. Costs: No information that discusses emissions savings or program costs specifically for off-road vehicles was found. Key Benefits and Challenges: Gaps or Disadvantages – The emissions standard has the potential to be relatively expensive for owners of old and high polluting equipment, but does not provide any funding mechanism that can be used to offset replacement/retrofit costs. Two main challenges regarding the regulation have been identified. One of these challenges lies in ensuring off-road engine owners do not re-sell (or simply move) their Tier 0 engines after claiming vehicle retirement and collecting the 80% of their registration fee rebate. The other challenge lies in enforcing the low-use element of the regulation. Benefits/Innovation – This bylaw is very innovative. The initiative specifically targets higher polluting engines with higher registration costs, and eases those costs depending upon how much the engine is used, and the application of emissions control technology. This approach encourages the use of lower polluting engines, and also would encourage phasing out engines gradually (registering the engines for shorter periods of time would be much less costly), which has the potential to limit or reduce up front capital costs for fleet owners. Additionally, the standard targets engines based on horsepower and tier, a combination that should assign the highest registration costs to the engines that pollute the most, while allowing engines that pollute less to continue to be run. The stepped nature of the registration costs (increasing with time) will also put increasing pressure on owners to replace high polluting engines over time. Lastly, the
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Metro Vancouver website contains a tier/fee calculator and online tools for registering engines that likely make the registration process easier for off-road diesel engine owners/operators. Another key benefit would be that they obtained support from stakeholders. Also, that it targets emissions in the more highly populated region of the province. Lessons Learned: The following factors were considered some of the main reasons why the regulation has been well received: • efficient registration system (online system) • economic instrument as opposed to a ban or requirement (provide encouragement for
businesses to make changes, while still allowing them the flexibility to make decisions that best reflect their interests);
• registration fee structure and return policy (returns 80% of the registration fees paid by an equipment owner to Metro Vancouver over the prior three years if the equipment owner retires or retrofits the vehicle);
• medical community/other stakeholder support and lobbying; and • regulation simplicity and focus (designed to target only the oldest and highest polluting
engines) (focus on Tier 0 and Tier 1 engines helps to keep the regulation more efficient and simple to run).
The success of the regulation highlights the importance of performing extensive research and stakeholder consultation sessions, and leveraging the expertise of multiple sectors, partners, and other regulatory bodies during initiative development.
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Case Study #5 In-Use Off-Road Diesel Vehicle Regulation Program Title: In-Use Off-Road Diesel Vehicle Regulation (off-road example) http://www.arb.ca.gov/msprog/ordiesel/ordiesel.htm Jurisdiction: State Level – California Objective and Description: The In-Use Off-Road Diesel Vehicle Regulation is meant to reduce emissions of oxides of nitrogen (NOx) and particulate matter (PM) from off-road diesel vehicles operating within California. The Off-Road regulation: Imposes limits on idling, requires a written idling policy, and requires a disclosure when selling vehicles; Requires all vehicles to be reported to CARB (using the Diesel Off-Road Online Reporting System, DOORS) and to be labeled; Restricts adding older vehicles into fleets; and Requires fleets to reduce their emissions by retiring, replacing, or repowering older engines, or installing Verified Diesel Emission Control Strategies, VDECS (i.e. exhaust retrofits). The regulation applies to all self-propelled off-road diesel vehicles over 25 horsepower used in California, and most two engine vehicles. This includes vehicles that are rented or leased. Personal use vehicles, vehicles used solely for agriculture, vehicles that are awaiting sale, and vehicles already covered by the Regulation for Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards (Cargo Handling regulation), are exempt. The requirements of the regulation depend upon the size of the fleet being regulated. Fleet size is determined by adding up all of the off-road horsepower under common ownership or control in the fleet. Requirements of the regulation include: • Idling time limited to 5 minutes, and each fleet owner must have a written idling policy • Disclosure for selling vehicles (the seller must provide disclosure of the regulation before
selling a vehicle) • Reporting – completed using DOORS, California’s online reporting tool for the regulation • Labelling – after reporting their vehicles to the California Air Resources Board (CARB) each
vehicle is assigned an Equipment Identification number and must be labelled with that number
• All fleet owners must review and update their fleet information each year and report to CARB annually
The following case study information is extracted (with permission) directly from the following report: Cheminfo Services Inc., Jurisdictional Review of Off-Road Source Emission Reduction Strategies and Best Practices, prepared for Canadian Council of Ministers of the Environment, Mobile Sources Working Group, April 17, 2014 [Confidential Report].
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• As of September 13th, 2013, fleet operators are not allowed to add older vehicles (Tier 0 or Tier 1 depending upon fleet size) to their fleets, bans on adding Tier 2 vehicles to fleets will begin in 2018.
Beyond the requirements above, fleets must also meet certain compliance options (that are changing with time). A fleet must either demonstrate that it meets a particular minimum fleet average for a year, or have completed the Best Available Control Technology (BACT) requirements. Large fleets have compliance deadlines each year from 2014 through 2023, medium fleets each year from 2017 through 2023, and small fleets each year from 2019 through 2028. The fleet average index is an indicator of a fleet’s overall emissions rate, and is based on the fleet’s average NOx emissions which are determined by the horsepower and model year of each engine in the fleet. If the fleet average index is equal to or less than the fleet average target for a given year, the fleet is not required to take further action to reduce emissions from its vehicles. If a fleet cannot, or does not want to meet the fleet average target in a given year, it may instead choose to comply with the BACT requirements. A fleet may meet the BACT requirements each year by turning over or installing a vehicle diesel emission control system (VDECS) on a certain percentage (referred to as the BACT rate) of its total fleet horsepower. ‘Turnover’ means retiring a vehicle, designating a vehicle as permanent low-use (a vehicle used less than 200 hours per year), repowering a vehicle with a higher tier engine, or rebuilding the engine to a more stringent emission standard. ‘Installing VDECS’ means installing the highest level VDECS verified by CARB to reduce PM, or installing a VDECS verified to reduce NOx. In order to fulfill the BACT requirements for large and medium fleets, if a VDECS cannot be installed on a vehicle, then that vehicle must be turned over. However, for small fleets, if a VDECS cannot be installed, that vehicle is exempt from the BACT requirements. The BACT rates for each fleet size are shown the below. Large fleets: 2014: 4.8% 2015 to 2017: 8% 2018 to 2023: 10%
Medium fleets: 2017: 8% 2018 to 2023: 10%
Small fleets: 2019 to 2028: 10%
Target Vehicles: Off-road diesel vehicles operating within the state Year(s) or Operation: The regulation was proposed in 2007 and amended in 2010. Method of Compliance and Enforcement: CARBs Diesel Off-Road On-Line Reporting System (DOORS) is an on-line tool designed to help fleet owners report their vehicle inventories for compliance with the off-road diesel regulation. It is also used by CARB to track compliance of individual fleets with the requirements of the regulation.
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Results (emission reductions): CARB has estimated that NOx emissions would decrease by about 2% in 2014, 13% in 2020 and 17% in 2023 over an unregulated baseline. PM2.5 emissions are similarly estimated to be reduced by 2% in 2014, 16% in 2020, and 21% in 2023. Costs: No information on costs was provided. Key Benefits and Challenges: The strategy which requires vehicle fleets to incrementally lower emissions is innovative and considered a benefit. Challenges included the need to maintain flexibility due to changing economic conditions. This is discussed further under lessons learned. Lessons Learned: CARB conducted a great deal of research to ensure that the In-Use Off-Road Diesel Vehicle Rule was effective at reducing emissions without being too burdensome for industry. As discussed above, however, unforeseen circumstances can require regulatory tools to be flexible, or to change in response to conditions. Utilizing a mandatory on-line registration system is an innovative method of collecting useful data (similar to Metro Vancouver’s online reporting system, discussed above). Potentially, jurisdictions could draft legislation regarding off-road vehicles with a mandatory registration period preceding the development of any retrofit/repowering requirements. This period could be utilized to collect population/use/load data, which could then be leveraged to inform regulatory requirements. Engaging stakeholders in the information collection process by offering credits towards early requirements was important in order to collect the activity data required for an updated emissions inventory. This strategy of offering credits to stakeholders for information collection purposes could be leveraged in support of initiative development. The regulatory amendments CARB has needed to make due to the economic recession have provided a few key “lessons learned” for any initiative development that could require off-road engine owners/operators to retrofit or repower. First, while setting long term targets and structuring an initiative to require accelerating annual retrofit/repower requirements is an appropriate strategy, the targets should ideally be capable of adapting to changing circumstances. The mechanism through which this adaptability could be accomplished is not clear (CARB had to delay regulatory enforcement and re-do their emissions estimates from the ground up), but leveraging stakeholder support (offering credits for information) and utilizing online reporting data sources such as DOORS or Metro Vancouver’s online reporting system (discussed above) could allow a regulatory body to stay ahead of changing circumstances that might otherwise require the suspension of an initiative.
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Second, stakeholder engagement can be an important part of initiative development and enforcement. In the case of the In-Use Off-Road Diesel Regulation, stakeholders conducted an independent study at UC Berkeley which brought the emissions inventory developed in support of the original regulation into question. Then, as described above, stakeholder data (both through survey tools and mandatory online reporting) was leveraged to develop the updated emissions inventory. There are several strategies that could be utilized to encourage stakeholder participation in initiative development.
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Conclusion and Recommendations This document is intended to assist Canadian jurisdictions in reducing air pollutant and GHG emissions from heavy duty on-road and off-road in-use diesel vehicles and engines. By doing so, jurisdictions can also improve air quality and human health by reducing exposure to CACs and toxic substances. The benefits of reducing air pollutants are usually realized at a local scale, whereas the benefits of reducing GHGs are realized globally. The methodology for producing the document was divided into four tasks. The first was to define the different types of policy and program options available to municipal, provincial/territorial and federal jurisdictions for reducing emissions. During this process, 17 policy and program options were defined, under the headings of: vehicles and engines; fuels; general activity; and cross-cutting. The second task was to define criteria in order to evaluate the different options, based mainly on: potential emission reductions; costs; ease of implementation and complying; and the ability to enforce the policy or program. The third task was to carry out the evaluation of the 17 options using these criteria. Finally, the fourth task was to develop recommendations and guidance based on the evaluation process. These are presented below. Policy and program recommendations have been developed to consider what factors would lead a jurisdiction to make one decision over another with respect to the different options. Guidance on the process involves considerations on moving forward with any policy or program decision, including a discussion of what makes a program or policy successful. Policy and program recommendations The recommendations provided below are drawn from the results of the evaluation presented in this document. The selection of options is therefore limited by the extent of the evaluation. They are not intended to definitively suggest policy and program options that should be undertaken for any jurisdiction wishing to reduce emissions from the in-use diesel fleet. As with any document, the intent is to be informative rather than prescriptive. This document is intended to provide key information on a wide variety of policy and program options to aid jurisdictions in delineating options of interest in their context. Each jurisdiction must define their specific problem, and carry out their own detailed analysis to identify the most suitable and cost-effective solution to the problem, specific to their fleet characteristics, vehicle use, (fuelling) infrastructure, available budget, and institutional mandate and organization. The recommendations provided below are intended to inform that process. For details on each policy or program option, including whether they are applicable to municipal, provincial/territorial or federal jurisdictions, please refer to the individual option profiles presented in Chapter Four. The following highlights select program and policy options based on level of impact in terms of emissions reductions and vehicle costs. These recommendations are made independent of other considerations.
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On-road Vehicles
Medium to High Potential for CAC
Reductions (/vehicle)
• Emission control system anti-tampering requirements
• Vehicle emission standards/fleet rules for in-use fleets
•Retrofit/upgrade/replace-ment regulations (mandatory or voluntary)
•Programs to encourage alternative vehicles and technologies
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The following program and policy recommendations are organized by vehicle type. These policy and program options were selected by considering the type of vehicle, typical use for those vehicles and mechanisms for engaging the primary stakeholders. These recommendations are made independent of other considerations. On-road Vehicles
Light heavy duty diesel
Class 2B
Retrofit/upgrade/replacement regulations (mandatory or voluntary) Inspection and maintenance programs Idling restrictions/Idling reduction campaigns Driver training programs Labelling and information policies
Class 3; Class 4; Class 5
Inspection and maintenance programs Programs to encourage use of alternative vehicles and technologies Idling restrictions/Idling reduction campaigns Driver training programs Labelling and information policies Policies and programs on logistics, route optimization and vehicle tracking
Medium heavy duty diesel Class 6; Class 7
Labelling and information policies Vehicle emission standards/fleet rules for in-use fleets Retrofit/upgrade/replacement regulations (mandatory or voluntary) Scrappage programs Programs to encourage use of alternative vehicles and technologies Policies and programs on logistics, route optimization and vehicle tracking Purchasing and right-sizing policies Idling restrictions/Idling reduction campaigns Driver training programs
Heavy heavy duty diesel
Class 8; Class 8B
Retrofit/upgrade/replacement regulations (mandatory or voluntary) Scrappage programs Programs to encourage use of alternative vehicles and technologies Policies and programs on logistics, route optimization and vehicle tracking Idling restrictions/Idling reduction campaigns Use of operating restrictions
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Off-road Vehicles and Engines
Construction Vehicles and Equipment
Examples: Excavators, Cranes, Tractors, etc.
Retrofit/upgrade/replacement regulations (mandatory or voluntary)
Programs to encourage use of alternative vehicles and technologies
Geographic operating restrictions
Idling restrictions/Idling reduction campaigns
Agricultural Vehicles and Equipment
Examples: Tractors, Combines, Balers, Irrigation Sets, etc.
Retrofit/upgrade/replacement regulations (mandatory or voluntary)
Programs to encourage use of alternative vehicles and technologies
Idling restrictions/Idling reduction campaigns
Labelling and information policies
Mining Vehicles and Equipment
Examples: Off-highway trucks, Underground mining equipment, etc.
Fuel regulations
Idling restrictions/Idling reduction campaigns
Labelling and information policies
Lawn and Garden Vehicles and Equipment
Examples: Front mowers, Wood splitters, etc.
Scrappage programs
Idling restrictions/Idling reduction campaigns
Labelling and information policies
Other
Examples: Aerial Lifts, Forklifts, Gen Sets, other industrial or commercial equipment
Geographic operating restrictions
Labelling and information policies
Scrappage programs
Programs to encourage use of alternative vehicles and technologies
Process guidance This guidance is drawn from the results of the evaluation presented in this document as well as the case studies, illustrating the factors that make a program or policy successful. There are numerous considerations to make when selecting and implementing a policy or program to reduce emissions from the in-use diesel fleet. Each jurisdiction will have its own priorities and challenges. As a result, there is no one standard option that will be applicable to the wide range of jurisdictions. Even similar policy and program options can be designed, supported, implemented and enforced in different ways to suit the capacity of the implementing jurisdiction. Key considerations that will lead a jurisdiction to make one decision over another include: • Fleet size and composition (e.g. small, uniform fleet vs. a large, diverse fleet) and ownership
(e.g. owner/operators, owners of smaller fleets vs. large fleets, private rather than for-hire truckers, etc.)
• Fleet use, considering drive cycles and annual vehicle kilometres travelled (e.g. short-haul, delivery, long-haul, etc.) and vehicle age (model year)
• Geographic region • Costs (e.g. start-up, operational) • Existing infrastructure (e.g. alternative fuel supply and distribution) • Existing mechanisms (e.g. financial, enforcement, etc.)
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• Impetus for change (e.g. visible smog, poor health of residents, vulnerable populations, air quality exceedances, etc.)
As an example, for a fleet of short-haul, delivery trucks that operate most of the time within city limits and typically drive in stop and go traffic, use of hybrid technologies may be a leading consideration, since the benefits of hybrid vehicles are optimized with frequent stops and low speeds. On the other hand, for a fleet of long-haul trucks that operate most of the time on inter-city highways and typically drive at highway speeds with infrequent stops, hybrid technologies may not be a consideration, as the benefits of a hybrid engine may not be realized in those driving conditions. Similarly, a jurisdiction that has existing natural gas supply and distribution infrastructure, including fuelling stations, may consider purchasing new natural gas vehicles when turning over diesel vehicles, as the costs would be limited to the incremental difference between the natural gas and diesel vehicles. However, a jurisdiction with no existing infrastructure may not find it cost effective to switch from diesel to natural gas, if they have the costs of developing the fuel transportation and distribution infrastructure in addition to the incremental vehicle costs. With all of these considerations in mind, the following guidance is provided to assist jurisdictions in beginning the process of selecting an appropriate policy or program option. Under each element, a series of questions is presented to illustrate the types of factors that a jurisdiction may want to consider before proceeding with the selection of a policy or program. Each of these elements touches on the themes that make a policy or program successful. • Know your problem: What is the problem that you are trying to address? Does your
jurisdiction have concerns about GHG emissions or CAC emissions? • If the issue is CAC emissions, what are the air quality issues within your region (e.g.
PM or O3)? If there are concerns with PM emissions, it would be important to look specifically at measures that reduce PM. If there are concerns with O3, consider options to reduce NOx and/or VOCs. For this, you must be aware of the importance of the NOx/VOC ratio, as in some areas O3 formation is driven by NOx, and in other areas O3 formation is driven by VOCs. Furthermore, are there sensitive receptors you are trying to protect within your area? If so, which in-use diesel vehicles or engines operate within that area that could be addressed to limit exposure? Are there specific activities that could be addressed near that location?
• Is the issue GHG emissions? What is the motivating factor in reducing GHG emissions?
• Know your fleet: Are there specific vehicles within the fleet that are the main concern? What vehicles are contributing disproportionately to CAC emissions? What vehicles are contributing disproportionately to GHG emissions? What is the age structure of the fleet? What is the main function of each vehicle? What are the utilization rates of each vehicle? Are there any incoming vehicle/engine regulations that would preclude any program/policy considerations?
• Know and engage your stakeholders: Who are the key players that you would need to consult with in developing a policy or program? Who does the policy or program impact, what types of organizations? It is important to note that a recurring theme for the successful
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design and implementation of policies and programs is stakeholder engagement, from the very start of the process.
• Do your research: Are there similar jurisdictions that have faced the same issues as you? Have they implemented any policies or programs to address these problems? What were their successes/failures? Are you considering new or emerging technologies? Have the technologies been tested and proved in real and similar situations, within your region/climate? Are you basing your expected savings on optimal conditions or real conditions? Are there existing or incoming federal, provincial or municipal government environmental regulations that impact your jurisdiction or that could be leveraged?66
• Develop a short list: After the specific problem is defined and the research is conducted, create a short list of options for detailed evaluation. Which will be the suitable and cost-effective solution to the problem? To the specific fleet characteristics and vehicle use? For the existing (fuelling) infrastructure? For the available budget? Which fits into the institutional mandate and organization?
• Consider capacity: Does your organization have the senior management support required to develop and implement this type of policy or program option? Does your organization have the necessary human resources available to implement and administer the program or policy? Is the necessary organizational infrastructure in place to support the policy or program?
• Consider budget and time: Complete a detailed evaluation of the estimated costs and benefits of the short listed options. Does your organization have access to the necessary capital? Does your organization have access to on-going funding to implement and support an initiative or is the funding only for a one-time expense? Are you considering short, medium or long term initiatives? Are you expecting “quick win” results or is long term impact acceptable to your organization? Allow for sufficient lead time (particularly in developing a complex program). Are your plans sufficiently flexible to address changing circumstances over time?
Mobile source emissions from on-road and off-road diesel vehicles and engines continue to be significant contributors to air emissions despite the implementation of significant policy tools over the years, such as air pollutant and GHG emission standards, financial mechanisms and outreach. The impacts from these air pollutants and GHG and black carbon emissions from on-road heavy duty diesel vehicles and off-road diesel vehicles and engines are widespread. Effects range from human health impacts to environmental impacts to impacts on climate change, which in turn has its own effects on air quality and health. In order to assist Canadian jurisdictions in reducing air pollutant and GHG emissions from heavy duty on-road and off-road in-use diesel vehicles and engines, this document has been prepared. It is intended to support structured decision making through careful consideration of options, as Canadian jurisdictions work to address emissions from in-use diesel vehicles and engines.
66 Knowing what federal, provincial or municipal regulations impact your jurisdiction may help in reducing duplication of environmental efforts at multiple levels of government. This also applies to existing federal, provincial or municipal policies or programs that may be leveraged by multiple levels of government.
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Appendix A Diesel Vehicle and Engine Examples Examples of off-road diesel vehicles and engines
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Examples of on-road diesel vehicles Type Classification Examples
Class 2B – Light Duty 3,856–4,536 kg
(10,000 lb) Cargo van, ambulance
Class 3 – Light Duty 4,536–6,350 kg
(14,000 lb) Ford F-350, small dump truck, delivery truck
Class 4 – Medium Duty 6,531–7,257 kg
(16,000 lb) Ford F-450, landscaping utility vehicles, small city delivery truck, mini buses
Class 5 – Medium Duty 7,258–8,845 kg
(19,500 lb) Bucket trucks, medium city delivery trucks/vans, large walk-in vans
Class 6 – Medium Duty 8,846–11,793 kg
(26,000 lb) Single-axle vans, school buses, stake body trucks
Class 7 – Heavy Duty 11,794–14,969 kg
(33,000 lb) Tow trucks, furniture vans, garbage trucks, medium semis, medium tractor trailers
Class 8 – Heavy Duty 14,969 kg–27,216 kg
(60,000 lb) Cement mixers, fire trucks, large tour buses, heavy/medium tractor trailers
Class 8B – Heavy Duty >27,216 kg
(greater than 60,000 lb) Long-haul tractor trailers
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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Appendix B Policy and Program Examples Examples of on-road policy and program initiatives
Index Option Title Option Category - Primary Target Pollutant
1 Alberta “Trucks of Tomorrow” Incentive Program Financial incentives/disincentives (subsidies, grants, tax credits, fees, charges, taxes, etc.)
GHGs
2 BC Transit - Nitrogen Tire Inflation Pilot Program Inspection and maintenance programs (otherwise) GHGs 3 Berlin Environmental Zone Geographic operating restrictions CACs 4 Brampton, ON - Fleet Right-Sizing Review
Program Purchasing and right-sizing policies GHGs
5 Brampton, ON - Ultra-Low Sulphur Diesel (ULSD) Biodiesel policy
Use of alternative fuels CACs
6 British Columbia - Air Action Plan - Diesel Retrofit Requirement
Retrofit/upgrade programs (mandatory) CACs
7 British Columbia - BC AirCare On‐Road (ACOR) Program
Inspection and maintenance programs (roadside) CACs
8 British Columbia - Diesel School Bus Retrofit Program
Retrofit/upgrade programs (mandatory) CACs
9 British Columbia - Motor Vehicle Emissions Inspection and Maintenance Program (AirCare)
Idle reduction campaigns Both
10 British Columbia – New Transit Plan Use of alternative vehicles and technologies Both 11 British Columbia - SCRAP‐IT Program Scrappage programs (voluntary) CACs 12 British Columbia CARBON TAX Financial incentives/disincentives (subsidies,
13 British Columbia Climate Action Toolkit Education and Training Both 14 British Columbia Greenhouse Gas Reduction Act Fuel regulations GHGs 15 British Columbia Motor Vehicle Act Regulations
(Sect 29.03) under the Motor Vehicle Act Emission control system tampering detection and prevention strategies
CACs
16 British Columbia PST Exemption on Aerodynamic Devices for Commercial Tractor Trailers
17 British Columbia Truck Stop Electrification Use of alternative vehicles and technologies Both 18 Building Canada Fund (BCF) Financial incentives/disincentives (subsidies,
grants, tax credits, fees, charges, taxes, etc.) Both
19 California - Carl Moyer Grant Program Retrofit/upgrade programs (voluntary) Both 20 California - Diesel Risk Reduction Strategy Emission standards for in-use fleet CACs 21 California - The Drayage Truck Regulation Retrofit/upgrade programs (mandatory) Both 22 California Air Resources Board (CARB) Financial
34 Denver, CO - DOC and crankcase retrofits Retrofit/upgrade programs (voluntary) CACs 35 Edmonton Transit - Limited Idle Policy Idle reduction campaigns Both 36 Edmonton, AB - Fuel Sense program Education and Training Both
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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Index Option Title Option Category - Primary Target Pollutant
37 Edmonton, AB - Fuel Sense Incentive Program Purchasing and right-sizing policies Both 38 Environment Canada - Ultra-low Sulphur Diesel
(ULSD) Fuel regulations CACs
39 Environment Canada, Metro Vancouver & local municipalities - DOC retrofit project
Retrofit/upgrade programs (voluntary) CACs
40 Fleet Challenge - Ontario's Fleet Review Program Labeling and information GHGs 41 Fleet Complete program from Alberta Mobility and
TELUS Mobility and Complete Innovations Logistics, route optimization and vehicle tracking GHGs
42 Fraser Basin Council - E3 Fleet Program/Green Fleets BC
Education and Training Both
43 Gas Tax Fund (part of the Building Canada Fund (BCF))
44 Government of British Columbia - School Bus Retrofit Program
Retrofit/upgrade programs (voluntary) CACs
45 Government of Canada - Federal Excise Tax Financial incentives/disincentives (subsidies, grants, tax credits, fees, charges, taxes, etc.)
Both
46 Guelph, ON - Stand-alone Anti-idling Bylaw Idling restrictions Both 47 Halifax Regional Municipality - Biodiesel Policy Use of alternative fuels CACs 48 Hamilton, ON - Green Fleet Action Plan Labeling and information GHGs 49 Hamilton, ON - Idling Control Policy Idle reduction campaigns GHGs 50 Hamilton, ON - natural gas-powered transit buses Use of alternative fuels CACs 51 Hamilton, ON - Regenerative Air Street Sweepers Retrofit/upgrade programs (voluntary) CACs 52 Harrison Transport of Winnipeg - Tire Nitrogen
Conversion Inspection and maintenance programs (otherwise) GHGs
53 Houston-Galveston Area Council (H-GAC) Drayage Truck Replacement Loan Program
Retrofit/upgrade programs (voluntary) Both
54 Idling Reduction in the City of Williams Lake, BC Idle reduction campaigns GHGs 55 Industry Canada - Small Business Financing
56 Kelowna School District, BC - School Bus Tracking System
Logistics, route optimization and vehicle tracking Both
57 Kingston, ON - Stand-alone Anti-idling Bylaw Idling restrictions Both 58 London, ON - Stand-alone Anti-idling Bylaw Idling restrictions Both 59 Manitoba - Biofuels Act Fuel regulations Both 60 Manitoba - GrEEEn Trucking Program Retrofit/upgrade programs (voluntary) Both 61 Manitoba - Vehicle Standards and Inspections Idle reduction campaigns Both 62 Manitoba- The Climate Change and Emissions
Reductions Act Purchasing and right-sizing policies Both
63 Markham, ON - Proactive Preventative Maintenance Program
Inspection and maintenance programs (roadside) GHGs
64 Metro Vancouver - Sustainable Procurement Policy
Purchasing and right-sizing policies GHGs
65 Mid-Atlantic Regional Air Management Association (MARAMA) Drayage Truck Replacement Program
Retrofit/upgrade programs (voluntary) Both
66 Minnesota – Biodiesel Blend Mandate Fuel regulations Both 67 Mississauga, ON - Idling Control Bylaw Idling restrictions Both 68 Model Idling Control Program for Municipal Fleets Idle reduction campaigns Both 69 Moose Jaw, SK - pickup truck transition to CNG
from gasoline Use of alternative fuels CACs
70 Municipality of Thunder Bay, ON - Green Fleet Plan
Labeling and information Both
71 Municipality of Vancouver, BC - Green Fleet Plan Labeling and information Both 72 Natural Resources Canada (NRCan) - FleetSmart Labeling and information Both 73 Natural Resources Canada (NRCan) - Fuel
Management 101 workshop Education and Training Both
74 Natural Resources Canada (NRCan) - SmartDriver for Transit
Education and Training Both
75 Natural Resources Canada (NRCan) - SmartDriver Training
Education and Training Both
76 Natural Resources Canada (NRCan) FleetSmart program
Retrofit/upgrade programs (voluntary) Both
77 Natural Resources Canada (NRCan) Office of Energy Efficiency (OEE) -Idle Free zone
Idle reduction campaigns CACs
78 Natural Resources Canada (NRCan) SmartWay Financial incentives/disincentives (subsidies, Both
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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Index Option Title Option Category - Primary Target Pollutant
Certified Technology Fund Pilot Project grants, tax credits, fees, charges, taxes, etc.)
79 Newfoundland and Labrador - Inspection Requirements
Inspection and maintenance programs (otherwise) CACs
80 Newfoundland and Labrador -Air Pollution Control Regulations
Emission standards for in-use fleet CACs
81 Newfoundland and Labrador -Highway Traffic Act Emission control system tampering detection and prevention strategies
CACs
82 Niagara Falls, ON - Stand-alone Anti-idling Bylaw Idling restrictions Both 83 North Carolina Idling Rule for Heavy Duty
Vehicles (HDV) Idling restrictions Both
84 Northwest Territories - Motor Vehicle Regulations (SI‐013‐92)
Emission control system tampering detection and prevention strategies
CACs
85 Nova Scotia - Standards of Vehicle Equipment Regulations
Emission control system tampering detection and prevention strategies
CACs
86 Nova Scotia Clean Foundation FleetWiser Municipal Program (Pilot)
Education and Training Both
87 Nova Scotia FleetWiser - Greening the Fleet Rebate Program
106 Quebec - Regulation Respecting the Quality of the Atmosphere: Q2, r20:
Emission control system tampering detection and prevention strategies
Both
107 Quebec - Speed Limit Control Measure Time of use operating restrictions Both
108 Quebec - The Drive Electric Program Use of alternative fuels CACs 109 Québec, QC - GPS Pilot Project Logistics, route optimization and vehicle tracking Both 110 Québec – Title : Regulation respecting
environmental standards for heavy vehicles/ PIEVAL
Inspection and maintenance program (roadside) CACs
119 Saskatchewan - Renewable Diesel Program Fuel regulations Both 120 SmartWay Transport Partnership program Education and Training GHGs 121 Stockholm, Sweden - Low Emission Zone (LEZ) Geographic operating restrictions Both 122 Sudbury, ON - Turn it Off Campaign Idle reduction campaigns Both 123 Sustainable Purchasing Network - Integrating
Sustainability into Purchasing Purchasing and right-sizing policies Both
124 Swift Transportation "Clean Fleet" Use of alternative vehicles and technologies Both 125 The Canadian Environmental Protection Act, 1999 Emission standards for in-use fleet CACs 126 The Clean Air Partnership - Model Idling Control
Program for Municipal Fleet Idle reduction campaigns Both
127 The Federation of Canadian Municipalities (FCM) Green Municipal Fund (GMF)
128 The Puget Sound Clean Air Agency and partners - Diesel Solutions program
Retrofit/upgrade programs (voluntary) CACs
129 The Renewable Fuels Regulations (SOR/2010‐189) and The Alternative Fuels Act
Fuel regulations GHGs
130 Tokyo Metropolitan Government In-Use Emission Standard
Emission standards for in-use fleet CACs
131 Toronto, ON - Green Fleet Transition Plan: 2004-2007 and Green Fleet Plan 2008-2011
Purchasing and right-sizing policies GHGs
132 Toronto, ON - hybrid aerial tower trucks Use of alternative vehicles and technologies Both 133 Toronto, ON - hydraulic launch-assist garbage
trucks Use of alternative vehicles and technologies Both
134 Toronto, ON - Regenerative Air Street Sweepers Retrofit/upgrade programs (voluntary) CACs 135 Toronto, ON - Route Optimization Policy Logistics, route optimization and vehicle tracking GHGs 136 Toronto, ON - Space Heater Policy Retrofit/upgrade programs (voluntary) Both 137 Toronto, ON - Stand-alone Anti-idling Bylaw Idling restrictions Both 138 TransLink - ITS technology Logistics, route optimization and vehicle tracking GHGs 139 Transport Canada - ecoTechnology for Vehicles
Program (eTV) Labeling and information Both
140 Transport Canada (TC) - ecoFreight Program Financial incentives/disincentives (subsidies, grants, tax credits, fees, charges, taxes, etc.)
Both
141 Transport Canada cash rebate incentive demonstration projects
150 US EPA Ultra-low Sulphur Diesel (ULSD) Regulations
Fuel regulations CACs
151 Vancouver, BC - Supplier Code of Conduct Purchasing and right-sizing policies Both 152 Windsor, ON - Stand-alone Anti-idling Bylaw Idling restrictions Both 153 Winnipeg, MB - Automatic Vehicle Location
Systems (AVLS) in buses Logistics, route optimization and vehicle tracking GHGs
154 Winnipeg, MB - Water and Waste Vehicle Auxiliary Power Unit (APU) Trial
Use of alternative vehicles and technologies Both
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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Index Option Title Option Category - Primary Target Pollutant
155 Wisconsin State Energy Office - Diesel Truck Idling Reduction Grant Program
Use of alternative vehicles and technologies CACs
156 Yukon - The Air Emissions Regulations under the Environment Act 37
Emission control system tampering detection and prevention strategies
CACs
157 Canada Fuels Regulations Fuel regulations Both
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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Examples of off-road policy and program initiatives
Index Option Title Option Category - Primary Target Pollutant
1 A Guide to Energy Efficient Best Practices for Alberta’s Road Building & Heavy Construction Industry/Memorandum of Understanding (MOU)
Labeling and information GHGs
2 Alabama Fuel-Efficient Green Fleets Policy and Fleet Management Program Development
Purchasing and right-sizing policies Both
3 Alberta Environmental Protection and Enhancement Act – Approvals
Air quality standards and regulations Both
4 Alberta Renewable Fuels Standard Fuel regulations GHGs 5 Arizona Clean Fuel Contracts for Heavy Duty
7 Arkansas Biodiesel Use Requirements Fuel regulations Both 8 Berlin Environmental Zone Geographic operating restrictions CACs 9 Biodiesel Blend Mandate (Minnesota Statute
239.75 and 239.77) Fuel regulations Both
10 Biodiesel Use Requirements (Missouri Revised Statutes 414.407 and 414.365)
Use of alternative fuels Both
11 Brampton, ON Biodiesel Purchasing Policy Use of alternative fuels GHGs 12 California – In-Use Off-Road Diesel Vehicle Rule Emission standards for in-use fleet CACs 13 California AB 118 Air Quality Improvement
19 California Sustainable Freight Transport Initiative Use of alternative fuels Both 20 Canada Fuels Regulations Fuel regulations Both 21 Canada's Federal Sustainable Development
Strategy Purchasing and right-sizing policies Both
22 City of Auburn, California Anti-Idling Ordinance Idling restrictions CACs 23 Clean Air Strategy for the Port of New York and
New Jersey Use of alternative vehicles and technologies Both
24 Clean Construction and the Construction Equipment Rebate Program
25 Code of Federal Regulations (CFR) Title 40, Chapter I, Subchapter U, Part 1068 - General Compliance Provisions for Highway, Stationary, and Non-road Programs
Emission standards for in-use fleet CACs
26 Colorado Alternative Fuel, Advanced Vehicle, and Idle Reduction Technology Tax Credit
33 Directive 2001/81/EC of the European Parliament and the Council on National Emission Ceilings for certain pollutants (NEC Directive)
Air quality standards and regulations CACs
34 Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air
Air quality standards and regulations CACs
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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Index Option Title Option Category - Primary Target Pollutant
quality and cleaner air for Europe 35 EU Low Emission Zones (LEZs) Geographic operating restrictions Both 36 Florida Statute 286.29 – Climate Friendly Public
Business Purchasing and right-sizing policies Both
37 Fuel-Efficient Vehicle Acquisition Requirements (North Carolina General Statutes 143-341(8)(i))
Purchasing and right-sizing policies Both
38 Georgia Alternative Fuel and Advanced Vehicle Job Creation Tax Credit
60 London - Draft: The Control of Dust and Emissions During Construction and Demolition
Labeling and information CACs
61 Los Angeles County Metropolitan Transportation Authority (Metro) Green Construction Policy
Emission standards for in-use fleet CACs
62 Maine Idle Reduction Requirement Idling restrictions Both 63 Massachusetts Diesel Retrofit Program Retrofit/upgrade programs (mandatory) CACs 64 Minnesota Small Business Environmental
65 Montreal Regulation 2001-10 on atmospheric emissions (Règlement relatif à l’assainissement de l‘air et remplaçant les règlements 44 et 44-1 de la Communauté)
Idling restrictions Both
66 National Clean Diesel Funding Assistance Program
76 Pittsburgh Clean Air Act of 2010 Emission standards for in-use fleet CACs 77 Rhode Island Diesel Emission Reduction Act Retrofit/upgrade programs (mandatory) CACs 78 Rhode Island Diesel Retrofit Program Retrofit/upgrade programs (mandatory) CACs 79 San Francisco Clean Construction Ordinance Emission standards for in-use fleet Both 80 Summerhill Impact - Mow Down Pollution Financial incentives/disincentives (subsidies,
grants, tax credits, fees, charges, taxes, etc.) Both
81 Switzerland Emission Regulations for In-Use Engines – General Construction (BUWAL)
Retrofit/upgrade programs (mandatory) CACs
82 Switzerland Emission Regulations for In-Use Engines – Underground Construction (SUVA)
Retrofit/upgrade programs (mandatory) CACs
83 Switzerland Ordinance for Air Protection, occupational exposure limits, and emission regulations for construction applications
Emission standards for in-use fleet CACs
84 Switzerland Particulate Filter Requirements and VERT Filter List
Labeling and information CACs
85 Texas Emissions Reduction Incentive Grants (ERIG) Program
87 Texas Idle Reduction Requirement Idling restrictions Both 88 US Clean Diesel Collaborative Labeling and information Both 89 US EPA – Clean Construction and the
Construction Equipment Rebate Program Financial incentives/disincentives (subsidies, grants, tax credits, fees, charges, taxes, etc.)
CACs
90 US EPA DERA - Funding for Projects to Improve Air Quality at Ports
Options to Address Air Pollutant and Greenhouse Gas Emissions from In-use Heavy Duty On-road and Off-road Diesel Vehicles and Engines
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