The National Off-Highway Equipment Environmental Outlook

2010 Randall-Reilly Construction Symposium

Tuscaloosa, Alabama

April 29, 2010

The National Off-Highway Equipment Environmental Outlook

2010 Randall-Reilly Construction Symposium

Tuscaloosa, Alabama

April 29, 2010

Construction Equipment Environmental Issues Air Quality

• EPA Non-Road Emission Regulations

• Engine Technologies

• State Initiatives

• Contracts and Bid Specification Noise Greenhouse Gases

Topics Covered Today

Off-Highway Equipment

Construction Equipment Mobile Equipment

• Backhoes• Excavators• Loaders• Etc.

Portable Equipment• Generators• Compressors• Pumps• Auxiliary Engines• Etc.

Air Quality

Particulate Matter (PM)

Nitrogen Oxide (NOx)

Volatile Organic Compound (VOC)

Non-Methane Hydrocarbons (NMHC)

Sulfur

Opacity

Current Non-Attainment Areas

PM2.5 208 counties

Ozone 347 counties

Total 408 counties

Non-Attainment Area Facts

2010+

PM2.5 ~237 counties (based on latest EPA data)

Ozone ~345 counties (based on latest EPA data)

Total ~440-550 counties

2011+ Non-Attainment Projection

Ozone Non-attainment OnlyPM & Ozone Non-attainmentPM Non-attainment OnlyOzone Non-attainment Risk (Aggressive = .060 ppm)

Ozone Non-attainment OnlyPM & Ozone Non-attainmentPM Non-attainment OnlyOzone Non-attainment Risk (Aggressive = .060 ppm)

NOx

Byproduct of combustion especially at higher temperature

Precursor to Ozone

Lumped with NMHC in many emission standards

EPA Manufacturer Standards

EPA Non-Road Emission Regulations

Exhaust After

Treatment

Required

Exhaust After

Treatment

Required

Technologies to Achieve Standards

Exhaust Gas Recirculation (EGR)

Diesel Oxidation Catalyst (DOC)

Nitrogen Enriched Air (NEA)

Selective Catalytic Reduction (SCR)

PM

PM, PM10, PM2.5

Byproduct of incomplete combustion

Classified as an air toxic in California

EPA Manufacturer Standards

EPA Non-Road Emission Regulations

Exhaust After

Treatment

Required

Exhaust After

Treatment

Required

Technologies to Achieve Standards

Most NOx emission control strategies contribute to a decrease in PM emissions

Diesel Oxidation Catalyst - 25%

Diesel Particulate Filters - >85%

Verified Diesel Emission Control Strategies (VDECS)

Tier 3 Technical Path

Air Inlet

Compressed Air from Turbocharger

Cooled Air from Intercooler

Exhaust Gas

VTG Turbo

EGRCooler

EGR Valve

NOx reduction:

Exhaust Gas Recirculation (EGR)

Particulate Matter (PM) reduction:

Advanced Fuel Injection System

Interim Tier 4 Technical Path

Exhaust Gas

Air Inlet

Compressed Air from Turbocharger

VTG Turbo, plus Fixed turbo

DPFDOCIntake Air Throttle

EGR Valve

Larger EGR

Cooler

NOx reduction:

Additional Exhaust Recirculation

Particulate Matter (PM) reduction:

Higher fuel injection pressure

Diesel Oxidation Catalyst (DOC)

Diesel Particulate Filter (DPF)

HC Injection

Final Tier 4 Possible Technology

• Additional NOx reduction with Urea-based Selective Catalytic Reduction (SCR)

• Urea injected into exhaust

• 80% NOx reduction

Urea Injection

Exhaust Gas

DPF

HC Injection

Intake Air Throttle

SCR

EGRCooler

EGR Valve

Compressed Air from Turbocharger

DOC

Air Inlet

VTG Turbo, plus Fixed turbo

Tier 4 Final (2010 On-Highway, 2014 Non-Road) Selective Catalytic Reduction (SCR)

Aftertreatment

Requires urea injection into exhaust

• Urea freezes at 11°F

Sulfur

Contributor to SOx (acid rain).

Currently transitioning from low sulfur diesel fuel to ultra low sulfur diesel fuel (ULSD) nation wide.

ULSD has 15ppm or less S. All emission control strategies work best using ULSD but engines do

not.

Other Emission Reduction Strategies

NOx and PM

Emulsified Fuel

Conversion to Natural Gas

Electrification

Hybrid Diesel Electric Designs

Idling Restrictions

The Regulatory Movement

California ARB Diesel Regulation Activities

New York City Local Law 77

Connecticut Clean Air Construction Initiative

Massachusetts Projects

Virginia - Bid to Contractors

Texas TERP

California Air Resources Board (ARB)

California Air Resources Board (ARB) Portable Diesel Engine Air Toxic Control Measure Stationary Diesel Engine Air Toxic Control Measure Carl Moyer Surplus Off-Road Opt- in for NOx (SOON) Program Off-road (In-Use) Diesel Regulation

• Up to 32 States are closely watching this regulation

- Connecticut - Delaware - Georgia

- Illinois - Indiana - Kentucky

- Maryland - Michigan - Missouri

- New Jersey - New York - North Carolina

- Ohio - Pennsylvania - Tennessee

- Virginia - District of Columbia

States Expressing an Interest in Adopting California’s Off-

Road Rule

The Regulatory Movement (cont.)

Lead Time Requirement for California’s Off-Road Rule to Take Effect in Other States

California Adopts Rule States Must go Through their Rule Adoption Process The Rule Must be Identical to California’s The State’s Rule Must Provide a Minimum Two-Year Lead

Time After Adoption

Note: States do not need to wait for the California Rule to receive a federal preemption waiver before adopting their own Rule. EPA and the courts have consistently taken the position that a non-California state may adopt California standards that have not received a preemption waiver but that the state cannot enforce the rules until the California preemption waiver is granted.

New York City Local Law 77

Requires Best Available Technology (BAT) for construction equipment 50 hp or greater operated by agencies and contractors working within the city.

BAT is technically feasible EPA or CARB verified devices, or others.

Ultra low sulfur diesel fuel (ULSD) is also required.

CT Clean Air Construction Bid Specification

Low Sulfur Diesel

Diesel Oxidation Catalysts

Diesel Particulate Filters

Annual Review of CARB/EPA Verifications

New Verifications Included in Following Years’ Bid Specifications

Connecticut Clean Air Construction Initiative

Massachusetts

Highway Department, Transportation Authority, Department of Environmental Protection all require at least a DOC on all project equipment.

Example: The Big Dig more than 200 equipment retrofitted with DOC’s

The Regulatory Movement (cont.)

The following requirements were included in the bid specification: All Contractor and sub-contractor diesel powered non-road

construction equipment with engine horsepower (HP) ratings of 60 HP and above…shall be retrofitted with Emission Control Devices in order to reduce diesel emissions. The Retrofit Emission Control Devices shall consist of oxidation catalysts, or similar retrofit equipment control technology that (1) is included on the Environmental Protection Agency (EPA) Verified Retrofit Technology List and (2) is verified by EPA or certified by the manufacturer to provide a minimum emissions reduction of 20% PM10, 40% CO, and 50% HC.

• Tier 2, Tier 3 and Tier 4 Engines Exempt from this Requirement

No contractor will allow any diesel-fueled commercial motor vehicles or diesel non-road construction equipment to idle for a period greater than 5 minutes.

Virginia - Army Relocation of National Capitol Region

Facilities to Fort Belvoir, VA

Texas Emissions Reductions Plan

Provides incentive funding for retrofits and newer cleaner equipment

Voluntary

Texas Emissions Reductions Plan (TERP)

Since the 1972 passage of the Noise Control Act, noise has been regulated at every level of government

National standards have been created to limit noise from vehicles and industrial equipment

States have also required noise elements in planning documents

Local ordinances mainly directed at construction noise are in place in thousands of cities and towns

Most noise is treated at the “nuisance” level and not quantified for enforcement purposes

Consult your local “noise” expert for additional information

Noise

CO2, N2O, CH4

EPA mandatory greenhouse gas reporting for large stationary sources starts in 2011 for the 2010 calendar year.

Industrial sources which includes construction sources account for 18% of GHG emissions, construction is in this.

It is only a matter of time before GHG’s from construction equipment will become subject to direct regulation.

Greenhouse Gases (GHG)

If you have any questions, please contact me:

Drew Delaney

Associates Environmental

16882 Bolsa Chica Street, Suite 202

Huntington Beach, CA 92649

Office: (714) 916-4953 x703

Mobile: (949) 322-3739

Fax: (714) 362-9085

ddelaney@associatesenvironmental.com

Thank You