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HomeMy WebLinkAboutItem J April 10, 2000 STAFF REPORT To: Mayor and Members of the City Council Attention: Keith R. Till, City Manager From: Lee Whittenberg, Director of Development Services Subject: APPROVAL OF COMMENT LETTER - SCAQMD PROPOSED RULE 1191, CLEAN ON-ROAD LIGHT- AND MEDIUM-DUTY PUBLIC FLEET VEHICLES SUMMARY OF REQUEST Authorize Mayor to sigh proposed comment letter with any amendments determined appropriate. Instruct staff to forward to the Environmental Quality Control Board for information, and receive and file the Staff Report. DISCUSSION Overview of Proposed Rule: The South Coast Air Quality Management District (SCAQMD) has proposed a series of Clean On- Road Fleet Vehicle Rules in an effort to reduce toxic air pollutants. Concern over toxic air contaminants has come on the heals of a study recently completed by the SCAQMD, referred to as the MATES Il (Multiple Air Toxics Exposure Study), which concluded that diesel particulates account for about 70 percent of the total cancer risk estimated in the South Coast Air Basin. The Clean Fleet Rules have been developed and proposed to attempt to reduce diesel emissions from heavy-duty vehicles, as well as other toxic pollutants generated by light- and medium-duty vehicles. Due to certain issues raised by the proposed rule, staff has prepared a comment letter for City Council approval, provided as Attachment 1. AGENDA ITEM f C:\My Documents\AQMP\Proposed Rule 1191 Co runent Letter,CC SR.doc\LW\04-05-00 Approval of Comment Letter re: SCAQMD Proposed Rule 1191 City Council Staff Report April 10, 2000 Summary of Proposed Amended Rule 1191: Provided as Attachment 2 is "briefing paper" regarding this rule, prepared by the Orange County Council of Governments Air Quality Technical Assistance Program. Please refer to Attachment 2 for an overview of the basic provisions of the proposed rule. City Review of SCAQMD Proposed Rule 1191: Staff has referred this proposed rule to the Police Department and Public Works Department for any comments or concerns they may have. Vehicles operated by state and federal law enforcement agencies, police, sheriff and fire departments, and hospital, medical and paramedic facilities, and exclusively used for responding to situations where potential threats to life or property are exempt. In addition, the vehicles certified to qualify under the proposed rule are extensive, and have been determined to be comprehensive enough to meet future vehicle acquisition needs of the City and be in compliance with the proposed rule. Staff would recommend the rule effective date coincide with the beginning of the fiscal year, which would affected agencies to plan ahead for the implementation of the rule in conjunction with the budget preparation process. RECOMMENDATION Authorize Mayor to sigh proposed comment letter with any amendments determined appropriate. Instruct staff to forward to the Environmental Quality Control Board for information, and receive and file the Staff Report. NOTED AND APPROVED / Whittenberg, Director Keith R. Till Development Services II:41 City Manager Attachments: (2) Proposed Rule 1191 Comment Letter,CC SR 2 Approval of Comment Letter re: SCAQMD Proposed Rule 1191 City Council Staff Report April 10, 2000 ATTACHMENT 1: Draft Comment Letter Re: Proposed Rule 1191 - Clean On- Road Light- And Medium-Duty Public Fleet Vehicles ATTACHMENT 2: "Briefing Paper - Clean On-Road Fleet Vehicle Rules", prepared by Orange County Council of Governments, dated February 25, 2000 Proposed Rule 1191 Comment Letter,CC SR 3 Approval of Comment Letter re: SCAQMD Proposed Rule 1191 City Council Staff Report April 10, 2000 ATTACHMENT 1 DRAFT COMMENT LETTER RE: PROPOSED RULE 1191 - CLEAN ON-ROAD LIGHT- AND MEDIUM-DUTY PUBLIC FLEET VEHICLES Proposed Rule 1191 Comment Letter,CC SR 4 3 DE SEA( Seak—geaCA CITY HALL • 211 EIGHTH STREET SEAL BEACH, CALIFORNIA 90740.63 (562) 431.2527 April 10, 2000 Dr. William A. Burke, Chairman South Coast Air Quality Management District 21865 E. Copley Drive Diamond Bar, CA 91765-4182 Dear Dr. Burke: SUBJECT: CITY OF SEAL BEACH COMMENTS RE: PROPOSED RULE 1191 - CLEAN ON-ROAD LIGHT- AND MEDIUM-DUTY PUBLIC FLEET VEHICLES The City of Seal Beach has reviewed Proposed Rule 1191 and supports the intent and purpose of the rule to alleviate toxic air contaminants within the South Coast Air Basin through implementation of this rule. Although the immediate impacts upon local and regional agencies within the Air Basin may be a cause for certain local concerns regarding vehicle acquisition programs, the long-term improvements to air quality within the region are certainly supportable and should be received in a positive manner. The City of Seal Beach has been very active in converting our fleet vehicles to alternative fuels sources. During the past 2 years the City has acquired 4 electric vehicles and 8 CNG vehicles for use within our vehicle fleet. In addition, the City has opened 2 separate electric vehicle charging stations and a public CNG fast-fuel facility within the community in cooperation with Edison EV and Pickens Fuel Corporation, respectively. Funding for these vehicle acquisitions was provided by the District's MSRC program and the PVEA program of the State of California. At this time, the City is actively seeking funding through the PVEA program for 9 additional CNG vehicles, 2 bi-fuel vehicles and a CNG/PM 10 street sweeper to further enhance our air quality improvement program relating to city-operated vehicles. In the opinion of our staff, the proposed rule provides an adequate selection of vehicle types and models for our future vehicle acquisition needs and will not be detrimental to C:1My Documents\AQMPIProposed Rule 1191.CC Comment Letter.doc1LW104-10-00 City of Seal Beach Comment Letter re: tqf Proposed Rule 1191—Clean On Road Public Fleet Vehicles April 10, 2000 those efforts. We support the proposed revision to the effective date of the rule to coincide with the common fiscal year date of July 1, 2001. This will allow District staff additional time to work in a cooperative manner with local agencies not currently involved with alternative fuel/low emission vehicle acquisition programs. If you have any questions regarding the comments of the City of Seal Beach, please contact Mr. Lee Whittenberg, Director of Development Services, telephone (562) 431- 2527, extension 313. He will be most happy to discuss our involvement with alternative fuel/low emission vehicles and our comments regarding this proposed rule. Sincerely, 11Z-otV Paul Yost, Mayor City of Seal Beach Distribution: City Council Environmental Quality Control Board City Manager Director of Development Services Proposed Rule 1191.CC Comment Letter 2 ORANGE COUNTY COUNCIL OF GOVERNMENTS Air Quality Technical Assistance Program BRIEFING PAPER CLEAN ON-ROAD FLEET VEHICLES RULES (as of February 25, 2000) In effort to reduce toxic air pollutants, the South Coast Air Quality Management District (AQMD) has proposed a series of Clean On-Road Fleet Vehicle Rules. Concern over toxic air contaminants has come on the heals of a study recently completed by the AQMD, referred to as MATES II(Multiple Air Toxics Exposure Study), which concluded that diesel particulates account for 70 percent of total cancer risk estimated in the South Coast Air Basin. The Clean Fleet Rules have been developed to reduce diesel emissions from heavy-duty vehicles, as well as other toxic pollutants generated by light-and medium-duty vehicles. OVERVIEW PROPOSED RULE 1191 — Light- and The South Coast Air Quality Management District Medium Duty Public Fleet Vehicles (SCAQMD) Clean On-Road Vehicle Fleet Rules require fleets to deploy clean-burning low-emission or Beginning in January 1, 2001, requires public fleets of 15 alternative-fuel vehicles when procuring or leasing new or more vehicles which include passenger, cars, light- vehicles. The SCAQMD includes Orange Cot•nty and the duty truck, or medium-duty vehicles, to acquire low- non-desert portions of Los Angeles, San Bernardino and emitting gasoline or alternative fuel vehicles when Riverside counties. procuring or leasing these vehicles. The AQMD first released their proposed mandate in Who is Affected? November 1999 as a single Rule, Proposed Rule 1190, which targeted light-, medium- and heavy-duty vehicles Rule 1191 targets fleets of 15 or more vehicles operating in a broad range of applications. Due to the specifically including the following: number of issues which surfaced in review of the • Federal, state, regional, county, and city agencies. AQMD's proposal, a modified approach was presented • Special District (water, air, sanitation, transit school on February 16th to develop a series of rules to target districts). specific fleet types. Proposed Rules What vehicles comply with the Rule? The following lists the proposed rule series: District staff has developed a list of vehicle models and engines which meet the certified by the California Air Rule 1191 Light and Medium Duty Public Fleet Vehicles Resources Board (CARB) that can be chosen to comply Rule 1192 Clean On-Road Transit Buses with the Rule. The vehicle list includes vehicles for light- Rule 1193 Clean On-Road Refuse Collection Vehicles and medium-duty vehicles which meet certification Rule 1194 Commercial Airport Operations standards from zero-emission (ZEV), super-ultra low Rule 1195 Clean On-Road School Buses (SULEV), ultra-low (ULEV), and low emission (LEV) Rule 1196 Heavy Duty Public Fleet Vehicles vehicles. The LEV category includes gasoline-fueled Rule 1186 Street Sweeping vehicles which are in use by many fleets throughout the Rule 431.2 Lower Sulfur Content in Diesel region. Some concerns have been expressed related to the availability of vehicles in the medium-duty category. To date, the District has released language for Rule 1191 District staff is considering allowing for exemptions in and Rule 1192. A summary of each rule follows: cases where a LEV vehicle or cleaner is not available. SCAOMD's Clean On-Road Vehicles Fleet Rules Page 1 202/25/00 Briefing Paper: Clean On-Road Fleet Vehicle Rules Who is exempt? ADOPTION SCHEDULE The Rule exempts vehicles operated by state and federal The following identifies the proposed adoption schedule law enforcement agencies, police and sheriff for the Clean On-Road Vehicle Fleet Rule series: department, fire department, hospital, medical or paramedic facility, and exclusively used for responding Rule 1191 Light and Medium Duty April 2000 to situations where potential threats to life or property Rule 1192 Transit Buses April 2000 exists. In addition, existing contracts for the purchase of Rule 1193 Refuse Collection Vehicles May 2000 new vehicles are not affected. In addition, the rule Rule 1194 Airport Operations June 2000 exempts privately owned or operated fleets. Rule 1195 School Buses July 2000 Rule 1196 Heavy Duty Public Vehicles July 2000 Rule Compliance Rule 1186 Street Sweeping June 2000 Rule 431.2 Lower Sulfur in Diesel June 2000 Compliance with Proposed Rule 1190 will be carried out by audit to be conducted at the request of the District. Public Workshops will be convened on a regular basis to The Rule does not specify the frequency of the audits or address each rule as they become available. In addition, how the fleets to be audited will be chosen. the District staff has organized a series of working groups To ensure compliance with the Rule fleet operators must to address the specific issues related to each rule. provide files and/or records containing fleet purchase The fourth public workshop is scheduled for March 10' information, such as DMV registrations, vehicle location, at the SCAQMD at 1 pm. Comments on Rules 1191 and manufacturer, model, model year, and fuel type of each 1192 are due March 16th. fleet vehicle. This shall apply to records in existence for more than one year. CONCLUSION PROPOSED RULE 1192— Clean On- SCAQMD staff has been diligent in addressing the Road Transit Buses concerns of the affected fleets. As result they have chosen to take a less aggressive schedule and piece the Beginning upon Rule adoption (scheduled April 2000), fleets into separate Rules allowing for a more thorough requires public transit fleets of 15 or more transit review of the issues. Nevertheless, the Proposed Rule vehicles or urban buses to acquire alternative-fuel heavy- series has potential to impact several public and private duty vehicles when procuring or leasing these vehicles. fleets as well as, school districts and local transit providers. The issues identified by the OCCOG Who is Affected? generally include the following: Rule 1192 applies to public transit fleets operated by • costs, government agencies or operated by private entities • availability of technologies, under contract to government agencies, that provide passenger transportation services including intra- and • infrastructure, inter city services. • Funding support, and What vehicles comply with the Rule? • impacts to contract services. Rule 1192 requires these targeted vehicles to be The attached matrix discusses these issue areas as they alternative fueled, which is the Rule to include: relate to each rule. The matrix will continue to be compressed or liquefied natural gas, propane, methanol, updated as the remaining rules are made available by electricity, fuel cells, or other advanced technologies that the SCAQMD to generate discussion and to determine do not rely on diesel fuel. the need to forward comments on behalf of the OCCOG. P\od-06\R1190\Rof a 119OBApap.d oc Page 2 The Planning Cent '% 6 ORANGE COUNTY COUNCIL OF GOVERNMENTS Air Quality Technical Assistance Program SCA QMD'S CLEAN ON-ROAD VEHICLE FLEET RULES (as of February 25, 2000) In December 1999, the South Coast Air Quality Management District (SCAQMD)presented a proposed rule to mandate the use of clean-burning or alternative fuel vehicles in fleets of 15 or more. In response to comments presented by the OCCOG, as well as other entities in the region, the SCAQMD has proposed a modified approach to segment the targeted fleets into separate rules and schedules. The list t at follows oreflects n the proposed QMD's current proposal. The issues presented are those specified by the OCCOG TACs Adoption Discussion Schedule Issues ProposedngRule ger Light- tu Medium-Duty medum-duty vehicles ublic Fleet Vehicles acquirequires public fleets low-emitting gasolinef15 or more o or fuel including passenger car, vehicles beginning January 1, 2001. Funding Support/Incentives No increased costs anticipated. Increased Costs No increased costs anticipated. Lack of Infrastructure Allows for gasoline-fueled vehicles. April 2000 100+ light-duty vehicles allowed. Concern related to medium-duty. Unavailability of Technology Suggest allowance for exemption. Issues Related to Contract Services Exempts private fleets. Proposed Rule 1192 Clean On-Road Transit Buses—Requires public transit fleets of 15 or more vehicles to acquire alternative fuel heavy-duty vehicles beginning upon rule adoption. Potential for Carl Moyer and MRC funding. Requires these programs to Funding Support/Incentives adopt/update policy to allow for funds to support mandated program. Urban bus fleets typically receive federal subsidies which will assist in Increased Costs off-setting increased costs. April 2000 Lack of Infrastructure Urban bus fleets operate centralized fueling facilities. Unavailability of Technology Majority of urban bus fleets already operating alternative fuel vehicles. Issues Related to Contract Includes private entities under contract to government agencies that Services provide intra- and inter-city shuttle service. THE SCAQMD HAS NOT RELEASED RULE LANGUAGE FOR THE FOLLOWING: Proposed Rule 1193 Clean On-Road Refuse Collection Vehicles May 2000 1 Proposed Rule 1194 Commercial Airport Ground Access June 2000 Proposed Rule 1195 Clean On-Road School Buses July 2000 Proposed Rule 1196 Clean On-Road Heavy Duty Public Fleet Vehicles July 2000 1 Proposed Amendment to Rule 1186 Street Sweeping Vehicles June 2000 I Proposed Amendment to Rule 431.2 Lower Sulfur Content in Diesel Fuels June 2000 I Page 1 The Planning Center \\TPC CMPROJECT\DATA\PROJDATA\od R 90\Issuatabledoc 027 FACT SHEET PROPOSED CLEAN ON-ROAD VEHICLE FLEET RULES FOR GOVERNMENT AND CERTAIN PRIVATE FLEETS Why is the AQMD proposing on-road fleet rules? As part of its ongoing efforts to attain state and federal ozone and particulate matter (PM) air quality standards, recent studies conducted by the South Coast Air Quality Management District (AQMD) and other air agencies have shown that mobile source emissions (from passenger cars, trucks, and other heavy-duty vehicles) are the dominant contributors to air quality problems in the South Coast Air Basin (Basin). Mobile source emissions contribute to over 75% of the nitro- gen oxide emissions in the South Coast Air Basin. In addition,the California Air Resources Board (ARB) recently listed diesel particulate exhaust emissions (to represent all diesel exhaust emissions) as an air toxic contaminant. A recent study conducted by the AQMD indicates that over 70% of the potential cancer risk estimated from air toxics for the Basin is due to diesel exhaust emissions. Gasoline exhaust emissions, too, contain several chemical compounds that are considered toxic. It is estimated that 15% of the potential risk is due to gasoline fueled vehicles. The South Coast Air Basin has seen improved air quality and reduced levels of toxic exposure over the last 25 years. During that time, much of the focus in reducing emissions has been on industrial sources locally while the state and federal governments focus on mobile sources. De- spite the large reduction in emissions, exceedances of air quality standards still and the av- erage toxic risk level is estimated to be about 1400 in one million. As such,the ,..XD MD staff is proposing clean on-road fleet rules to address air toxic issues and provide additional emission reductions to attain air quality standards as early as possible. The proposed rules and proposed amended rules are listed on Attachment A. All proposed rules and rule amendments will undergo extensive public review. As with any rule development process,the initial rule proposals may be modified to reflect public comments. The final rule proposals to be considered by the AQMD Governing Board in mid-.,pring or summer of 2000 will reflect the AQMD staff's efforts to craft rules that will provide air quality benefits and be sensitive to financial and operational needs of affected parties. What will the proposed rules require? The initial proposed rules will require the public sector and certain private sector fleet operations that have 15 or more vehicles (in that category), to purchase lower emitting gasoline or alterna- tive fueled vehicles when adding or replacing vehicles in the fleet. In addition, any new fleets will be required to purchase cleaner burning or alternative fueled vehicles. Specifically, the initial proposed rules cover all on-road vehicles including passenger cars, light- duty trucks such as pickups,medium-duty and heavy-duty vehicles for affected vehicle fleets. Currently, proposed rule language is available for PR 1191 and PR 1192. PR 1191 provides a list of engines and associated vehicle models that would meet the requirements of the proposed rule. These engines have been certified by the ARB for sale in California. For light- and me- dium-duty vehicles, PR 1191 is expected to have little to no impacts on fleet operations since over 60% of current fleet vehicles are widely-available passenger cars and light-duty trucks fu- South Coast Air Quality Management District - 1 - (draft:February 23,2000) eled by gasoline. However, PR 1192 will require transit buses to be powered by propane, natural gas, methanol, fuel cells, electricity or other advanced technologies that do not rely on diesel fuel. Specifically,who is impacted by the proposed rules? The proposed fleet rules will apply to local, state, and federal governments; special districts such as air, water, transit, and school districts; and commercial airports. In addition, private opera- tions such as intra- and intercity transit, waste hauling, and street sweeping will be required to purchase cleaner burning vehicles. Also included are private operations at commercial airports such as airlines, taxi services, and passenger shuttle services. Why apply the rules to the public sector first? Over 25% of fleet vehicles in the South Coast Air Basin are owned or operated by local govern- ments and special districts. The AQMD believes that government agencies have an opportunity to take a leadership role to protect public health by lowering harmful emissions from motor vehi- cles and expanding the clean fuel market. Many government agencies have developed policies to acquire lower emitting gasoline or alternative fueled vehicles. In addition, many government agencies have taken advantage of funding programs to offset the additional costs of alternative fueled vehicles. Lastly, many government fleets have centralized fueling stations and could im- plement the proposed rule sooner. Are any fleets exempt from the proposed rules? Under the initial proposed rules, emergency and rescue vehicles operated primarily by fire and police departments and hospitals would be exempt at this time. In addition, military tactical ve- hicles used for combat operations are also exempted. Lastly, existing contracted services would not be affected by the proposed rules. However, other fleet vehicle purchases for maintenance or personnel transport purposes may be subject to the initial proposed rules. Exempt vehicles would not be counted when inventorying the number of vehicles in the fleet. (Contact number below for more information.) When would lower emitting gasoline or alternative fueled vehicles need to be purchased? For PR 1191,implementation would begin on January 1,2001. For PR 1192, implementation will begin from the date of adoption of the proposed rule. Implementation dates for the other proposed rules have not been specifically determined but will be similar to the PR 1191 and PR 1192 implementation time frames. What efforts are underway to provide financial assistance and training for the purchase of alternative fueled vehicles? For the purchase of any vehicles that use conventional fuels such as gasoline, there will be little to no financial impacts. For many of the medium-duty and heavy-duty vehicles, certified en- gines are largely alternative fueled such as natural gas (compressed - CNG or liquid - LNG), propane, or other alternative fuels. In general, the capital cost of an alternative fueled vehicle is higher than a conventional fuel vehicle, although this difference can often be offset by various incentives that are currently available. There are several funds that the SCAQMD and other sponsors have provided for the purchase of alternative fueled vehicles. These include the SCAQMD's Clean Fuels Program and the Carl Moyer Fund. AB2766 funds and the Mobile Source Review Committee funds are also available. Federal funds are potentially available for transit fleets. In addition, several state funds are South Coast Air Quality Management District - 2 - (draft:February 23,2000) nn available. Recently, Gov. Gray Davis has proposed $50 million in his budget for next fiscal.year to help replace aging school buses with cleaner, safer models. AQMD staff is preparing a com- panion report to the rule development package describing current funding mechanisms and future funding needs. There is general recognition that the alternative fuel infrastructure is not yet as extensive as the fueling infrastructure for gasoline or diesel. Numerous fleet operations have already installed alternative fuel stations at their maintenance yards. For others, there is a need to inform fleet op- erators where public access fueling stations are located and what procedures apply. In addition, there is a need to explore potential to expand private fueling station operations to enable con- trolled public access. Lastly, there is a need to build additional fueling stations in areas where fueling stations are sparse. The SCAQMD staff believes that an outreach effort on fueling sta- tion availability and future development is needed for the successful implementation of the pro- posed rules. In addition, initiating public/private partnerships to share existing fueling facilities is an important aspect to assist in the transition to larger alternative fuel usage demands. Relative to maintenance of alternative fueled vehicles, comments range from improved perform- ance and relatively low maintenance to less than satisfactory performance. SCAQMD staff is evaluating actual in-use information and is preparing a companion document for the rule devel- opment package addressing these concerns. SCAQMD staff believes that training outreach on fueling and maintenance issues is needed. Identification of qualified training facilities and guid- ance from successful clean fueled operations will be valuable components of the rule implemen- tation. What happens if I cannot find a compliant engine that meets my specific application? The initial proposed rule language is the starting point of the rule development and based on comments received,the AQMD staff crafts additional or revised language proposals. Relative to availability of compliant engines, it is the AQMD staffs intent to apply the proposed fleet rules where it is technically and economically feasible. Staff has received comments that the proposed rule language should provide for some relief if the situation should arise that there are no avail- able compliant engines. The relief could be a full exemption or time extension until such time certified engines become available; in the meantime, the operator could purchase a convention- ally fueled engine. AQMD staff is continuing to solicit comments on this issue. Currently, PR 1192 contains exemption language to address alternative fuel engine model unavailability. What is the schedule for rule adoption? The AQMD will be holding a fourth public workshop on the proposed rule on March 10, 2000 at the AQMD Headquarters in Diamond Bar, CA. The workshop will start at 1:00 p.m. Proposed Rules 1191 and 1192 are currently scheduled for AQMD Governing Board consideration on April 21, 2000 beginning at 9:30 a.m. However, the AQMD staff will inform the Governing Board of any need to move the date for Board consideration if key issues such as financial and infrastructure needs are not resolved. South Coast Air Quality Management District 3 - (draft:February 23,2000) 031 Who to contact for questions and information? • Comments and questions on the proposed rule should be addressed to: Mr. Henry Hogo, Planning Manager Planning, Rule Development and Area Sources AQMD 21865 E. Copley Drive Diamond Bar, CA 91765 (909) 396-3184 • • • South Coast Air Quality Management District —4 - (draft:February 23,2000) 32 April 10, 2000 STAFF REPORT To: Mayor and Members of the City Council Attention: Keith R. Till, City Manager From: Lee Whittenberg, Director of Development Services Subject: APPROVAL OF COMMENT LETTER - SCAQMD PROPOSED RULE 1191, CLEAN ON-ROAD LIGHT- AND MEDIUM-DUTY PUBLIC FLEET VEHICLES SUMMARY OF REQUEST Authorize Mayor to sigh proposed comment letter with any amendments determined appropriate. Instruct staff to forward to the Environmental Quality Control Board for information, and receive and file the Staff Report. DISCUSSION overview Qf Proposed Rule: The South Coast Air Quality Management District (SCAQMD) has proposed a series of Clean On- Road Fleet Vehicle Rules in an effort to reduce toxic air pollutants. Concern over toxic air contaminants has come on the heals of a study recently completed by the SCAQMD, referred to as the MATES II (Multiple Air Toxics Exposure Study), which concluded that diesel particulates account for about 70 percent of the total cancer risk estimated in the South Coast Air Basin. The Clean Fleet Rules have been developed and proposed to attempt to reduce diesel emissions from heavy-duty vehicles, as well as other toxic pollutants generated by light- and medium-duty vehicles. Due to certain issues raised by the proposed rule, staff has prepared a comment letter for City Council approval, provided as Attachment 1. AGENDA ITEM f C:\My Documents AQMP'1Ptiopo.ed Rule 1191 Carmel letter,CC SR.doc\LW O4-O5-0U I Approval of Comment Letter re: SCAQMD Proposed Rule 1191 City Council Staff Report April 10, 2000 ATTACH 1 NT 1: Draft Comment Letter Re: Proposed Rule 1191 - Clean On- Road Light- And Medium-Duty Public Fleet Vehicles ATTACHMENT 2: "Briefing Paper - Clean On-Road Fleet Vehicle Rules", prepared by Orange County Council of Governments, dated February 25, 2000 • • Proposed Rule 1191 Comment Letter,CC SR 3 Approval of Comment Letter re: SCAQMD Proposed Rule 1191 City Council Staff Report April 10, 2000 ATTACHMENT 1 DRAFT COMMENT LETTER RE: PROPOSED RULE 1191 - CLEAN ON-ROAD LIGHT- AND MEDIUM-DUTY PUBLIC FLEET VEHICLES Proposed Rule 1191 Comment Letter,CC SR 4 Approval of Comment Letter re: SCAQMD Proposed Rule 1191 City Council Staff Report April 10, 2000 ATTACHMENT 2 "BRIEFING PAPER - CLEAN ON-ROAD FLEET VEHICLE RULES", PREPARED BY ORANGE COUNTY COUNCIL OF GOVERNMENTS, DATED FEBRUARY 25, 2000 Proposed Rule 1191 Comment Letter,CC SR 1 7 I ORANGE COUNTY COUNCIL OF GOVERNMENTS Air Quality Technical Assistance Program BRIEFING PAPER CLEAN ON-ROAD FLEET VEHICLES RULES (as of February 25, 2000) 1 In effort to reduce toxic air pollutants, the South Coast Air Quality Management District (AQMD) has proposed a series of Clean On-Road Fleet Vehide Rules. Concern over toxic air contaminants has come on the heals of a study recently ,nmpleted by the AQMD, referred to as MATES II(Muhiple Air Toxics Exposure Study), which concluded that diesel ..trculates account for 70 percent of total cancer risk estimated in the South Coast Air Basin. The Clean Fleet Rules nave been developed to reduce diesel emissions from heavy-duty vehicles, as well as other toxic pollutants generated by llight-and medium-duty vehicles. OVERVIEW PROPOSED RULE 1191 — Light- and The South Coast Air Quality Management District Medium Duty Public Fleet Vehicles (SCAQMD) Clean On-Road Vehicle Fleet Rules require fleets to deploy clean-burning low-emission or Beginning in January 1, 2001, requires public fleets of 15 alternative-fuel vehicles when procuring or leasing new or more vehicles which include passenger, cars, light- vehicles. The SCAQMD includes Orange County and the duty truck, or medium-duty vehicles, to acquire low- non-desert portions of Los Angeles, San Bernardino and emitting gasoline or alternative fuel vehicles when Riverside counties. procuring or leasing these vehicles. The AQMD first released their proposed mandate in Who is Affected? November 1999 as a single Rule, Proposed Rule 1190, which targeted light-, medium- and heavy-duty vehicles Rule 1191 targets fleets of 15 or more vehicles operating in a broad range of applications. Due to the specifically including the following: number of issues which surfaced in review of the • Federal, state, regional, county, and city agencies. AQMD's proposal, a modified approach was presented Special District (water, air, sanitation, transit school on February 16th to develop a series of rules to target districts). specific fleet types. Proposed Rules What vehicles comply with the Rule? The following lists the proposed rule series: District staff has developed a list of vehicle models and engines which meet the certified by the California Air Rule 1191 Light and Medium Duty Public Fleet Vehicles Resources Board (CARB) that can be chosen to comply Rule 1192 Clean On-Road Transit Buses with the Rule. The vehicle list includes vehicles for light- Rule 1193 Clean On-Road Refuse Collection Vehicles and medium-duty vehicles which meet certification Rule 1194 Commercial Airport Operations standards from zero-emission (ZEV), super-ultra low Rule 1195 Clean On-Road School Buses (SULEV), ultra-low (ULEV), and low emission (LEV) Rule 1196 Heavy Duty Public Fleet Vehicles vehicles. The LEV category includes gasoline-fueled Rule 1186 Street Sweeping vehicles which are in use by many fleets throughout the Rule 431.2 Lower Sulfur Content in Diesel region. Some concerns have been expressed related to the availability of vehicles in the medium-duty category. To date, the District has released language for Rule 1191 District staff is considering allowing for exemptions in and Rule 1192. A summary of each rule follows: cases where a LEV vehicle or cleaner is not available. SCAOMD's Clean On-Road Vehicles Fleet Rules Page 1 02/25/00 025 ORANGE COUNTY COUNCIL OF GOVERNMENTS Air Quality Technical Assistance Program SCAQMD'S CLEAN ON-ROAD VEHICLE FLEET RULES (as of February 25, 2000) In December 1999, the South Coast Air QuaIiry Management District(SCAQMD)presented a proposed rule to mandate the use of clean-burning or alternative fuel vehicles in fleets of 15 or more. In response to comments presented by the OCCOG, as well as other entities in the region, the SCAQMD has proposed a modified approach to segment the targeted fleets into separate rules and schedules. The list that follows reflects the SCAQMD's current proposal. The issues presented are those specified by the OCCOG TACs comments on the proposed mandate. Adoption -hedule Issues Discussion rroposed Rule 1190 Ught- and Medium-Duty Public Fleet Vehicles—Requires public fleets of 15 or more vehicles including passenger car, light-duty truck, or medium-duty vehicles to acquire low-emitting gasoline or alternative fuel vehicles beginning January 1, 2001. Funding Support/Incentives No increased costs anticipated. Increased Costs No increased costs anticipated. Lack of Infrastructure Allows for gasoline-fueled vehicles. April 2000 100+ light-duty vehicles allowed. Concern related to medium-duty. Unavailability of Technology Suggest allowance for exemption. Issues Related to Contract Services Exempts private fleets. Proposed Rule 1192 Clean On-Road Transit Buses—Requires public transit fleets of 15 or more vehicles to acquire alternative fuel heavy-duty vehicles beginning upon rule adoption. Potential for Carl Moyer and MRC funding. Requires these programs to Funding Support/Incentives adopt/update policy to allow for funds to support mandated program. Urban bus fleets typically receive federal subsidies which will assist in Increased Costs off-setting increased costs. April 2000 Lack of Infrastructure Urban bus fleets operate centralized fueling facilities. Unavailability of Technology Majority of urban bus fleets already operating alternative fuel vehicles. Issues Related to Contract Includes private entities under contract to government agencies that Services provide intra- and inter-city shuttle service. THE SCAOMD HAS NOT RELEASED RULE LANGUAGE FOR THE FOLLOWING: Proposed Rule 1193 Clean On-Road Refuse Collection Vehicles May 2000 Proposed Rule 1194 Commercial Airport Ground Access June 2000 Proposed Rule 1195 Clean On-Road School Buses July 2000 Proposed Rule 1196 Clean On-Road Heavy Duty Public Fleet Vehicles July 2000 Proposed Amendment to Rule 1186 Street Sweeping Vehicles June 2000 Proposed Amendment to Rule 431.2 Lower Sulfur Content in Diesel Fuels June 2000 The Planning CenterPage 1 \\TPC CM\PROJECT\DATA\PROJDATA\od-06\Ql'Minuends doc 027 FACT SHEET - PROPOSED CLEAN ON-ROAD VEHICLE FLEET RULES FOR GOVERNMENT AND CERTAIN PRIVATE FLEETS Why is the AQMD proposing on-road fleet rules? As part of its ongoing efforts to attain state and federal ozone and particulate matter (PM) air quality standards, recent studies conducted by the South Coast Air Quality Management District (AQMD) and other air agencies have shown that mobile source emissions (from passenger cars, trucks, and other heavy-duty vehicles) are the dominant contributors to air quality problems in the South Coast Air Basin (Basin). Mobile source emissions contribute to over 75% of the nitro- gen oxide emissions in the South Coast Air Basin. In addition, the California Air Resources Board (ARB)recently listed diesel particulate exhaust emissions (to represent all diesel exhaust emissions) as an air toxic contaminant. A recent study conducted by the AQMD indicates that over 70% of the potential cancer risk estimated from air toxics for the Basin is due to diesel exhaust emissions. Gasoline exhaust emissions, too, contain several chemical compounds that are considered toxic. It is estimated that 15% of the potential risk is due to gasoline fueled vehicles. The South Coast Air Basin has seen improved air quality and reduced levels of toxic exposure over the last 25 years. During that time, much of the focus in reducing emissions has been on industrial sources locally while the state and federal governments focus on mobile sources. De- spite the large reduction in emissions, exceedances of air quality standards still Or - and the av- erage toxic risk level is estimated to be about 1400 in one million. As such,the r.QMD staff is proposing clean on-road fleet rules to address air toxic issues and provide additional emission reductions to attain air quality standards as early as possible. The proposed rules and proposed amended rules are listed on Attachment A. All proposed rules and rule amendments will undergo extensive public review. As with any rule development process,the initial rule proposals may be modified to reflect public comments. The final rule proposals to be considered by the AQMD Governing Board in mid-.spring or summer of 2000 will reflect the AQMD staff's efforts to craft rules that will provide air quality benefits and be sensitive to financial and operational needs of affected parties. What will the proposed rules require? The initial proposed rules will require the public sector and certain private sector fleet operations that have 15 or more vehicles (in that category), to purchase lower emitting gasoline or alterna- tive fueled vehicles when adding or replacing vehicles in the fleet. In addition, any new fleets will be required to purchase cleaner burning or alternative fueled vehicles. Specifically,the initial proposed rules cover all on-road vehicles including passenger cars, light- duty trucks such as pickups,medium-duty and heavy-duty vehicles for affected vehicle fleets. Currently, proposed rule language is available for PR 1191 and PR 1192. PR 1191 provides a list of engines and associated vehicle models that would meet the requirements of the proposed rule. These engines have been certified by the ARB for sale in California. For light- and me- dium-duty vehicles, PR 1191 is expected to have little to no impacts on fleet operations since over 60% of current fleet vehicles are widely-available passenger cars and light-duty trucks fu- South Coast Air Quality Management District - 1 - (draft:February 23,2000) �?o 0.,,, available. Recently, Gov. Gray Davis has proposed $50 million in his budget for next fiscal year to help replace aging school buses with cleaner, safer models. AQMD staff is preparing a com- panion report to the rule development package describing current funding mechanisms and future funding needs. There is general recognition that the alternative fuel infrastructure is not yet as extensive as the fueling infrastructure for gasoline or diesel. Numerous fleet operations have already installed alternative fuel stations at their maintenance yards. For others, there is a need to inform fleet op- erators where public access fueling stations are located and what procedures apply. In addition, there is a need to explore potential to expand private fueling station operations to enable con- trolled public access. Lastly, there is a need to build additional fueling stations in areas where fueling stations are sparse. The SCAQMD staff believes that an outreach effort on fueling sta- tion availability and future development is needed for the successful implementation of the pro- posed rules. In addition, initiating publiclprivate partnerships to share existing fueling facilities is an important aspect to assist in the transition to larger alternative fuel usage demands. Relative to maintenance of alternative fueled vehicles, comments range from improved perform- ance and relatively low maintenance to less than satisfactory performance. SCAQMD staff is evaluating actual in-use information and is preparing a companion document for the rule devel- opment package addressing these concerns. SCAQMD staff believes that training outreach on fueling and maintenance issues is needed. Identification of qualified training facilities and guid- ance from successful clean fueled operations will be valuable components of the rule implemen- tation. What happens if 1 cannot find a compliant engine that meets my specific application? The initial proposed rule language is the starting point of the rule development and based on comments received,the AQMD staff crafts additional or revised language proposals. Relative to availability of compliant engines, it is the AQMD staff's intent to apply the proposed fleet rules where it is technically and economically feasible. Staff has received comments that the proposed rule language should provide for some relief if the situation should arise that there are no avail- able compliant engines. The relief could be a full exemption or time extension until such time certified engines become available; in the meantime, the operator could purchase a convention- ally fueled engine. AQMD staff is continuing to solicit comments on this issue. Currently, PR 1192 contains exemption language to address alternative fuel engine model unavailability. What is the schedule for rule adoption? The AQMD will be holding a fourth public workshop on the proposed rule on March 10, 2000 at the AQMD Headquarters in Diamond Bar, CA. The workshop will start at 1:00 p.m. Proposed Rules 1191 and 1192 are currently scheduled for AQMD Governing Board consideration on April 21, 2000 beginning at 9:30 a.m. However,the AQMD staff will inform the Governing Board of any need to move the date for Board consideration if key issues such as financial and infrastructure needs are not resolved. south Coast Air Quality Management District - 3 - (draft.February 23,2000) 031