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Non-Road Diesel Engines Regulatory Initiative
Discussion Guide 

Please complete this Discussion Guide by Friday, January 15, 2010.

This Discussion Guide accompanies the presentation provided at three public workshops held by Metro Vancouver. Download the public presentation here. 

Presentation from Public Workshops

If you would prefer to download your own copy of the Discussion Guide and submit it through mail or fax, it is available here:

 Discussion Guide 

If you have any questions about the Non-road Diesel Engine Initiative, please contact Derek Jennejohn, Senior Project Engineer at Metro Vancouver by phone at 604-436-6744 or by email at aqbylaw@metrovancouver.org.

*Note: Personal information and input contained in this Online Discussion Guide will be compiled with other public responses and may be included in a report to the Metro Vancouver Board of Directors. Such reports are available to the public. In addition, personal information may be used for Metro Vancouver follow-up mailings.

* - Mandatory Fields

* Name:

 
* E-Mail:
 
 
Organization:


Mailing address:


City:


Phone:

Fax number:


How does the Non-road Diesel Engine Initiative affect you?
   


1. Metro Vancouver’s Diesel Emission Reduction Program
Reducing diesel emissions is the most important step we can take to improve air quality and public health in Metro Vancouver and the most effective means of quickly reducing climate change effects. In February 2009, the Metro Vancouver Board of Directors approved the Diesel Emission Reduction Program for Metro Vancouver. The Program includes the public and private sector Non-road Diesel Engine Initiatives and collaborative initiatives with industry and senior government to reduce diesel emissions from marine vessels, railway locomotives, and on-road diesel vehicles. Under provincial legislation (the Environmental Management Act), Metro Vancouver has the delegated authority to provide the service of air pollution control and air quality management in the region.

The Metro Vancouver Diesel Emission Reduction Program


1. Please provide your comments regarding the Metro Vancouver Diesel Emission Reduction Program in the space below:



2. Private Sector Non-road Diesel Engine Initiative - Framework

2.1 Vision
Metro Vancouver is proposing to develop regulatory requirements that would accelerate the phase-out or upgrade of diesel machines with Tier 0 and Tier 1 engines.

This would be achieved through a combination of:
  1. Regulatory Requirements:
    • Based on the emission standards, or “tiers”, an engine meets.
  2. Economic Incentives:
    • The Non-road Diesel Engine Incentive Fund would assist owner/operators with the cost of retrofitting or upgrading Tier 0 and Tier 1 engines.
    • The fund would be financed in part by regulatory fees collected from owner/operators of non-retrofitted or non-upgraded Tier 0 and Tier 1 engines, and also by financial contributions from senior levels of government.
A Tier 0 engine is one that was made before there were emission standards. A Tier 1 engine refers to any engine that was made to meet the first emission standards, which came into effect around 1996.

2.a. Please provide your comments regarding the Non-road Diesel Engine Initiative description in the space below:


3. Private Sector Non-road Diesel Engine Initiative - Overview

3.1 Goal and Objectives

3.1.1 Goal
The initiative aims to:
  • Reduce emissions of diesel particulate matter (PM) from non-road machines.

3.1.2 Objectives
In achieving this goal, the objectives are to:
  • Minimize the risk to human health by reducing exposure to diesel PM emissions;
  • Develop regulatory requirements to promote retrofitting, re-powering or replacement of older, polluting non-road diesel engines; and
  • Establish an incentive fund (with senior government funding and regulatory fees) to provide funding for diesel emission reductions.


3.2 Machines included in the regulation:
  • Non-road diesel machines with 25 horsepower or greater engines.
Examples of machines included in the regulation: cranes, excavators, graders, loaders, pavers, skid steers, cargo handling equipment, commercial lawn and garden machines, compressors, generators and pumps.

The regulation will not include machines such as marine vessels, line haul locomotives, on-road diesel vehicles, agricultural, forestry, recreational equipment and standby generators.

3.3 Emission Standards

3.3.1 Tier 0:
  • Engines made before there were emission standards

3.3.2 Tier 1:
  • Engines made to meet the first emission standards which began to be phased-in in 1996

3.3.3 Tier 2, 3 and 4:
  • Engines with more recent emission standards
  • Engines with significant diesel PM reductions

3. Please provide your comments regarding the Non-road Diesel Engine Initiative overview in the space below:



4. Regulatory Requirements

An emission regulation for non-road diesel machines with 25 horsepower or greater operating in Metro Vancouver could include the following requirements:

4.1 Administrative Requirements:


4.1.1 Registration

The requirement for registration says that:
  • Tier 0 and Tier 1 machines must be registered with Metro Vancouver beginning in 2012.

4.1.2 Labelling


The requirement for labelling says that:
  • Machines with Tier 0 engines must be labelled with the text “T- 0” (either paint or decal), beginning in 2012.
  • Machines with Tier 1 engines must be labelled with the text “T-1” (either paint or decal), beginning in 2014.

4.1.3 Record-Keeping

The requirement for record-keeping says that:
  • Under the regulation, the hours of use for low-use machines must be recorded and made available for inspection by Metro Vancouver.

4.a. Do you support the administrative requirements described above?

Please explain:



4.2 Technological Requirements

4.2.1 Opacity Limits

The requirement for opacity says that:
  • Opacity of emissions must not exceed 20%, except during the first minute of startup.


4.2.2 Idling Restrictions

The requirement for anti-idling says that:
  • Engines must not idle more than five minutes in accordance with anti-idling procedures (as prepared by the owner); and
  • Machine operators must read anti-idling procedures.

4.b. Do you support the technological requirements described above?

Please explain:



4.3 Fees

Metro Vancouver’s Non-road Diesel Engine Emission Regulation includes the collection of regulatory fees from owners/operators of non-road diesel Tier 0 and Tier 1 engines. Some engines are exempt from these fees.

4.3.1 Fees


The requirement for fees says that:
  • Annual Tier 0 fees are payable for machines with Tier 0 engines that operate in Metro Vancouver, beginning in 2012.
  • Annual Tier 1 fees are payable for machines with Tier 1 engines that operate in Metro Vancouver, beginning in 2014.
  • Tier 0 and Tier 1 fees are assessed on a per horsepower basis and increase on an annual basis.
  • For machines that operate on a limited basis, monthly or low-use (i.e. less than 100 hours annually) fees could be paid instead.


4.3.2 Fee Table

Year

Tier 0 Fees ($/engine hp)

Tier 1 Fees ($/engine hp)

Annual

Low-use

Monthly

Annual

Low-use

Monthly

2012

4.00

1.00

1.00

--

--

--

2013

6.00

1.50

1.50

--

--

--

2014

8.00

2.00

2.00

4.00

1.00

1.00

2015

10.00

2.50

2.50

6.00

1.50

1.50

2016

14.00

3.50

3.50

8.00

2.00

2.00

2017 +

20.00

5.00

5.00

10.00

2.50

2.50



4.3.3 Fee Examples

i. Fee Example #1
A Tier 0 machine such as a skid steer loader with a 50 hp diesel engine would pay the following fee:


Year

Annual

Low-use

Monthly

2012

 $     200

 $       50

 $       50

2013

 $     300

 $       75

 $       75

2014

 $     400

 $     100

 $     100

2015

 $     500

 $     125

 $     125

2016

 $     700

 $     175

 $     175

2017 +

 $   1,000

 $     250

 $     250



ii. Fee Example #2
A Tier 0 machine such as an excavator with a 375 hp diesel engine would pay the following fee:

Year

Annual

Low-use

Monthly

2012

 $   1,500

 $     375

 $     375

2013

 $   2,250

 $     563

 $     563

2014

 $   3,000

 $     750

 $     750

2015

 $   3,750

 $     938

 $     938

2016

 $   5,250

 $   1,313

 $   1,313

2017+

 $   7,500

 $   1,875

 $   1,875


iii. Fee Example #3
A Tier 1 machine such as skid steer loader with a 50 hp diesel engine would pay the following fee:

Year

Annual

Low-use

Monthly

2012

 $        -  

 $        -  

 $        -  

2013

 $        -  

 $        -  

 $        -  

2014

 $     200

 $       50

 $       50

2015

 $     300

 $       75

 $       75

2016

 $     400

 $     100

 $     100

2017+

 $     500

 $     125

 $     125


iv.  Fee Example #4
A Tier 1 machine such as an excavator with a 375 hp diesel engine would pay the following fee:


Year

Annual

Low-use

Monthly

2012

 $        -  

 $        -  

 $        -  

2013

 $        -  

 $        -  

 $        -  

2014

 $   1,500

 $     375

 $     375

2015

 $   2,250

 $     563

 $     563

2016

 $   3,000

 $     750

 $     750

2017+

 $   3,750

 $     938

 $     938



4.3.4 Fee Exemptions

The requirement for fee exemptions says that:
  • No fees would be payable for any engine that meets Tier 2 standards or better, including:
    • Engines that were originally manufactured to meet the Tier 2 standard;
    • Tier 0 or Tier 1 engines that have been re-powered, retrofitted or otherwise upgraded to meet the Tier 2 standard.
  • Any Tier 0 engine that has been re-powered, retrofitted or otherwise upgraded but does not meet the Tier 1 standard will pay Tier 1 fees (beginning in 2014).
  • Any Tier 0 or Tier 1 engine that has been re-powered, retrofitted or otherwise upgraded to exceed (i.e. be better than) the Tier 1 standard, but does not meet Tier 2, will be exempt from fees through 2016, and will pay Tier 1 fees beginning in 2017.
  • Any re-powers, retrofits or other upgrades performed to meet the Tier 2 standard would require technology that has been verified to reduce diesel particulate matter emissions by the U.S. Environmental Protection Agency (EPA) or California Air Resources Board or alternatively determined by Metro Vancouver’s District Director to meet similar emission standards.

4.3.5 Compliance and Enforcement

The emission regulation would apply to non-road diesel engines that operate in Metro Vancouver, including any machines that may be based outside Metro Vancouver but are temporarily operating within the region. Metro Vancouver officers will be responsible for the compliance and enforcement of the regulation. The compliance and enforcement requirement says that:
  • Contravention of this regulation would be an offence and in accordance with the Environmental Management Act may result in regulation notice ($500 maximum), ticket ($1,000 maximum), fine ($1,000,000 maximum) or imprisonment.
4.c. Do you support the fee and compliance mechanism requirements described above?

Please explain:



5. Non-road Diesel Engine Incentive Fund for Engine Owners

In addition to the regulation, the other way Metro Vancouver would like to meet its goal to reduce emissions of diesel particulate matter from non-road machines is to establish the Non-road Diesel Engine Incentive Fund for owner/operators. The incentive fund:
  • Would provide economic assistance to owner/operators for Tier 0 and Tier 1 engine re-powers, retrofits or other upgrades.
  • Would be established through a combination of regulatory fees and provincial and federal government contributions, if approved.
  • Could be administered, and funding decisions made, by a collaborative group that could include industry and government representatives.
The collaborative group would be responsible for determining how it operates, including components such as establishing funding criteria, determining a process for decision-making (e.g. competitive, based on emissions reduced per dollar), funding allocation (e.g. how to distribute amongst sectors) and funding proportions (e.g. % funding for retrofit, re-power, replace).

5.1 Incentive Fund Qualification

In order to qualify for incentive funding, any engine re-powers, retrofits or other upgrades would require technology that has been verified, conditionally verified or certified to reduce particulate matter emissions by the U.S. Environmental Protection Agency (EPA) or California Air Resources Board, or alternatively determined by Metro Vancouver’s District Director to achieve similar emission reductions.

5.a. Do you support the incentive fund requirements described above?

5.b. Please provide your comments on the proposed Non-road Diesel Engine Incentive Fund:




5.c. Please provide your comments on the qualifications required to receive incentive funding:



6. Additional Comments


6. Are there any alternatives to the regulatory framework and incentive fund proposed above that should be considered by Metro Vancouver?



7. Working Group
Metro Vancouver is developing a working group to review and discuss aspects of the initiative that require further consideration before the initiative is presented to its Board of Directors. It is anticipated that a working group would comprise decision makers in small, medium and large companies affected by the regulation, industry associations, equipment and emission control suppliers and Metro Vancouver staff. It is expected that the group will meet four to six times beginning in 2010.

7. Are you interested in participating in the working group?
If yes, please ensure we have your contact information on the top of this discussion guide.

8. Timeline and Consultation Process

8.1 Timeline

In January 2009, Metro Vancouver’s Board of Directors approved the Diesel Emission Reduction Program, which includes the Non-road Diesel Engine Initiative.

Diesel Emission Timeline

8.2 Consultation Process

Metro Vancouver invites feedback on the content of this discussion guide by January 15, 2010. Feedback will be considered by Metro Vancouver and will help frame the discussions of the working group.

Based on the outcome of the consultation process, Metro Vancouver intends to finalize the regulation and present it to the Metro Vancouver Board for their consideration in 2010.

Further information and background on the initiative is available at: www.metrovancouver.org/services/permits/DieselEmissions


8. Please provide your comments regarding the timeline and consultation process for the initiative in the space below:




8.b. If you attended one of the workshops in November or December, how did you hear about the workshops?

   


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