Attention Contractors
We need to hear from large fleets that cannot rely on Reduced Activity Credit alone to comply with the Off-Road Regulation’s first compliance deadline (March 1, 2010).
The Construction Industry Air Quality Coalition (CIAQC) is working with its member associations and members to gain additional regulatory relief from the CARB Off-Road Regulation for equipment owners and operators. By March 1, 2010 large fleets (greater than 5,000 total fleet horsepower) must achieve NOx and particulate matter (PM) fleet average target rates or meet Best Available Control Technology (BACT).
Most large fleets will not meet the fleet average target rates for NOx and PM, and will then be subject to the BACT requirements. CIAQC believes many fleets will be able to utilize the Reduced Activity credit provisions approved by the CARB in July to satisfy the March 1, 2010 requirements. However there may be some fleets that did not accumulate enough Reduced Activity credit to fully meet the 8 percent NOx and 20 percent PM retrofit BACT requirements for 2010. In these cases, additional equipment retrofits, repowers, purchases or vehicle retirements will be needed to meet the BACT levels.
If your company will not have enough Reduced Activity credit to comply with the March 1, 2010 requirements, and will need to sell or retire equipment or expend funds to retrofit, repower or purchase newer equipment, we would like to hear from you. To pursue additional regulator relief for the Off-Road Regulation, CIAQC must have a couple real world examples of companies that will not be able to rely on Reduced Activity credits alone to comply with the first compliance deadline.
March 1, 2010 is right around the corner! This does not leave much time and places everyone under a tight time frame to get meaningful changes to the regulation. Please do not hesitate to contact Mike Lewis or Clayton Miller with CIAQC at 626-858-4611 (mike@lewisandco.net or clayton@lewisandco.net) if you think your company is not going to be able to use Reduced Activity credit alone to comply with the March 1, 2010 deadline.