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Commercial Truck Idling: Federal & State Laws Create Air Emissions and Energy Efficiency Challenges and Opportunities
-Size & Nature of the Problem. Each year, idling of commercial truck engines consumes billions of gallons of gasoline and diesel fuel. The exact amount of fuel consumed by idling is not known, but a recent analysis performed by Argonne National Laboratory, using conservative assumptions, estimated the amount of fuel consumed by workday and overnight long duration commercial truck idling may exceed three billion gallons a year. See “Estimation of Fuel Use by Idling Commercial Trucks, Argonne National Laboratory, Page 17: http://www.transportation.anl.gov/pdfs/TA/374.pdf. The greatest share of fuel consumed by truck idling comes from Class 8 Vehicles, trucks with a gross vehicle weight of 33,000 lbs or more. Id., page 4. Class 8 trucks include the long haul trucks (many equipped with sleeper cabs) that are commonly referred to as semi-trailers.
Idling does not merely consume enormous amounts of fuel; it also generates large amounts of air pollution. The EPA’s Smartway Transportation Partnership website indicates that long duration truck and locomotive engine idling produces annual air emissions of 11 million tons of carbon dioxide, 200,000 tons of oxides of nitrogen and 5,000 tons of particulate matter. (See http://www.epa.gov/smartway/idling.htm).
There is also concern that increased air pollutant concentrations caused by idling trucks may be harmful to the health of their occupants and occupants of vehicles parked nearby. A recent EPA-funded study of air pollution inside and outside trucks idling at a large truck stop indicated that in-cab fine particulate matter concentrations and nitrogen dioxide concentrations were higher than some USEPA ambient air quality standards. A second study indicated that PM2.5 concentrations measured at a truck stop near a federal highway interchange not only often exceeded the National Ambient Air Quality Standards, but were highest at night, suggesting that the emissions came primarily from idling truck engines, rather than the busier daytime traffic. (See Miller, et al, “Diesel Truck Idling Emissions: Measurements at PM2.5 Hot Spot, Paper No. 2609 (Presented at the Transportation Research Board 2007 Annual Meeting), “Air Quality Measurements Inside Diesel Truck Cabs” (2005), and “Measuring Air Pollution Inside and Outside of Diesel Truck Cabs” (2005), http://www.epa.gov/smartway/documents/incabairquality-110405.pdf.
Finally, truck idling consumes a significant portion of a truck engine’s operating life, leading to increased maintenance and engine rebuild expense Many large trucking companies offer their drivers financial incentives to keep the number of idling hours below certain thresholds, such as 30% of the total hours the engine is operating. The problem of truck idling is well known in the trucking industry but despite its enormous impact has only recently begun to receive attention in the mainstream media, See, e.g., “Call of the Truck Stop: Gentlemen Stop Your Engines” (New York Times, March 7, 2007).
Why So Much Idling? For many long haul truck drivers, their truck is their second home. They are on the road for weeks at a time, essentially living out of the truck’s sleeper cab when they are not driving. The primary reason long haul trucks idle is to provide truck drivers climate control comfort by running the truck’s HVAC systems during cold and hot weather conditions. Another important reason is so that truckers can provide electricity to a growing array of appliances in their vehicles, including refrigerators, televisions, and microwave ovens.
In addition, long haul truckers spend a good deal of time waiting – waiting to make deliveries, waiting at border crossings and waiting to pick up loads for delivery. Last, but not least, truck drivers spend significant periods of time waiting to satisfy the safety-related requirements of the federal Hours-of-Service regulations of the Federal Motor Carrier Safety Administration, 49 CFR Part 395. These rules establish maximum limits on the number of consecutive hours that Commercial Motor Vehicle drivers may drive and mandate minimum length rest periods.
Workday truck idling also appears to be more prevalent than previously realized. A very large number of vehicles, including not only long haul trucks, but also utility service vehicles, ambulances, police vehicles and many other types of vehicles require the ability to provide electric power for extended periods of time while they are stationary. For the overwhelming majority of these vehicles, engine idling keeps this power flowing. The number of idling hours per vehicle is not as large as the idling hours of each long haul truck that idles overnight, but the collective impact is very large, perhaps several times the impact of overnight truck idling.
State & Local Regulations. The air emissions impact of truck idling is significant enough that a growing body of state and local regulations now place limits on truck idling. As of December, 2006, part or all of 20 different States and the District of Columbia had in place some form or another of idling regulation. See Compendium of Idling Regulations compiled by the American Transportation Research Institute, on the web at http://www.atri-online.org/research/idling/Truck_Idling_Regulations.htm. While these laws are local in scope, their cumulative effect has been to create a network of jurisdictions that a long haul trucker is increasingly likely to have to pass through in order to bring goods to market. State and local anti-idling laws typically limit the time that a truck may idle and impose civil and criminal fines for non-compliance. While fines for first offenses are typically small, several jurisdictions authorize the levying of fines as large as $25,000 to $50,000, plus the prospect of prison time.
Perhaps the most noteworthy of these state and local laws in their impact are the anti-idling regulations of the California Air Resources Board (CARB). The CARB anti-idling rules, found in Title 13 of the California Code of Regulations, are comprehensive in their scope and detailed in their application. They apply to drivers of diesel-fueled commercial vehicles with a gross vehicle weight rating of more than 10,000 pounds when they are operating in California, even if their vehicles are not based in California.
The CARB anti-idling rules currently impose a 5 minute idling limit at any location, with limited exceptions, including when “idling of the primary diesel engine is necessary to power a heater, air conditioner, or any ancillary equipment during sleeping or resting in a sleeper berth.” Title 13, California Code of Regulations. Section 2485(d). Within 100 feet of a “restricted area” which “means any real property zoned for individual or multifamily housing units that has one or more such units on it”, Title 13, California Code of Regulations. Section 2485(h)(16), the regulations are even tighter, and even limit the operation of diesel fueled auxiliary power systems (i.e., a reduced-sized diesel generator that functions as an idle reduction solution) to five minutes.
Effective January 1, 2008, the CARB anti-idling rules will become significantly stricter. First, the exemption for trucks with sleeper cabs will disappear and they will be subject to the 5 minute idling limit. Second, diesel fueled auxiliary power systems for trucks with 2007 and newer engines must be California-certified to be permitted to continue to be used as idle reduction solutions. Third, all 2008 and subsequent model-year heavy-duty diesel engines must either be equipped with a non-programmable automatic engine shutdown system that shuts the idling engine down after a minimum period of time or must be certified to a NOx idling emission standard of 30 grams per hour. Fourth, fuel-fired heaters operated on trucks with 2007 or newer engines must meet emission standards specified in California's Low Emission Vehicle Program (LEV II program). Heavy duty diesel engines in certain vehicles, including school buses, recreational vehicles, and military tactical vehicles will be exempt from these new requirements. Title 13, California Code of Regulations. Section 1956.8(a)(6).
Technology Options Offer Road to Legal Compliance and Energy Efficiency. To enable trucks to comply with State and local idling restrictions and to mitigate the economic impact of the fuel consumed and engine wear that results from excessive idling, a vibrant idle reduction industry has recently emerged. Technology options that are commercially available include:
· Auxiliary Power Units (APUs). An APU is a reduced-size diesel generator that substitutes for the truck’s main engine in powering the truck’s heating and cooling systems and electrical appliances. APUs use far less fuel than the engines for which they substitute.
· Truck Stop Electrification. Truck stop electrification enables a truck equipped with on board power infrastructure to “plug in" to the electrical grid to provide the necessary electric power for the truck’s heating and cooling systems and electrical appliances. To date, a limited number of truck and rest stops offer this option.
· Battery Powered/Hybrid Systems. These solutions capture energy generated while the truck is in motion and use it to charge a bank of high-performance batteries so it is available to power the necessary systems and appliances when the truck is stopped.
· Thermal Energy Storage Solutions. Thermal energy storage systems store cooling energy from the vehicle's air conditioning system while the vehicle is in operation. The stored energy can be used at a later time for cab or sleeper berth cooling during periods of rest. Such systems only provide cooling, but can be paired with a fuel-fired heater for a complete heating and cooling package.
Factors evaluated by truck owners in choosing among the growing array of idle reduction solutions are performance, up-front cost, maintenance expense and weight. For the time being, idle-reduction systems are after market systems installed on trucks after their manufacture. However, it is likely that in the not too distant future, idle elimination systems will be built in to new vehicles from the factory.
State Idle-Reduction Incentive Programs. While idle reduction systems are very cost effective in terms of payback periods, many small truck fleet owners and operators lack ready access to the capital it takes to retrofit their vehicles. To address this concern and promote better idling practices, a growing number of State programs provide grant funds or financing to assist truck owners and operators in retrofitting their trucks to comply with applicable laws.
An example of a typical such program is the Wisconsin Diesel Truck Idling Grant Program. This program provides $1,000,000 of annual grant funding to Wisconsin-based truck owners that is used to pay up to 70% of the cost of purchase and installation of idle reduction systems. The number of vehicles eligible for grant funding depends upon the size of the fleet. The program requires that successful applicants report their post-installation results. Applicants who seek funding for more than a single idle reduction unit are required to utilize more than a single maker and type of idle-reduction systems. These requirements will enable the funding agency, the Wisconsin Department of Commerce, to develop a performance baseline for various idle reduction solutions.
Three good sources of information for persons interested in learning more about idle reduction laws and grant programs, are the West Coast Collaborative website (For a list with links to the current programs, see http://www.westcoastdiesel.org/programs.htm.), the American Transportation Research Institute website, http://www.atri-online.org/, and the U.S. Department of Energy’s “National Idling Reduction Network News” newsletter, http://www1.eere.energy.gov/vehiclesandfuels/resources/fcvt_national_idling.html