John Trotti

Every once in a while some regulatory body comes up with a scheme that gets my goat, but seldom has one come as close to putting me in orbit as the South Coast Air Quality Management District's (SCAQMD) Rule 1193. This monument to governmental excess establishes a set of prescriptive regulations effectively banning the use of diesel fuel in vehicles weighing 14,000 lb. or more based in the Los Angeles Basin that collect or transfer solid waste, yardwaste, or recyclable materials.

Read 'Em and Weep (Please take the time to do so)

Beginning July 1, 2001, for public and private solid waste collection fleet operators of 50 or more solid waste collection vehicles; and beginning July 1, 2002, for public and private solid waste collection fleet operators of 15 or more solid waste collection vehicles, or a combined total of 15 or more rolloff, transfer, or solid waste collection vehicles, all additions to an existing fleet, or formation of a new fleet, of solid waste collection vehicles shall be by purchase or lease of: (a) alternative-fuel heavy-duty vehicles when adding or replacing solid waste collection vehicles to their vehicle fleet; or (b) prior to July 1, 2002, dual-fuel heavy-duty vehicles when adding or replacing solid waste collection vehicles.

Beginning July 1, 2001, for public and private solid waste collection fleet operators with a combined total of 15 or more transfer or rolloff vehicles, all additions to an existing fleet, or formation of a new fleet, of transfer or rolloff vehicles shall be by purchase or lease of alternative-fuel or dual-fuel heavy-duty vehicles when adding or replacing transfer or rolloff vehicles.

Just so there's no confusion as to what we're talking about here, look at the definitions:

Alternative-Fuel Heavy-Duty Vehicle means a heavy-duty vehicle or engine that uses compressed or liquefied natural gas, liquefied petroleum gas, methanol, electricity, fuel cells, or other advanced technologies that do not rely on diesel fuel.

Dual-Fuel Heavy-Duty Vehicle means a heavy-duty vehicle equipped with a diesel engine that uses an alternative fuel (such as compressed or liquefied natural gas, liquefied petroleum gas, methanol, or other advanced technologies) in combination with diesel fuel to enable compression ignition.

It's All About Clean Air, Right?

That's what SCAQMD says, but if so, why stick it solely to solid waste fleets? Why not extend this to all trucks operating in the LA Basin? Why specifically exclude vehicles that collect or transport hazardous, radioactive, or medical wastes? Indeed, why mandate a revolutionary rather than evolutionary fuel and power plant changeover when neither the technology nor the infrastructure exists to contain costs, nor is there a guarantee of success in achieving anything significant in air-quality improvement?

An answer to all the above is "because they can," but I wonder if it's really that simple. What are the costs? The immediate capital costs are pretty obvious: engine modifications, which run $40,000-$50,000 per vehicle - roughly a 20% increase to the overall price tag; the installation of refueling stands (in the case of compressed natural gas [CNG] something in the neighborhood of $500,000 each); plus the shop and servicing equipment needed to work on the new systems. While these additional costs cannot be regarded as negligible, they don't tell the entire story. Operationally, CNG - the approach obviously favored by the regulation - has some drawbacks because of its relatively low energy-density characteristics that reduce range, performance, and refueling turnaround time. Against a static amount of waste, these deficiencies almost certainly lead to a need for an increased number of vehicles and operators to meet demands.

Stop and think about who gets hurt by this. "Certainly the solid waste activities with 15 or more vehicles," you say. And by extension, of course, all the ratepayers who eventually get the tab. But this kind of simple accounting ignores the disproportionate impact Rule 1193 has on smaller-size operators. Not only is the cost burden very different for those with 20 vehicles versus those with 100 vehicles in terms of relative capital outlay and operating margins, the risks involved in technology and equipment selection are higher as well. While even a small mistake can spell disaster for either, comparatively the smaller activity lies closer to the precipice.

Who Besides Southern California Cares?

Those who experienced the California versus 49-state vehicle situation might remember saying, "They'll never do that to the rest of us." That memory alone should be enough of a wake-up call. But in case it isn't, you might pull out a pencil and paper and see just what Rule 1193 would mean to your operation and your community. And for what? Cleaner air? I don't buy that. In fact, I'll suggest that when all is said and done, the impact of Rule 1193 will be negative. Part of it stems from the increasing number of vehicles and ancillary activities likely to occur operationally, but there's also the implied environmental penalty resulting from the added expenditures involved. If you consider that every dollar carries with it an environmental burden - perhaps a 10-cent pollution penalty in the energy required societywide for its generation - SCAQMD's initiative might not only be fiscally draining, it could prove environmentally harmful as well.

MSW
March/April 2001