California ARB Large Spark Ignition (LSI) Engine Fleet Regulation Amendments

LSI Engine Regulation

 Background

The LSI Fleet Regulation applies to operators of forklifts, sweeper/scrubbers, industrial tow tractors, and airport GSE within California. An LSI vehicle fleet includes off-road gasoline, propane, LPG, CNG, and electric vehicles ≥25 HP. The regulation has been in place since 2006, and imposed target fleet average emission levels (FAELs) that decreased over time, to encourage integration of electric vehicles, newer lower-emitting engines, and retrofit emission control devices into LSI vehicle fleets in the state.

What's New?

CARB amended the LSI rule in the summer of 2016 to include the following additional requirements:

  • By June 30, 2017, all operators subject to the LSI regulation must:
    • Report key LSI vehicle/engine information to CARB; and
    • Label each LSI vehicle with an engine identification number (EIN) assigned by CARB.
  • Going forward:
    • Changes to the LSI fleet (e.g., purchases, leases, sold or retired vehicles) must be reported within 30 days of the change.
    • Additions to the LSI fleet must be labeled with 30 days of receiving the EIN from CARB.
    • The operator must annually (between June 1 and June 30) attest that the reported LSI inventory is true, accurate, and complete.

What do I need to do?

  • Reporting:Report all LSI vehicle/engine information in the online reporting system: https://ssl.arb.ca.gov/ssldoors/doors_reporting/doors_login.html If you have an existing off-road diesel fleet in DOORS, use the same login information, and then create a new LSI fleet. Fleet inventory information can be entered manually or via a bulk spreadsheet upload. Reporting should be completed early enough to meet the labeling deadline of June 30, 2017.
  • Labeling:When a vehicle is reported into DOORS, an EIN is assigned. A label with the EIN must be secured or painted on each vehicle: white characters on red background; characters at least 3” tall by 1.5” wide; affixed 5’ high (or as high as possible). A list of sticker vendors is provided at https://www.arb.ca.gov/msprog/ordiesel/labelvendors.htm
  • Fleet average emission level compliance:CARB has not changed the FAELs, so if your fleet has been in compliance with the fleet emission limits of the rule, this will not change. Because CARB will now have access to the pertinent fleet emission information, it is critical to confirm that your fleet complies with the FAEL limits. The current FAELs are:

Large Forklift Fleet

Medium Forklift Fleet

Non-forklift fleet

1.1 g/bhp-hr HC+NOx

1.4 g/bhp-hr HC+NOx

2.5 g/bhp-hr HC+NOx

Key strategies for lowering your fleet average emissions to comply with the applicable FAEL are: retire older vehicles; designate older vehicles as limited hours of use equipment (<200 hrs/calendar year); replace fueled equipment with electric; replace/repower older equipment/engines with newer equipment/engines; and install retrofit emission control devices on older engines.

Further Information

For more information,https://www.arb.ca.gov/msprog/offroad/orspark/orspark.htm. For help in determining whether these requirements apply to you, analyzing your LSI fleet to confirm or achieve compliance with FAELs, or assistance with online reporting of your LSI fleet inventory, please contact Lara Gertler, Ph.D. (lgertler@algcorp.com, 805-764-6014) at the Ashworth Leininger Group.