Red Sticker Regulatory Proposal Workshop
Transcript of Red Sticker Regulatory Proposal Workshop
Red StickerRegulatory Proposal WorkshopMAY 16, 2018 – EL MONTE
MAY 17, 2018 – SACRAMENTO
Outline
• Purpose of CARB Regulation
• Status of CARB Red Sticker Program
• Need for Emission Reductions
• Key Elements of Regulatory Proposal
• Uncontrolled Emissions and Projected Reductions
• Evaluation of Cost Effectiveness
• Rulemaking Timeline and Next Steps
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Why Are We Here?
• California has the worst air quality in the nation
• CARB develops regulations to comply with the federal Clean Air Act requirements
• This regulation will help California obtain the emission reductions needed for ozone attainment
• CARB’s proposed regulations for Red Sticker will help satisfy commitments set in California’s State Implementation Plan
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State Implementation Plan (SIP)
• SIP outlines plan for compliance
• SIP requires reductions from all categories, including mobile sources
• Examples of mobile sources regulated by CARB include cars, trucks, lawn mowers, off-road recreational vehicles, and boats
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OHRV Regulatory History
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1994: CARB adopts 1st
exhaust standards
1998: CARB creates
Red Sticker Program
2013: CARB adopts
evaporative standards;
Board directs staff to conduct
Red Sticker assessment
2006: U.S. EPA adopts
exhaust and evaporative
emissions standards
defines competition
OFF-HIGHWAY MOTORCYCLE (OHMC)
ALL-TERRAIN VEHICLE (ATV)
2017: Board directs staff to
sunset Red Sticker Program
Almost All Red Stickers Are OHMCs
• CARB’s regulation applies to all off-road motorcycles (OHMC) and all-terrain vehicles (ATV) that are certified according to section 2412(f) (Red Sticker)
• According to certification data for MY2012-2016, most Red Sticker vehicles are OHMCs
• The focus of the proposal is on OHMCs
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0
10,000
20,000
30,000
40,000
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Po
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lati
on
Green and Red Sticker Registration Type (MY 2012-2016)
Green Sticker
Red Sticker
Intent Of The Red Sticker ProgramORIGINAL PURPOSE OF PROGRAM ASSESSMENT FINDINGS
Delay 1998 exhaust standards to ensure OHRV availability
Ease transition to cleaner technology
Limit summertime exhaust emissions from OHVs in ozone
non-attainment areas
Over 3 times as many Green Sticker models available than in
1998
Technology has developed, but transition to Green Sticker has not
occurred as anticipated
Red Sticker OHVs are operated in ozone non-attainment areas
during the summer
Allow riders to practice for competitive events on public land
Red Sticker OHMCs are predominately competition vehicles used for recreation
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Status Of CARB Red Sticker Program
• Program was originally develop to be a temporary solution for manufacturers◦ Program still exists more than 20 years later
• Does not provide expected emissions benefits◦ Year round Red Sticker OHMC operation results in uncontrolled exhaust emissions
• Problematic for state agencies◦ Enforcement challenges
◦ Registration difficulties
• Allows for manufacturers to avoid complying with MY2018 evaporative standards
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Drop In Green Sticker Certifications For MY2018
• Implementation year for 2013 evaporative rulemaking more than 75% drop in Green Sticker certification◦ Noted decrease in Green Sticker certification
◦ Green Sticker models moved to Red Sticker certification
◦ No OHMCs have been certified for evaporative compliance
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166204
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0
50
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2016 2017 2018
Red and Green Sticker OHMC Executive Orders Issued by Year
75% drop in Green Sticker
certification
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Evaporative Emissions Comparison
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gram
s R
OG
/day
Red Sticker
Carbureted
OHRV
2018 Passenger
Car Standards
2018 Green Sticker
OHRV Standards
0.35 g/day1
1 g/day2
3x 2018 Car
Emissions
1 Source: 2018 Passenger car limit2 Source: 2018 Green Sticker standard3 Source: CARB test dataRed Sticker
Fuel Injection
OHRV
3.4 g/day3
10x 2018 Car
Emissions
15-26 g/day3
40-70x 2018 Car
Emissions
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g H
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i
2018 Passenger
Car Standards
Exhaust Emissions Comparison
Red Sticker
2-Stroke OHRV
2018 Green Sticker
OHRV Standards
0.075 g/mi1
1.9 g/mi2
25x 2018 Car
Emissions 1 Source: CARB LEV III Standard2 Source: CARB OHRV Emissions Standard3 Source :CARB Emissions Testing 2015
Red Sticker
4-stroke
OHRV
2.6 g/mi3
35x 2018 Car
Emissions
34.2 g/mi3
456x 2018 Car
Emissions
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Calendar Year
Current Population of Recreational Vehicles
All Other Recreational VehiclesOHMC Green StickerOHMC Red StickerOHMC Red sticker G2
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Population Of OHRVs
<20% of population
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RO
G (
tpd
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Calendar Year
Updated Distribution of ROG (tpd) from Recreational Vehicles*
All Other Recreational VehiclesOHMCOHMC Red StickerOHMC Red Sticker G2
*Statewide Summer
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Statewide Summer ROG Emissions
70% of emissions
CARB Priorities For A Regulatory Proposal
1. Reduce emissions◦ Eliminate future sales of uncontrolled vehicles
◦ Realize expected benefits of 2013 evaporative rule
◦ Set stage for future emission reductions
2. Eliminate inconsistency with federal rules
3. Reduce enforcement burden of existing Red Sticker Program
4. Minimizing impact to vehicle availability
5. Accelerate development and adoption of zero-emissions OHRV
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Key Elements Of Regulatory Proposal
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Step I: Sunset Red Sticker Program Establish date to end the sale of Red Sticker OHVs
Transition to green sticker controls
Step III: Evaluate New Emissions Standards
Transition to cleaner engine technologies Incentivize zero emission technologies
Step II: Clarify Racing Exemption Define competition
Protect exemption for true racing purposes
Step I: Sunset Red Sticker Program Establish date to end the sale of Red Sticker OHRVs
Transition to Green Sticker controls
Step II: Clarify Racing Exemption Define competition
Protect exemption for true racing purposes
Sunset Red Sticker Program
• Eliminate Red Sticker sales – MY2022
• Establish two emissions categories for off-highway motorcycles, cap percentage of Category 2 and reduce over time
◦ Both categories are CARB certified, no usage restrictions
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Exhaust Evaporative Comments
Category 1(CARB)
1.2 g/km HC 1 g/day TOG • No change
Category 2(U.S. EPA)
2.0 g/km HC + NOx Hose/tank perm• Fleet averaging is allowed• Most Red Sticker 4-strokes can meet this
Step I
Sunset Red Sticker Program (Cont.)• Cap the percentage of Category 2 OHMCs that can be sold - reduce percentage over time, transition to Category 1
• ZEM sales provide incentives in percentage and fleet average
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Model Year Maximum Percentage of Category 2 off-road
motorcycles that may be sold
2022 55%
2023 45%
2024 35%
2025 25%
2026 15%
2027 5%
2028 0%
Step I
• Starting on January 1, 2025:◦ No seasonal restrictions for Red Sticker vehicles
◦ All the restricted riding areas will now allow for year-round riding
◦ Existing Red Sticker bikes will be grandfathered in
◦ Registration sticker may be either green or red, no difference in access or registration
Lifting Red Sticker Riding Restrictions
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Step I
• Uncertified vehicles can still be sold◦ Closed course, competition only
• Public OHV areas with private tracks/racing events will still allow competition riding ◦ Ex: Hollister Hills, Prairie City, Carnegie, etc.
• CARB will work with dealers and manufacturers to inform riders about use of competition vehicles
What About Competition OHMCs?
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Step I
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RO
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NO
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Ton
s/d
ay)
Calendar Year
Baseline vs. Regulatory Proposal
Emission Reductions From ProposalStep I
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OHMC EmissionsBusiness as Usual
OHMC Regulatory Proposal
Emissions Reductions Are Significant
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Ton
s R
OG
Per
Day
Board Hearing Year
Emission Reductions from Recent Regulations
Motor Vehicles*(Car Scrap)
Gas Dispensing Facilities
Aerosols
OHRV Evap
Marine Watercraft
Red StickerProposal
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Step I
* - ROG + NOx
UTV, 10773, 39%
ATV, 6592, 24%
OHMC Green, 4775, 18%
OHMC Red 4-Stroke, Fuel Injected, 2782, 10%
OHMC Red 4-Stroke, Carbureted, 258, 1%
OHMC Red 2-stroke, 2152, 8%
2016 Model Year OHRV Registered in California
Industry-Wide: Model Availability Will Not Be Significantly Impacted
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Step I
Additional Proposed Regulatory Changes
• Lower displacement consideration for evaporative requirements◦ Section 2416(b)
• Additional evaporative test fuel ◦ TP-933
• Zero-emission definition/credits◦ Section 2411
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Step I
Evaluation Of Cost Effectiveness
• Cost effectiveness is a key consideration when the Board decides to approve or reject the staff’s proposal
• Cost effectiveness is a ratio of a OHMC’s estimated increased retail cost divided by the projected lifetime emission reductions ($/lb)
• Evaporative costs• Accounted for in 2013 Rulemaking
• Exhaust costs◦ Certification and testing costs to meet Category 1/2
◦ CARB is seeking incremental costs from manufacturers to comply from Category 2 to Category 1
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Marine Watercraft
Aerosols
OHRVs
Gas Dispensing Facilities
Motor Vehicles*
$0.00
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
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2008 2009 2010 2011 2012 2013 2014 2015 2016
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llars
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(RO
G)
Board Hearing Year
Historical Cost Effectiveness
Step I
* - ROG + NOx
Rulemaking Timeline
• Receive and evaluate stakeholder comments – June 15, 2018
• Finalize proposal, staff report, and fiscal/economic analysis – July 2018
• Documents released for formal comment period – September 4, 2018
• Board Hearing – October 25, 2018
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Step I
Clarify The Racing Exemption
• Develop single competition definition for all categories
• Protect exemption for true racing purposes• Provide clarity on exempted vehicle use
• Eliminate excess emissions associated with misuse
• Rulemaking by Enforcement Division – Early 2019
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Step II
Evaluate Further Emission Reductions
• Evaluate the need for more stringent standards for OHRV◦ Conduct control technology assessment
◦ Perform economic analysis/cost surveys
• Evaluate additional zero emissions vehicle incentives
• Encourage development of zero-emissions competition classes
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Step III
Scott Monday– Staff Air Pollution Specialist – Red Sticker Project Lead
(916) 445-9319, [email protected]
Scott Bacon – Manager
(916) 322-8949, [email protected]
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For more information and to sign up for our list serve, please visit:
http://www.arb.ca.gov/msprog/offroad/orrec/redsticker.htm
Contacts