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Frequently Asked Questions
Q: Is ARB and CARB the same thing?
A: Yes, Air Resources Board and/or California Air Resources Board are used interchangeably.
Q: What does ATCM stand for?
A: Airborne Toxic Control Measure
Q: What does PERP stand for?
A: Portable Equipment Registration Program
Q: Are the rules completed or proposed?
A: ATCM & PERP are law and being enforced. On-Road Truck & Bus is at the draft & public education stages. ARB hopes to present the final rule October 2008
Q: What engines are affected by ATCM?
A: Portable engines (not used for propulsion) of 50 bhp and greater fueled with diesel.
Q: What engines are affected by the “ In-Use Heavy-Duty Diesel-Fueled Vehicle” regulations AKA “On-Road Diesel Truck and Bus” Regulation.
A: All heavy duty diesel-fueled or alternative diesel-fueled vehicles of 14,000 GVWR or greater. This includes vehicles entering California from other states, Canada and Mexico.
Q: Is PERP voluntary?
A: The Statewide PERP was established to allow portable engines that travel to two or more Air Quality Management Districts to avoid having to register in each district. If your sweeper never leaves your district, you have a choice to follow the district rules or the Statewide PERP. That we know of, only SQAQMD does not require registration for sweeper auxiliary engines. (However, ATCM will apply)
 CalPortableEngines.html
List of local Districts:
Roster.htm
Q: Are any sweeper manufactures offering to retrofit older trucks?
A: Not that we know of.
Q: Sweepers are exempt from the bi-annual smog checks. Does this apply to these
rules as well?
A: ARB says no. NAPSA-CA is investigating.
Q: I register my sweepers “off-road” with SE plates, am I exempted?
A: No.
Q: I’m very small with only one truck, is there a small fleet exemption?
A: The ATCM has no small fleet exemptions for auxiliary engines. The proposed Truck & Bus rules may allow a few extra years for propulsion engines to comply.
Q: I’ve heard of companies offering to retrofit sweepers with particulate traps. If I spend the $10,000 to $20,000, are they guaranteed to work?
A: There are particulate and NOx issues to consider. Also, only certain year engines are eligible for retrofit and the retrofit device must be pre-approved by CARB. We understand retrofit companies will guarantee their alterations meet CARB rules, but will not certify or indemnify the vehicle owner for safety.
Q: Who else is affected by this?
A: Farming, trucking, construction, large & small business. The California Chamber of Commerce has formed a special coalition on just this issue.
http://drivecleanca.org/
A: All of us. This is not just a business issue. The regulations will cause everything transported or built using diesel engines to cost more.
Q: I’ve heard these laws will actually increase water and air pollution?
A: True. One estimate is an additional 273 Million Tons each year left on our streets.
CA Pollution Set to Jump 2010.pdf
Q: 273 Million tons would affect water pollution, not air pollution, right?
A: Those tons include over 5.4 million tons (per year) of fine particulate matter that when left on the street is “re-entrained” back into the air by passing vehicles, tire surface interaction and wind.
Q: “Re-entrainment”, is that a new issue?
A: This quote from “Street Cleaning Practice” published by the American Public Works Association in 1978 should clarify.
“As early as 1915 concern was expressed about roadways as significant particulate emission sources: vehicular-induced re-entrainment remains an issue today. The National Assessment of the Urban Particulate Problem (EPA study) documented that much of the total suspended particulate (TSP) in specific urban areas can be traced to material re-entrainment from the street surface. This material becomes entrained in the air by natural surface air flows and air flow and tire surface interaction generated by vehicle traffic.
During a three-day driving moratorium in Sweden in 1967 (to change the driving pattern from left to the right side of the road), particulate concentrations dropped substantially, even thought point-source emissions and meteorological condition remained similar. Swedish officials concluded that the vehicles acted like pistons in the narrow streets, causing re-entrainment and moving the particulates to higher elevation.
Researches measured particulate losses for various paved and unpaved roads in Seattle, Washington. The results of that (1973) study….indicate that …cleaning a dirty paved road could reduce these emissions by more than 80 percent.”
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Q: What sweepers are “grandfathered”?
A: None. The main purpose of these laws are to force early turnover of diesel engines.
Q: Why are snow plows and diesel pusher motor homes exempted?
A: Check back, we are waiting for an answer.
Q: Would pollution output be about the same in 2023 with or without these laws?
A: Yes. These rules are just intended to speed things up. (see graph)
Q: I’ve read the links and White Papers, why are the examples using a diesel locomotive for output data and older sweeper studies for the pick up data? Doesn’t this understate your case
A: Very much so.
Q: What do I do next?
A: Educate yourself on how these rules will affect your fleet and future purchases. ARB’s web site is huge and constantly changing. Attend the ARB workshops in person or on-line. Participate by submitting fleet or financial data. (direct to ARB or through NAPSA-CA) Get a feel for what this will cost you, then consider a contribution of time or money to NAPSA-CA The ARB is willing to listen. We need your help to back up what we have to say.
Q: We all want clean air, why should the sweeping industry be exempted?
A: It is not just the sweeping industry that should be exempted. The forced early retirement of thousands of diesel engines will dramatically affect farmers, school districts, transportation and all products moved by truck (especially fuel). Other industries are fighting this even harder. These rules will affect the economy, employment, housing, construction and even state tax revenue.
Since this is a sweeping forum, here are some issues unique to sweeping.
1: The sweeping industry was not told about the ACTM until years after it was enacted. ARB’s public outreach did not include any list that would include our industry.
2: Sweepers have been exempted from emission regulations, since the 1960’s
3: Sweeper trucks are unique vehicles and do not have the same spaces available as other trucks to safely mount retrofits.
4: In relative size, the industry is too small to attract repower and retrofit companies. Those that do consider sweepers require the vehicle owner accept all safety liability.
5: Virtually all sweeping fleets are in-state. Large multi-state truck fleets have the option of just putting their new trucks in California, and sending the older ones elsewhere.
6: Financial infeasibility. After tax and license, new street sweepers are $200,000 to $250,000+. Trucks of a similar size with a simple bed are less than half this cost. Profit margins at small companies are simply not available to pay for new equipment. Sweeping companies can not charge more for new equipment and there are no operational cost savings.
7: Most sweeping contractors do not have long term contracts. Construction and roadway sweeping is on-call and often seasonal. Maintenance work allows at most a 30 day cancellation.
8: Higher prices for sweeping will force cities, private communities and construction sites to sweep less and pay more for it. When sweeping is cut back, air and water pollution increase.
9: The early retirement of thousands of sweeper trucks will negate many of the hoped for gains of these rules, forcing ARB to consider even tougher rules to meet their goals.
10: The cumulative impact of multiple regulations on each sweeper is unreasonable.
11: Technological infeasibility. Emission controls should filter down from engine manufactures. Asking small business to engineer safe retrofits (on multiple engines) on vehicles not designed for them is not an equitable distribution of emission goals.
12: Sweepers are often used in emergencies to get roads open after an accident, after storms and natural disasters.
13: Sweepers spend most of the time traveling at very low speeds and at considerably less than the rated horse power. This further reduces retrofit options as many technologies rely on a predictable engine exhaust temperature.
14: 95% of Sweeping companies in California have 20 trucks or less. Small business are disproportionately burdened by these regulations.
15: As much as 1/3 of each companies fleet are stand-by or back-up trucks. This is a result of three issues. A: Extremely high maintenance requirements. B: Much of the roadwork and construction sweeping is extremely time sensitive with huge monetary penalties for not opening roads on time, or having the site prepped when the materials arrive. Having adequate back-up equipment is critical. C: When sweeper trucks need major repairs, you can’t just go rent one from Hertz or Penske for a few days. This enhances the burden on small companies when upgrading or retrofitting their fleets that fleets in other industries do not share.
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NAPSA California Chapter