CARB’s LSI Regulations Begin January 1, 2009 – Are Your Forklifts Ready?

The California Air Resources Board’s Large-Spark Ignited (LSI) regulation will soon require users of propane-fueled and other types of spark-ignited forklifts, sweepers/scrubbers, towmotors, and airport ground support equipment with more than 25 horsepower each to meet special fleet-averaged emission levels and record-keeping requirements by January 1, 2009.  These rules were adopted in 2006 and became law in mid-2007.

The new regulation has lots of twists and turns, but what follows here are some of the basic requirements that affect the owner-operators of propane-fueled forklifts—the most popular type of LSI equipment. CARB designed this regulation to require that fleets of four or more forklifts meet specific reduced emissions rates focused on NOx (oxides of nitrogen).  If you or your customers use propane forklifts in California, compliance with these requirements is critical.  Failure to comply can result in penalties of $500 per day per piece of non-compliant equipment as of January 1. This article will help you understand certain important portions of the regulation, but for all requirements, see the regulatory language and information at http://www.arb.ca.gov/msprog/offroad/orspark/orspark.htm and a “frequently asked questions” document at http://www.arb.ca.gov/msprog/offroad/orspark/documents/faq7_08.pdf. 

The LSI regulation already requires that a propane forklift fleet owner keep detailed records for each forklift—including serial numbers, model, year, and the factory emission rate or the emission rate of a retrofitted “controlled” lift.   And on January 1, 2009, a fleet of four or more forklifts must meet specified fleet-averaged emissions values for each one that runs more than 251 hours per year.  What makes a “fleet”? Three lifts or fewer is a small fleet, 4 – 24 lifts is a medium-sized fleet, and 25 or more is a large fleet. Only medium and large fleets must meet the fleet-averaged emission requirements. 

If you rent or lease forklifts, the regulation applies, but in different ways depending on how many you rent and for how long.  If you or your customers rent or lease, the regulation still applies, so be sure to discuss this with the rental or leasing company.  And agricultural lifts?  They have specific compliance requirements, so please consult the LSI regulations. Riding electric lifts reflect a zero-emission rate, so if your fleet has some electrics, you will factor in their zero-emission rate in your overall fleet average.  Nearly all propane-fueled forklifts 2007 model year or later will also have lower emission rates that will help you meet the LSI regulation’s fleet-averaged emission requirements.  The table below shows fleet emissions requirements by number of equipment and the dates for compliance.

Forklifts are required to have a data plate in the engine compartment, so use it for record-keeping and to determine your lift’s emissions rate, model year, etc.   Year 2000 and older lifts, along with some “uncontrolled” lifts from 2001 – 2003 use an emission rating of 16 g/kw-hr (12 g/bhp-hr).  Lifts that came with controls from the factory in 2001 – 2003 use 4 g/kw-hr (3 g/bhp-hr) for a rating.  So do lifts built 2004 – 2006. Lifts built in or after 2007 use 2.7 g/kw-hr (2 g/bhp-hr).   Check the data plate or placard in your lift’s engine compartment—it will help you determine its emission rate.  If your fleet average emission rate is above the values shown above, you must reduce it by replacing a forklift, repowering forklifts with new engines, and/or retrofitting lifts by adding an aftermarket conversion system.  You must do any of these to an appropriate number of your lifts to meet or beat the average.

In some cases, retrofitting a lift makes good sense if CARB-verified aftermarket conversion kits are available for it.   But be certain that those retrofitted lifts only use CARB-verified systems with a placard affixed to the engine on installation.  Retrofits can reduce emissions down to 1.3 g/kw-hr for many older lifts—1990 through 2000, with some uncontrolled lifts 2001 through 2003—if they have 3-liter or smaller engines.  For larger engines of the same vintage, retrofits will provide a 4 g/kw-hr emission rate.  If you bought a 2001 – 2006 lift with factory emission controls, no currently CARB-verified retrofit system is available to reduce its emissions even more. And unfortunately, forklifts in these years will not by themselves be able to  meet the LSI regulation’s fleet-average emission requirements.  However, IF you have older lifts (1990 – 2000, or 2001 – 2001 uncontrolled), you have a good chance of finding a very-low emission retrofit system.  Retrofitting older lifts may make sense to achieve the CARB fleet-average emission value.  Or you may wish to add 2007 or later propane lifts, or a few electrics.

LPG Forklift Retrofits—Cost and Availability

Two manufacturers currently sell CARB-verified retrofits for forklifts.  Not all models of lifts are covered, so you’ll need to contact the retrofit manufacturers to determine if they have product that can work on yours or your customers’ lifts.  Nett Technologies (www.nett.ca) sells the “BlueCat” system—contact Wayne Borean at Nett in Canada: (800) 361-6388 ext. 124.  Nett Technologies has a helpful spreadsheet available online that you can use to enter your equipment numbers and emission rates, and to calculate the numbers of lifts you’ll have to retrofit, repower, or replace.  Another company, Engine Control Systems (ECS), (www.enginecontrolsystems.com/terminox) sells the TermiNox system—contact Wayne Cochrane at (775) 376.2664.  Costs for the kits from these two companies and what you will pay locally for installation vary. We’ve been told they range from about $2,500 to nearly double that for some lifts.  

Depending on the forklift’s year of manufacture and its engine size, these systems can deliver large emission reductions so that your equipment can better meet the CARB fleet-averages.  Three-liter and smaller engines, 1990 – 2000 (or uncontrolled engines 2001 – 2003) drop from 16 g/kw-hr to 1.3 g/kw-hr.  Larger engines (over 3 liters) in the same age ranges will see their emissions go from 16 g/kw-hr down to 4 g/kw-hr.  Note, however, that 4 g/kw-hr is not, by itself, low enough to meet the CARB fleet-averaged emissions requirements.

Compliance Extensions—Can You Qualify For A One Year Extension?  How?

CARB’s LSI regulation says that “an operator may be granted an extension for compliance of up to one year if there is either no verified retrofit system available OR there is insufficient supply of verified system in the marketplace.  Forklifts built between 2001 and 2006 were certified at a rate above the current CARB fleetwide emission averages and therefore they cannot by themselves attain the LSI standard.  And currently there are no CARB-verified retrofits that would reduce their emissions to or below the fleet-averaged emission standard that starts on January 1, 2009.   Will CARB permit a one-year extension for forklift fleet operators who have a high proportion of those model years in their fleet?   WPGA continues to request clarification on this from CARB and will pass this along as soon as possible since you must have your request for an extension approved by CARB before the LSI fleet-average emission requirements start on January 1.   We recommend that you not wait, however, and that you and your propane customers begin immediately to calculate those important fleet-average emissions and determine compliance strategies that will meet the deadline.

For more information on the LSI requirements, please see CARB’s website at http://www.arb.ca.gov/regact/lore2006/lore2006.htm or contact WPGA at (916) 447-9742.