Load Carrying Equipment Emissions
An A. & L. Shatto Advisory
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Like it or not, California is setting the pace on air quality, again! On September 24, 1998 the California Air Resources Board (CARB) released a proposed Regulation (Title 13, California Code of Regulations, Chap. 9, Art. 4.5) which requires off-road load carrying equipment, such as forklifts, to meet air emissions standards starting in 2001.  The standards will be similar to the automotive emission standards, since the engines are derived from automotive engines.  The U.S. EPA was involved from the beginning, and will be proposing similar national regulations to take effect in 2004.  The regulators are beginning to take notice of the contribution that off-road equipment makes to air quality.  "So What, Who Cares!" I hear you say.
Please Read On!

The primary, and most obvious effect will be to increase the cost of new fuel-burning, 2004-compliant forklifts and replacement engines.  The expected increase is $500 to $1,000 per unit. Experiments funded by CARB, and supported by equipment manufacturers, indicated that the combined modifications could actually improve fuel economy by as much as 15%.  This could off-set the additional capital cost over the lifetime of the unit.  Whether or not electrically powered equipment will be attractive will depend on charging time improvements, battery capacity increases, and lift and mobility improvement.

Applying some Pessimistic Analysis to this development, we at A. & L. Shatto anticipate that fuel-burning load carrying equipment could be regarded by the regulators as "Fuel Burning Equipment", rather than "Mobile Sources" or "Off-Road Sources" since forklifts remain within facility boundaries and contribute to the total facility emissions.  They would then be regulated like a boiler, and impact your emission inventory and permitting status, possibly changing you from a "Minor" to a "Major" Emissions Source.  Having done such emission inventories for many of our clients, we can assure you that the emissions of load carrying equipment can be quite significant.

• How does this regulatory development affect your forklift purchase plans between now and 2004?

• Have you done an emissions inventory that includes your forklifts with projections to 2004?

• Would you need new equipment?

• Could you do retro-fitting of new engines, or bolt-on devices to control emissions?

• Would a mix of fuel-burning and electric equipment meet your needs?