Based on a long-standing consensus, any trend that began in California - whether social, cultural or environmental - will eventually spread to the rest of the country. Then, forklift fleet owners across the United States may want to know whether they should pay close attention to the proposal of the California Air Resources Board (CARB), which has sounded an alarm among practitioners who rely on forklift industry for survival, such as warehousing and distribution, construction, manufacturing and agriculture.
The proposal is still at an early stage, known as the "draft regulatory concept", before the development of the proposed regulation. Although the draft is far from being finalized, its intention is clear: most users will have to phase out emission producing internal combustion (IC) forklifts, and they will only be allowed to rent or purchase zero emission (ZE) equipment - forklifts will not produce air pollutants after the specified date. Although we cannot know how things will eventually develop at this time, we can provide an overview of the draft regulatory concept, outline some of the questions raised by end users and forklift OEMs, and explain how stakeholders can provide comments to carb.
What is carb's plan?
Carb is a California government agency responsible for air pollution control in California. Forklift measures originated from executive order n-79-20 of California governor Gavin Newson, which aims to reduce harmful emissions from various sources, including off-road vehicles and equipment.
Since forklifts may only account for a small part of off-road emissions, why focus on forklifts? Part of the reason is expediency. Carb's goals include accelerating the adoption of Ze technology. Angie Polanco, an air resources Engineer in carb's off highway implementation department, explained: "we determined that forklift electrification is a possible early action, which will enable us to introduce Ze vehicles into the target department. Many indoor forklifts have been zero emission, so this is a good start and then move forward quickly".
As of August 2021, the draft regulatory concept will impose the following requirements on forklifts operating in California with a lifting capacity of 12000 pounds or less:
Applicable forklifts (mainly category 4 and 5) purchased or leased after January 1, 2025 must be zero emission equipment.
The phase out of old internal combustion engines will begin on January 1, 2025. From this date, IC forklifts of 13 years (model year 2012) or earlier, or IC forklifts driven by engines of 13 years or earlier, shall not operate. Retired models will increase year by year. For example, forklifts with 2013 engines will be retired in 2026, forklifts with 2014 engines will be retired in 2027, and so on. By the end of 2035, all forklifts subject to regulations must be zero emission.
The forklift users in the state must register all forklifts with the state government and report the brand, model, model year, lifting capacity and purchase time of each forklift every year; Power supply and capacity of Ze equipment; Engine details and fuel type of IC equipment, as well as other details. Compliance with Ze regulations also needs to be demonstrated.
This regulation does not apply to rough terrain forklifts, military tactical vehicles, pallet carriers or small forklifts operating in ports and multimodal railway stations, which are subject to separate California regulations applicable to cargo handling equipment. Additional exemptions or delayed obsolescence are being considered for forklifts used in remote areas where emergency operation, rental, low / occasional use and battery charging are not feasible. Carb is also considering delaying small businesses for five years.
Clamour for stakeholders
In addition to considering the effectiveness of the proposed regulations in meeting state and federal pollution reduction standards, carb will also consider feasibility, fairness, environmental justice, cost and economic impact on enterprises, enforceability, and monitoring and reporting requirements. With this in mind, project engineers have been asking for feedback - and stakeholders are not shy about expressing their concerns. An open seminar in August raised dozens of questions and comments from participants. For example:
The implementation schedule is too short! The Board plans to consider the proposal in early 2022. If approved, the start date will be less than three years.
Phasing out the IC forklift according to the model year will force it to retire before the end of its service life and / or economic life. Phasing out should be based on hours of use, which will mitigate some of the value loss of fleet capital investment.
The proposal includes stricter restrictions than another California regulation applicable to some forklifts. According to the rules, it is legal to buy a diesel forklift that meets the class 4 standard, but according to the proposal, the same forklift purchased today will become illegal before its economic life ends. This early turnover of equipment will force enterprises to bear costs that will not occur in other states.
Why not let forklift truck owners decide how to achieve carb emission reduction targets by the specified date? In addition to the unified ban in exceptional cases, the "fleet average" compliance measures for diesel powered and spark ignition (propane gas) equipment have been adopted.
From the perspective of the American Industrial Truck Association (ITA), which represents forklift manufacturers, some parts of the current proposal are improved from the original version proposed in October 2020. For example, instead of retiring the IC forklift that has been used for 8 years, the threshold will be extended to 13 years. Although ITA considers this to be "a significant improvement", Gary cross, head of Dunaway & Cross, a consultant to ITA, said: "this is still lower than the life of many forklifts. We want to see this period extended. The longer it takes to phase out, the smaller the negative impact on the enterprise."
Ryan crochet, product marketing and financial sales manager of Mitsubishi logisnext, said that replacing the most widely used forklift type is a "major change" that will challenge end users and forklift dealers. If California proposes a hard deadline without exception, meeting the current schedule will be a real challenge for operations using IC devices. Mitsubishi logisnext is a comprehensive forklift and material handling company of unicarriers forklift, Mitsubishi forklift, cat forklift, Rocla AGV solution and JUNGHEINRICH in Houston.
One reason compliance may prove difficult is that although today's electric forklifts and have made significant improvements in power and efficiency than ever before, there are still many applications that are still more suitable for IC forklifts, especially in outdoor or heavy-duty applications. In addition, he explained: "not all locations where customers use forklifts have infrastructure or charging capacity to achieve this conversion [to electric forklifts]. This will make it a challenge for dealers and end users to meet the requirements of short-term or seasonal leasing."
Cross pointed out that even if it is feasible to switch to electric forklifts from the perspective of forklift performance, the operation of large fleets and charging stations will put pressure on the power infrastructure of the facility and the power grid serving it. I really think carb knows this. They understand in a broad sense that they need more grid capacity.
Carb response
Policymakers say they are listening and will consider these and other issues in the rulemaking process. Polanco pointed out that in fact, they have made some adjustments based on stakeholder feedback, such as raising the retirement age of IC forklift to 13 years and increasing the exemption for off-road forklift.
In the August open workshop and subsequent interview with DC velocity, David Chen, manager of Polanco and carb advanced emission control strategy, answered some questions raised by workshop participants. One problem is that the plan is to measure progress towards zero emissions based on the average emission level of a single forklift rather than a fleet. Chen explained that this method has been applied to diesel forklifts and other types of equipment, but it is difficult for carb inspectors to verify and implement. However, this is not completely infeasible. "If there are compelling reasons to adopt the fleet average measurement method, we are willing to listen to this opinion," he said. “
Another common issue relates to plans to phase out IC forklifts based on model year rather than hours used, which may force some fleets to scrap equipment long before the end of their operational and economic life - carb will continue to consider this issue. Chen said that here, enforceability plays a role again. He pointed out that in most cases, Retirement based on the model year "will make it easy for inspectors to immediately know whether forklifts are compliant. He said that some stakeholders suggested measuring the average age of a fleet, which will provide flexibility in choosing what and when to phase out, but it will also be difficult to verify and implement. Moreover, retirement based on service time has a great challenge. Every forklift in the state needs an hour meter that cannot be reset or tampered with.
Questions about compliance costs and the overall economic impact are common. One commentator said that replacing his company's IC forklift would cost $4 million, adding that the company would also face the cost of expanding its facilities and improving infrastructure to accommodate battery charging or hydrogen fuel cells. Polanco and Chen assured participants that carb's calculation of stakeholder costs would include charges for charging and related infrastructure, as well as other costs not incurred by IC forklifts. "Our goal is to develop a proposal to reduce the costs of stakeholders as much as possible while still achieving our goal of 100% zero emissions by 2035, where feasible," Chen said.
So is California?
If California's authorization for Ze forklift becomes effective, will similar rules be adopted elsewhere? "As a general proposition, I think the answer is yes." "Other states and the whole country are investing more and more in greater electrification. It's hard to say whether another state will develop a proposal specifically for forklifts," ITA's Cross said. However, he added: "if after a period of time, everyone knows... There are not many IC forklifts in California and the effect is very good, we can see similar effects in other places."
Although the industry as a whole continues to develop in the direction of electric solutions, there will be counterattacks from forklift users. Crochet predicts that this is not only because electric forklifts in some applications cannot meet the needs of the application, but also because some buyers have outdated misunderstandings about the performance of electric forklifts. He said that if we want to achieve the Ze goal and take into account a variety of application requirements, the California market may have to find a balance point to let electric vehicles and low emission or zero emission IC forklifts play a role in the overall strategy.
In any case, forklift end users, dealers and OEMs need to understand carb's proposal and its development environment. Crochet pointed out that his company is ready for the transition to zero emissions and is working to develop a series of environmental protection solutions that meet the market demand and the application of its services. On a broader scale, "this is the progress we expect, not only in the field of forklifts, but also in the whole field," he said
In any case, forklift end users, dealers and OEMs need to understand carb's recommendations and its development background. Crochet pointed out that his company is ready for the transition to zero emissions and is working to develop a series of environmentally sound solutions to meet the needs of the market and service applications. On a broader scale, "this is a progress we have expected, not only in the forklift world, but also in the whole field," he said.
The zero emission forklift team of the California Air Resources Board (CARB) is actively seeking stakeholder input in developing the draft regulatory concept outlined in this article.
Brian Feehan, President of the American Industrial Truck Association (ITA), pointed out that the carb team is improving its understanding of forklifts and applications and is trying to develop a method to consider the concerns of end users. However, he believed that providing additional feedback to the agency was a worthwhile effort.
"If they want to make regulations, let's help ensure that they make the best regulations possible and achieve their goals in terms of negative impacts on OEMs and end users," Feehan said
