CARB provides update to HD I/M pilot program and OBD specifications

The California Air Resources Board (CARB) hosted a web call to continue the conversation surrounding the State Senate Bill 210 Heavy Duty Vehicle Inspection and Maintenance (HD I/M) program. During this workgroup meeting, CARB staff discussed pilot program activities to support California’s future comprehensive HD I/M program. Staff also discussed a draft on-board diagnostics (OBD) data collection and submission specifications document that detailed the technical requirements for all systems and tools to be used to collect and submit heavy duty vehicle OBD data in California’s HD I/M program.

In a previous webinar, CARB outlined the full parameters of the proposed program’s structure, testing requirements, and implementation.

This call, “CARB HD I/M workgroup meeting on pilot program activities and OBD specifications,” primarily focused on pilot efforts underway, as well as various OBD specifications.

Inspection pilot program overview

“The SB210 Pilot is designed to test how the future CARB HD I/M program components can best operate together to ensure an efficient and effective rollout during program implementation,” CARB representatives said. The pilot focused on three avenues of the future program: OBD, vehicle monitoring infrastructure, and program enforcement.

OBD

OBD efforts are piloting data collection tools, submission options of collected data, and data processing. The pilot is serving to validate OBD data collection methods, including telematics platforms, plug-in dongle devices, kiosk submissions, and OBD scan tools. The goal is to offer a range of options for fleets to choose those best suited for their operations.

Testing efforts in the pilot include:

• Working with California fleets to test and demonstrate potential OBD submission options
• Collaborating with certified PSIP testers to use OBD devices
• Equipment vendors developing and testing prototype devices
• Consulting with telematics providers
• Surveying fleets on preferred submission options
• Coordinating with other state agencies in development and testing efforts

CARB stated that there are areas yet to be explored through the SB210 pilot program. The pilot seeks to:

• Ensure the feasibility and effectiveness of the different data acquisition platforms to collect and submit OBD data necessary to meet HD I/M program requirements
• Better characterize fleet testing preferences of these different platforms
• Further constrain potential vehicle downtime necessary to complete testing through these various platforms
• Evaluate potential costs and lead time required to bring devices to the marketplace
• Identify best testing approaches to maximize program effectiveness

CARB is also examining internal OBD data processing with the intent of verifying whether internal systems can adequately incorporate data submissions from multiple platforms, as well as establishing automated processes to collect, store, and assess data submissions for program compliance. Another area of focus includes security protocols to ensure privacy protection for incoming data submissions.

Vehicle monitoring infrastructure

Vehicle monitoring infrastructure efforts are piloting remote sensing emission detection equipment, automatic license plate reading (ALPR) cameras for non-compliance identification, and vehicle and emissions data processing through integrated roadside monitoring systems.

The SB210 pilot program is evaluating enforcement through the use of remote sensing devices (RSD) with the goal of learning how to best establish an RSD and complimentary ALPR network designed to identify potential high emitter and non-compliant vehicles, as well as to better understand vehicle operations throughout the state of California. The pilot also seeks how to best establish a data-driven enforcement process.

This will be done through the piloting of long-term unattended Portable Emissions Acquisition System (PEAQS) deployments, evaluation of different RSD technologies, piloting stand-alone ALPR cameras, and piloting a data-driven enforcement process, CARB representatives said. Stand alone ALPR deployments have been considered to form a denser network to monitor out-of-state vehicles in particular.

In piloting unattended PEAQS deployments, CARB is assessing system deployment, operation, maintenance requirements, and associated costs. Currently, CARB is piloting two unattended PEAQS systems at CDFA Border Inspection Stations. Emissions data from tens of thousands of vehicles each month is remotely and continously transferred to CARB. The group stated that pilot efforts are to continue through the spring of 2021.

CARB also discussed the recent completion of a two-week field test, conducted November 2-13, which utilized RSD testing. The test compared available RSD robustness of measuring critical emissions (particulate matter, nitrogen oxide and carbon dioxide) and optimal RSD set-up conditions. Concurrent OBD and opacity data was collected to determine the correlation between RSD and control tests. Among the systems tested were:

• Hagar Environmental Atmospheric Technology (HEAT)’s Emission Detection and Reporting (EDAR) system
• OPUS AccuScan
• CARB developed PEAQS

All systems utilized in the test were paired with ALPR systems. Drivers were also asked to volunteer OBD scans for CARB and each tested system had different OBD testing methods available in order to determine which combinations would be best suited for locations and scan methods.

CARB stated that the next steps include evaluation of results from RSDs, determining strengths and weaknesses of each system, evaluating RSD suitability in varied settings (such as traffic speeds, existing support infrastructure, etc.), and ensuring compatibility between RSD screening assessments and potential follow up emissions testing mechanisms. The group stated that completion is expected sometime early next year, dependent upon the data returned from the HEAT and OPUS systems.

Furthermore, CARB contracted the University of California Irvine to pilot stand-alone ALPR cameras as a potential means to supplement an ALPR-equipped RSD network to identify vehicles operating without a compliance certification. Three systems will be utilized along California’s borders, one being on the California/Nevada border near Mountain Pass, and two additional systems on the California/Arizona border and the California/Mexico border. The goals of the stand-alone ALPR cameras include assessing the feasibility and effectiveness of establishing a near-border monitoring network to ensure out-of-state vehicle compliance, assessing the durability for long-term deployment, and to improve the understanding of out of state truck travel.

Enforcement

Program enforcement efforts are piloting enhancements to various enforcement design processes. The goal of the pilot is to enhance the design of the process through evaluation of methods to identify non-compliance using RSD, ALPR, vehicle registration data, vehicle test data, and other CARB internal data sources. The desired outcome is a data-driven, targeted enforcement process, CARB representatives said.

Impact of inspection program

CARB is also analyzing impacts to fleet business operations as a result of being subject to the HD I/M program. The group will work with heavy duty repair shops and fleets in order to evaluate changes to vehicle repair processes due to HD I/M regulations, as well as assess vehicle downtime as a result of HD I/M related repairs. CARB representatives stated they are working with several repair facilities and other sources to identify the most common emission-related fault codes and subsequent necessary repairs to extinguish MIL-on events. Such work is intended to link specific repairs to repair costs. The group expects completion of this in the Spring of 2021.

Furthermore, CARB is evaluating the need for heavy duty vehicle repair assistance by determining if such a repair assistance program is needed within a fully implemented HD I/M program. Such a program would qualify small fleet owners to be paid for part of emissions-related repair bills, with the remainder of costs covered through a funding grant. CARB is currently analyzing data and costs from participating facilities and a report is being finalized for later this year.

ROBD systems

The web call also covered additional details of the draft remote OBD (ROBD) specification documentation, with the intent of communicating specifications for ROBD testing devices to be used to demonstrate vehicle compliance. This was the third public discussion regarding the development of OBD devices for the CARB HD I/M program.

The discussion covered ROBD submission options in the HD I/M program, high level functionalities of ROBD systems, as well as general and major specifications of ROBD systems. CARB representatives stated that they are seeking participation from telematics vendors, OEMs, and fleets to test and validate proposed specifications, as well as for any stakeholders to provide feedback which will be incorporated in a future stakeholder workgroup call in early Spring of 2021.

Participant feedback

Call participants shared questions, comments, and concerns during the sessions.

One question posed queried the definition of a high emitter, how that definition was being formulated, and what data was being used to establish such a definition. CARB representatives stated that collecting RSD information to characterize vehicles would assist in figuring out what would be considered a high emitter based on PM emissions and NOx emissions. As of now, there is no established definition for a high emitter; the definition can be formed through a number of approaches, recognized CARB representatives, such as by percentiles, or a threshold value. CARB is currently compiling data in order to establish a threshold, and all of the data collected through the pilot program will be used to help make that determination. It was noted that PM emissions are well characterized, though NOx emissions are lesser known being that there are variables that affect output of NOx emissions per vehicle.

Aside from answering to parameters of the program and device specifications, some concerns were raised from participants.

Most notably, the concern was presented that second- or third-time owners of trucks face greater pressure from the CARB HD I/M program than fleets that can afford to operate newer model year trucks and are first time owners with full warranty coverages. The concern is that the expenses of out-of-warranty emissions related repairs along with the associated costs of conforming to program compliance are falling to small to medium sized fleets. CARB representatives stated they are exploring avenues to understand which vehicles are failing, and that the repair assistance program may serve as an aid to operations for fleets who cannot afford the costs of repairs and compliance. “The goal is not to reduce emissions by removing a percentage of the fleet,” said CARB representatives. “The goal is to reduce emissions through well maintained vehicles through the parameters of this program.”