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RVIA Seeking Input on CARB Refueling Regs

August 19, 2010 by · Leave a Comment 

CARB logoThe Recreation Vehicle Industry Association (RVIA) has scheduled a conference call to provide the opportunity for sport utility trailer manufacturers to discuss recent activity by the California Air Resource Board (CARB) on the refueling systems onboard RVs. The call is set for Tuesday, Aug. 31, at 2 p.m. EST.

CARB’s Monitoring and Laboratory Division is examining regulations concerning on-board refueling systems to reduce gasoline refueling losses as well as permeation, evaporative and vented emissions. These systems, also known as “transfer tanks,” are mounted on RVs, trucks and trailers to fill various types of off-road vehicles, motorcycles, lawn and gardening equipment and other types of equipment.

RV refueling systems under consideration are those that stand alone, are installed underneath the body, are dual purpose and the fuel tank is regulated by SORE rule.

“The purpose of the call is for sport-utility trailer members to discuss the CARB regulations and assumptions so that RVIA can provide the agency with appropriate feedback,” said Bruce Hopkins, RVIA vice president of standards and education.

For more information or to register for the call, contact Gatie Gore in RVIA’s Standards Department at (703) 620-6003 ext. 348 or via email at ggore@rvia.org.

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Navistar Concerned About SCR Compliance

July 21, 2010 by · Leave a Comment 

Navistar International Corp. said from a workshop Tuesday (July 20) that the U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) presented preliminary proposals aimed at the compliance loopholes found in current 2010 liquid-based SCR systems.

“Navistar first identified these loopholes to the agencies and also presented our concerns at today’s workshop,” Jack Allen, president of Navistar’s North American truck group, said in a news release on Tuesday. “We will be working with the EPA and CARB to ensure full environmental compliance.”

At Tuesday’s joint CARB and EPA workshop, Navistar’s concerns about environmental compliance were backed up by independent test findings that show new commercial vehicles that must contain liquid urea to meet federal NOx emissions standards continue to operate effectively when urea is not present. At such times, Navistar said, the vehicles throw off levels of NOx as much as 10 times higher or more than when urea is present.

The research was conducted by EnSIGHT LLC, an independent environmental consulting firm, using two long-haul vehicles and one heavy-duty pickup, all of which use Selective Catalytic Reduction (SCR) technology that relies on liquid urea to clean up NOx emissions after they leave the engine.

EnSIGHT’s research showed that when liquid urea was not present, there was little or no effect on the vehicles’ operations. This included long periods of time when the vehicles’ urea tanks were empty or were refilled with water instead of urea. One truck tested appears to operate indefinitely with water and as a result without any functioning SCR NOx control. That truck has accumulated more than 13,000 miles with its SCR NOx emission control turned off.

European research also has shown that even with a full tank of liquid urea, the SCR NOx emission control system does not turn on when exhaust temperatures are not hot enough. This occurs during stop-and-go traffic. That means that there is frequently no SCR NOx control when these trucks are operating in urban areas as well as in any other congested traffic situation.

Navistar, which commissioned EnSIGHT’s work, joined two prominent environmental groups, the Coalition for Clean Air and Environment Now, in calling on the EPA and CARB to eliminate the loopholes and the resulting excessive NOx emissions.

“Truck owners are paying a substantial price to comply with 2010 NOx requirements,” said Allen. “They, and the public, deserve to know that the new equipment they are purchasing actually works as promised to curb pollution. It’s obvious, however, that these trucks can operate effectively without liquid urea, and that under these and other conditions, SCR NOx emission control is turned off. We’re calling on the EPA and CARB to assure that all vehicles, not just ours, work when they are supposed to be working.”

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RVIA Clarifies Its Position on CARB Enforcement

August 28, 2009 by · Leave a Comment 

rvia-logo2The Recreation Vehicle Industry Association’s (RVIA) Standards Department has issued the following clarification of the association’s position on the use of California Air Resource Board (CARB) certified wood in response to recent questions about whether the association plans to alter its enforcement position, according to RVIA Today Express.

The increased production of RVs over the past 60 days has spurred a concern among some RVIA members that there could be a shortage of  CARB-certified luan in the near future, impacting some manufacturers’ production. 

It appears that the temporary shortage of CARB-certified luan is a supply-chain issue rather than an RVIA enforcement issue. RVIA has no influence over the actions of CARB, which requires that, as of July 1, 2010, every RV sold in the state of California must contain CARB-certified wood. Any manufacturer or dealer who sells an RV containing non-certified wood in the state of California after this date would be subject to monetary penalties as established by CARB.

RVIA’s requirements use the same effective date for the other 49 states, but it will apply to RVs built on or after July 1, 2010, not to those RVs sold on or after that date. While RVIA has petitioned CARB for relief on the July 1, 2010, date of sale, there has been no response from CARB, leaving the association to assume that July 1, 2010, remains the effective date for mandatory inclusion of  CARB compliant wood (non-certified, but meets the CARB emission levels) in RV products sold at retail in California.

RVIA will continue to allow wood products that meet CARB emission levels but are not CARB certified until July 1, 2010, after which, CARB certified wood products will be required. If an RVIA member does not comply, a deviation will continue to be cited. For this type of deviation under the RVIA Standards program, a member would have to be cited a total of four times (the initial deviation and three repeats) before enforcement action will be taken.

Changing the program requirements in the face of a temporary shortage caused by supply chain issues does not appear to be in the best interest of RVIA or its members. Accordingly, RVIA will continue to enforce the program requirements as directed by the RVIA board of directors.

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CARB Issues Clarification on Wood Packaging

March 26, 2009 by · Leave a Comment 

The California Air Resource Board (CARB) has issued a notice clarifying its position on the applicability of wood packaging materials (i.e., to pallets and crates) under the Composite Wood Products Airborne Toxic Control Measure (ATCM). 

The advisory is designed to provide guidance with labeling requirements for manufacturers, fabricators, importers, distributors and retailers of composite wood products sold in California, according to a release from the Recreation Vehicle Industry Association (RVIA). 

The advisory reads, “Since wood packaging may contain composite wood products (i.e., hardwood plywood, medium density fiberboard, and/or particleboard), wood packaging would be ‘finished goods’ subject to the ATCM if one were to take a strict interpretation of the ATCM’s definition of ‘finished goods.’ However, it was not CARB’s intent to regulate wood packaging as ‘finished goods.’ 

To be consistent with this intent and provide fairness to the regulated community, CARB staff interprets the ATCM as not applying to wood packaging. 

These products are not subject to any of the requirements of the ATCM. By ‘wood packaging’ we mean pallets, skids, boxes, crates, and containers used for handling, sorting, storing, shipping, and transporting goods,” CARB stated. 

On June 12, 2008, RVIA’s board of directors set an effective date for member manufacturers to begin using wood products that meet CARB’s new formaldehyde emissions level as a mandatory condition of membership. 

Effective Jan. 1, 2009, RVIA member manufacturers are required to build units for sale in all 50 states using wood products that comply with the CARB standard’s emission limits. By July 1, 2010, they must use wood that has been certified by an appropriate third party as meeting the CARB standard.

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