By: Mike Salsgiver
Executive Director, AGC Oregon-Columbia Chapter
This article was published by the DJC on January 15 in Buildings Bridges and Roads, and can be viewed here (subscription required)
Over the course of the past few years, several bills have been proposed in the Oregon Legislature that would bring California’s strict off-road diesel regulation to Oregon.
Given the complexity and unintended consequences of such regulations, AGC argued for the need for independent, third-party data on actual diesel emissions in Oregon. This need became clear as we successfully led a broad-based industry coalition against the passage of diesel regulation. We advocated for the development of a bottom-up emissions inventory, and as a result, funding for the inventory was approved by the Oregon Legislature in 2017.
Before this inventory, policy makers (legislators and the Oregon Department of Environmental Quality) relied on modeling data when considering off-road diesel regulation. California (the only state that has passed off-road diesel regulation) relied on similar modeling when implementing its stringent off-road diesel laws. After AGC of America intervened in California, data from an actual inventory showed the modeling overestimated the diesel emissions by 340 percent.
To avoid the type of gross overestimation that occurred in California, we have advocated for a diesel inventory to establish what the actual diesel emissions are from all users – public and private – in Oregon. Typically, inventories that have been conducted demonstrate a much lower level of emissions than modeling suggests.
The Oregon DEQ has hired an independent third party to develop an emissions inventory of all off-road diesel equipment greater than 25 horsepower operating in the state. The inventory will be based upon surveys of equipment owners and operators. Previous emissions estimates developed by DEQ have been based upon national default information that does not represent Oregon’s equipment populations or operating conditions.
Conducting detailed equipment operator surveys will provide the data needed to accurately characterize Oregon-specific off-road diesel equipment operations.
What does the inventory entail? The project will include surveying all public and private sectors that use off-road diesel equipment (i.e., construction, agriculture, logging, public works departments, etc.). In addition to individual surveys, DEQ’s consultant will be working with a small group of contractors to develop a profile of the construction industry in Oregon.
Here are some basic facts about the inventory:
Q: Who will be conducting the inventory?
A: The inventory will be done by Eastern Research Group (ERG), a third party that has conducted similar surveys and emissions inventories in Texas and California, as well as numerous other sector-specific studies.
Q: Who will have access to the information gathered?
A: Only ERG will have information from each company. The information collected will only be given to DEQ in aggregate form and DEQ will not be involved directly in the data collection or analysis.
Q: What do I need to do?
A: AGC requests participation in the survey as full as possible from any party contacted for information. Contractors are extremely busy this time of year, but their participation in providing solid data will help ensure a reliable and accurate assessment of the emissions associated with off-road diesel equipment use.
As part of this survey, a company may be contacted by ERG in the coming months. The survey questions will focus on:
- Number and type of equipment owned/operated in the state in 2017
- Equipment make, model, model year and horsepower
- Annual fuel consumption
- Engine on-time and hours of operation (including weekly and seasonal distribution of hours)
- Anticipated retirement schedule
- Equipment ownership (own, rent or lease)
- Other details regarding your company structure/operation
Q: How much time will this take and how do I provide the information?
A: Companies with a small number of pieces of equipment (i.e., fewer than five units greater than 25 horsepower) will likely be able to provide this information to ERG survey staff during a telephone conversation lasting 10 to 20 minutes. Companies with larger fleets of equipment can submit information electronically through an online survey or other method of their choosing (e.g. database reports, Excel spreadsheets, etc.). Members of the ERG study team will be available to answer any questions or assist survey completion.
Getting this inventory done and done correctly is a critical first step. AGC will do its part to work with our members and others in the construction industry to build a strong foundation on which to make sound, defensible public policy.
Mike Salsgiver is the executive director of Associated General Contractors’ Oregon-Columbia chapter. Contact him at 503-685-8305 or firstname.lastname@example.org.