THE CLEAN AIR ACT
AND THE MUNICIPAL FLEET

By WALTER J. BURNETT, CAFM
General Services Superintendent, Department of Public Works, Village of Schaumburg, Illinois
and
GLENN D. LINHART
Superintendent of Public Works Services, Department of Public Works, Village of Oak Park, Illinois

This report is an extract of: Alternate Fuels and the Municipal Fleet by Walter.J. Burnett & Clenn D. Linhart and published as Technical Report Number 1, Municipal Fleet Managers Association, September, 1992.

Current interest on alternate fuels by municipalities is a direct result of the Clean Air Act of 1990. Although the fleet provisions for alternate fueling are only a minor part of this legislation, they have received substantial media attention. Unlike the petroleum crisis of the 70s and 80s, the alternate fuel issue today is driven by environmental concerns, not cost or availability of petroleum. This redefinition of the parameters surrounding the alternate fuel issue has created a different standard by which the feasibility of alternate fuel use is judged, broadening the range of potentially acceptable fuels based more on their potential environmental impact than cost or technological development.

It is apparent that the basic premise of Clean Air Act Fleet Provisions is to use fleets as the testing ground for undeveloped alternate fuels technology with the expectation that the private motorist will adopt alternate fuel as technology, vehicles and supporting infrastructure develop. The actual environmental impact of fleet vehicle conversion to alternate fuel is negligible since fleet vehicles account for less than 5% of the vehicles currently on the road. Municipal vehicle fleets are estimated to encompass something less than 1% of the total vehicles in this country.

The fleet provisions of the Clean Air Act are basically a timetable of standards that affect the municipal fleet in various ways. For a municipal fleet to fall under the fleet provisions it must meet certain criteria. First, the municipality must be located within one of the listed air quality non-attainment areas, which include most major metropolitan centers. Second, the municipal fleet must number 10 or more vehicles owned, operated, leased, or controlled by the municipality. Covered vehicles are vehicles of less than 26,000 lbs. gross vehicle weight which are centrally fueled or capable of central fueling, except those garaged at a personal residence. Several classes of vehicles are exempt from this legislation, including law enforcement, emergency response, and non-road vehicles.

For municipalities these exemptions effectively exclude Police, Fire, Emergency Medical vehicles, all construction and off-road equipment, most single axle Public Works trucks and all tandem axle trucks, refuse vehicles, and any vehicle on permanent drive home assignments. Essentially, covered vehicles are limited to general purpose sedans and light duty trucks.

For those vehicle classes which are covered, a municipality is required to purchase alternate fueled vehicles in certain proportions by certain dates as these vehicles are replaced. Only new purchases are affected and conversion of existing vehicles or newly purchased vehicles is not required. The municipality is not required to purchase any new vehicles, or any vehicles not scheduled for normal replacement, but required only to substitute a portion of those vehicles actually purchased with alternate fueled vehicles.

Of vehicles actually purchased, the proportion of alternate fueled vehicles of total covered vehicles actually purchased must meet the following minimums during the phase in period of model years 1998-2001.

Model Year	>8500 GVW	8500-26,000 GVW
1998	30%	50%
1999	50%	50%
2001	70%	50%

To see how these requirements actually work in practice, take as an example a fictional municipal fleet from Clean Air City, located within a severe air quality non-attainment area. This fleet has a total of 300 vehicles and equipment in the following numbers (Example 1):

Example 1

Vehicle Class	# Units	Covered By CAA Fleet Provisions
Sedans (General Purpose)	40	Yes
Police Sedans	40	No
Pick-up Trucks & Vans (less than 8,500 lbs. GVW)	70	Yes
1-11/2 Ton Trucks (8,500 lbs.-26,000 lbs. GVW)	20	Yes
Dump Trucks (Over 26,000 lbs. GVW)	20	No
Refuse Trucks (Over 26,000 lbs. GVW)	12	No
Sweepers	4	No
Endloaders	5	No
Misc. Off-Road	75	No
Fire Apparatus	10	No
Ambulance	4	No
	300	43%

Also note that of the 40 sedans, 10 are assigned to department heads who commute in these vehicles, and are therefore exempt under the "garaged at a personal residence" provision.

Clean Air City funds its vehicle purchases through a revolving replacement fund and plans on the following normal vehicle replacements in the 1998-2001 model year period (Example 2):

May 1993 / Illinois Municipal Review / Page 9

Example 2
SCHEDULED VEHICLE PURCHASES

Class	1998	1999	2000	2001
Sedans (drive home)	8(1)	8(2)	8(1)	8(3)
Police Sedans	20	20	20	20
Pickup Trucks	12	12	12	12
1-11/2 Ton Trucks	2	0	2	2
Dump Trucks	2	2	2	2
Refuse Trucks	1	2	1	2
Sweepers	0	1	0	1
Endloaders	1	0	1	0
Misc. Off-Road	7	8	7	8
Fire Apparatus	1	1	1	1
Ambulances	0	1	0	1
Total Vehicle Purchases	54	55	54	57

Of the total purchases schedule for 1998-2001, the following numbers and types of vehicles listed in Example 3 would be required to be alternately fueled under the Clean Air Act Fleet Provisions.

Example 3
REQUIRED TO BE ALTERNATE FUELED

Class	1998	1999	2000	2001
Sedans	3 (30%)	3 (50%)	4 (50%)	4 (70%)
Pickup Trucks	4 (30%)	6 (50%)	6 (50%)	9 (70%)
1-11/2 Ton Trucks	1 (50%)	0 (50%)	1 (50%)	1 (50%)
Total Alternate Fuel Purchases	8	9	11	14
% Of Total Annual Purchases	15%	16%	20%	25%
Cumulative % Of Fleet	3%	6%	9%	14%

As Example 3 demonstrates, the overall impact of the Fleet provisions of the Clean Air Act will be relatively minor on the typical municipal fleet in either total numbers or cost. Assuming a purchase cost "premium" of $2,000 per alternate fueled vehicle, the additional purchase costs incurred would be $16,000, $18,000, $22,000 and $28,000 respectively for each year listed. It would appear that the Fleet provisions will not be overly burdensome to the municipality or present any particular problems in acquisition or maintenance which cannot be adequately managed. Also readily apparent is that the time frame and required percentages of alternate fuel purchases does not preclude a well planned, orderly, and well researched approach to alternate fuel vehicle purchases.

The development of alternate fuels as a viable petroleum substitute is clearly in the earliest stages of economic and technical development. At this stage, none of the available fuels are emerging as a clear choice as a successor to gasoline. In fact, most experts consider the alternate fuels available today as transition fuels to an as yet unknown permanent energy source.

Municipalities are extremely concerned with how alternate fuels will impact municipal operations and the city budget. It is a basic premise that municipal fleets have a responsibility to meet the letter and spirit of the law; to set an example as environmentally responsible corporate citizens; to provide vehicles that functionally support municipal services; and perhaps most importantly, to meet these responsibilities by the most cost effective means possible. We recommend the following strategies to municipal fleet operations as consistent with this premise.

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1. Plan to implement alternate fuel vehicle purchases by the timetable listed in the Clean Air Act.
We recommend the municipal fleet manager exercise caution in alternate fuel vehicle purchase. The constantly changing technological, legislative and economic issues do not favor early purchase before the 1998 deadlines. The next few years will do much to resolve the alternate fuel picture and early purchase of alternate fuel vehicles may well prove a costly gamble if the wrong vehicle or fuel choice is made. Municipal fleet operations are not oriented to be experimental centers for fuel research and can contribute little or nothing to the data bank on alternate fuels. Economically, presently available alternate fueled vehicles are considerably more expensive and perform more poorly than their gasoline counterparts. Looking toward the 1998 deadline it seems clear that alternate fueled vehicles will be more commonly available and will be comparatively less costly than at the present. We believe this approach to be the most fiscally responsible response to the Clean Air Act requirements.

2. Utilize reformulated gasoline and clean diesel fuel as it becomes available.
We recommend municipal fleets should begin using reformulated gasoline and clean burning diesel throughout the fleet as these fuels become available. Although more expensive than traditionally formulated fuels, the environmental benefits will be widespread and immediate because the whole fleet is affected, providing an attractive cost/benefit ratio, This phase in requires no vehicle or fuel distribution system changes and will be transparent to the user.

3. Avoid aftermarket vehicle conversion.
We recommend that any alternate fueled vehicle purchased should be manufactured as a dedicated alternate fuel vehicle and not as an aftermarket conversion of a gasoline vehicle. Aftermarket conversions are expensive, relatively inefficient and prone to maintenance problems compared to a vehicle designed and manufactured specifically for alternate fuel. The major vehicle manufacturers have all committed to significant research and development of alternate fuel vehicles and to production of these vehicles in marketable quantities. As municipal fleets embark on this new technology, the engineering support, parts availability, warranties and service available through the major vehicle manufacturers will become critical to the municipal fleet user.

4. Stay abreast of alternate fuel development.
We recommend that the municipal fleet manager educate himself on alternate fuels. The municipal

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fleet manager is in the best position and has the most expertise to assess this developing technology and make the decisions necessary to guide the municipal fleet through the transitional fuels and ultimately to a permanent fuel choice.

5. Municipal joint effort.
We suggest that geographically clustered municipalities explore the possibilities of joint efforts on alternate fuel implementation. The advantages are obvious in joint purchasing, technical training pools, common fueling infrastructure and mutual aid in the implementation process.

Alternate fuels are a fast developing technology that will have a far reaching impact on both municipalities and society. If approached with foresight and caution the transition to new fuel sources in the 21st century is workable with minimal disruption of municipal operations and with acceptable costs to the municipality. •

Page 12 / Illinois Municipal Review / May 1993