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15 Additional mitigation measures can be found in CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures, which attempt to reduce GHG levels, as well as reduce criteria air pollutants such as particulate matter and NOx.27 DPM and NOx are a byproduct of diesel fuel combustion and are emitted by on-road vehicles and by off-road construction equipment. Mitigation for criteria pollutant emissions should include consideration of the following measures in an effort to reduce construction emissions.28 Require Implementation of Diesel Control Measures The Northeast Diesel Collaborative (NEDC) is a regionally coordinated initiative to reduce diesel emissions, improve public health, and promote clean diesel technology. The NEDC recommends that contracts for all construction projects require the following diesel control measures: 29 • All diesel generators on site for more than 10 total days must be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85 percent. • All diesel vehicles, construction equipment, and generators on site shall be fueled with ultra-low sulfur diesel fuel (ULSD) or a biodiesel blend 30 approved by the original engine manufacturer with sulfur content of 15 parts per million (ppm) or less. Repower or Replace Older Construction Equipment Engines The NEDC recognizes that availability of equipment that meets the EPA’s newer standards is limited.31 Due to this limitation, the NEDC proposes actions that can be taken to reduce emissions from existing equipment in the Best Practices for Clean Diesel Construction report.32 These actions include but are not limited to: • Repowering equipment (i.e. replacing older engines with newer, cleaner engines and leaving the body of the equipment intact). Engine repower may be a cost-effective emissions reduction strategy when a vehicle or machine has a long useful life and the cost of the engine does not approach the cost of the entire vehicle or machine. Examples of good potential replacement candidates include marine vessels, locomotives, and large construction machines.33 Older diesel vehicles or machines can be repowered with newer diesel engines or in some cases with engines that operate on alternative fuels. The original engine is taken out of service and a new engine with reduced emission characteristics is installed. Significant emission 27http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf 28 For measures to reduce operational DPM emissions, see section titled “Additional Feasible Mitigation Measures Available to Reduce Operational Emissions” on p. 25 of this letter. These measures would effectively reduce operational VOC and NOx emissions, DPM emissions, as well as GHG emissions. 29 Diesel Emission Controls in Construction Projects, available at:http://www2.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract-sepcification.pdf 30 Biodiesel lends are only to be used in conjunction with the technologies which have been verified for use with biodiesel blends and are subject to the following requirements: http://www.arb.ca.gov/diesel/verdev/reg/biodieselcompliance.pdf 31http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf 32http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf 33 Repair, Rebuild, and Repower, EPA, available at:https://www.epa.gov/verified-diesel-tech/learn-about-verified- technologies-clean-diesel#repair