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Welcome to our April 2008 newsletter!

Economic downturn, fuel prices, changing environmental regulations: This newsletter addresses them all!

by Ranger Kidwell-Ross

Ranger Kidwell-Ross, editor

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I'm devoting my editor's column to the changing environmental winds now starting to affect sweeping. There's no question they will do so more in the future. As is often the case, some of this is emanating from the lower left coast of the U.S., California.

At this year's NPE, we got the story of a Sacramento-based sweeping contractor who was fined and had a dozen of his sweepers 'red-tagged' as inoperable because they had older auxiliary engines.

In this issue of the newsletter, we also provide coverage about how California's Air Resource Board (CARB) is slated to eliminate perhaps the majority of the sweepers now in operation in that state by the beginning of 2012, less than four years from now. Although a concerted effort is being made by affected contractors, backed by a white paper I wrote as editor of, the possibility of getting a variance for street sweepers is far from a done deal.

In my discussions with top-level CARB representatives, it became clear that advancing emissions' regulations are on a fast track for implementation. Ultimately, it seems certain that CARB will mandate some type of sweeper testing designed to show how much small-micron material is picked up by different sweeper models, as well as documenting the amount of fugitive dust entrained into the air by each make and model of sweeper as it operates.

CARB, which is in charge of implementing air quality improvements in California, is not connected with the ongoing particle runoff regulations of the major district in its purview, the South Coast Air Quality Management District (SCAQMD). You may recall that SCAQMD is the agency responsible for the sweeper tests now touted as the 'PM-10 Compliant' tests run over five years ago by that agency.

Even though manufacturers like to say their sweepers are 'PM-10 Compliant' by passing the test, in my insider's role as editor of American Sweeper Magazine I was aware that the pass/fail test actually did not reflect any sweeper being able to pick up PM-10 material. That's because only 10% of the debris used in the test was 10-microns or smaller (10% paint pigment was used), yet for political reasons the curve was dropped to allow any sweeper picking up 70% of the total to pass. To date, as far as I know, every model tested by every manufacturer has managed to pass the test and so gain the certification status.

Because of that fact, the actual value of the test has been marginalized to the point of ridiculousness. Now, SCAQMD has set June 6th as the date to consider amending its statute, known as 'Rule 1186.' The proposed amendment, which came from the agency's Mobile Source Committee on May 6th, is as follows:

"Under the (proposed amendment to the 1186) rule, street sweeper manufacturers are required to certify their equipment 'pick-up efficiency' is at least 80%. It has been more than five years since any certification testing has been conducted and there is now a need to ensure that the overall performance of the sweepers can still be demonstrated in the event the manufacturer changes parts suppliers and/or modifies any sweeper specification from that on the originally configured model.

"The proposed amendment would require submission of data to demonstrate that the sweeper performance has not been affected by these changes and to establish a process that aftermarket parts suppliers may qualify to sell replacement parts while maintaining original certification."

The sweeping industry needs to organize in order to keep from getting railroaded by advancing environmental regulations.

In the face of these twin pressures for sweeper testing that are looming on the horizon, I believe it is time for the sweeping industry to start conducting its own ongoing testing procedures. Only by doing so will the industry be able to exercise some control of its own fate in the matter. What I propose is that a blue ribbon panel of industry experts, perhaps with input from both CARB and SCAQMD representatives, develop a testing process that is designed such that it can be fair and impartial, and so set the standard for sweeper testing in the U.S. and the world.

What I propose is what I call 'the test no sweeper can pass.' It would include air emissions' samples taken while sweeping under the test, as well as some type of vacuum test after the sweeper goes by to see what was left on the ground. Most importantly, it would have a wide range of material included. On the heavy end, this would be debris that would tax every broom sweeper to its limits. On the other end of the scale would be very fine, small-micron particles in the PM-10 -- and perhaps under range -- that current air sweepers will have a very difficult time with. Each segment of the test could either have a numeric score or, something that would probably gain my 'by in' by manufacturers, a % of pickup that designated a 'passing grade' for that particular test segment.

Such a test would have enormous benefits for users of sweepers. By evaluating the environmental sensitivity of their particular geographic area requires to provide the best type of environmental outcome given their watershed sensitivity, roadway conditions, area weather, etc., sweeper purchasers could use the results to determine the make and model of machine that appears to be best suited for them. If each category of the test was quantified and shown in the results for every machine tested, those in the market for sweepers would have a way, at long last, to actually evaluate and compare sweeper performance. The test could even include such items as maneuverability and average cost per hour of consumables.

And, to counteract the type of situations now being seen in California, part of this should be a model that shows how much more sweepers pick up than they emit in 'by-product emissions.' My initial analysis for CARB, for example, which compared the amount of small-micron material picked up even by an old Athey Mobil to the emissions from its relatively old engines, showed that taking the sweepers offline is not a good idea unless all sweepers removed were replaced and used the same amount. The result of any such sweeper removed but not replaced (at a cost of @$250,000) would result, the numbers show, in 500% more small-micron debris being available for entrainment into the air.

The test could be designed so as to be adaptable to changing needs over time and to be reproducible in any geographic locale, to make it less costly to conduct. I also envision the test as being open-ended, so as to allow sweeper manufacturers to re-test whenever they deem it necessary, simply by paying the standard testing and certification costs through a designated third party. Another plus is that with buy-in by the manufacturers, the possibility of getting initial funding through interested government agencies would be excellent.

In my view, unless something of this nature occurs the sweeping industry will find itself mired in regulations beyond its control. Given the situation in California, it's clear that's already occurring. It's time for the sweeping industry to regulate itself before it's too late.

In our articles and newsletters we're trying to bring you information you can actually put to use in your sweeping company or municipal sweeping operation. If there's something you'd like us to report about, or if you have comments on this editorial, please let us know. Our goal is to write about what you want to read. In addition, I'll post any comments to this editorial online with it.

As always, if you have a sweeping-related need please tell us about it. We'll try to assist in any way we can. I routinely reference articles and studies, provide information from my "Fundamentals of the Power Sweeping Business," manual and put contractors and city officials in touch with others who may have answers to their information needs. By the same token, if you have a story you can provide, additional information on any of the topics we've covered in this newsletter issue – or need more details – please let me know. I'll be glad to help if at all possible.

Good Sweeping!
Ranger's Signature
Ranger Kidwell-Ross, editor

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