RVIA is monitoring the progress generator manufacturers are making in developing zero-emission alternatives to Small Off-Road Engine (SORE) -powered generators and working with the California Air Resources Board (CARB) and other interested parties to find cost-effective and technologically feasible solutions that will allow RVs with generators to be sold in California.
CARB passed amendments to the SORE regulation in December 2021. The regulations apply to all spark ignition engines less than 25 horsepower. These amendments were approved by the Office of Administrative Law and will take effect Jan. 1, 2023.
The engines that power all gas and LP-powered RV generators are impacted by the regulation; diesel RV generators are exempt, but a separate regulation amendment covering diesel SORE engines is underway. In the SORE regulation, CARB defines “generator” as off-road equipment that exclusively produces electric power, while “generator engine” means an engine installed exclusively in a generator. It is technically not the generator that is being regulated, it is the engine that powers the generator.
The SORE regulation looks at products primarily in terms of model years, which it defines as “a manufacturer’s annual production period that includes Jan. 1 of a calendar year, or, if the manufacturer has no annual production period, the calendar year.” The amendments approved by CARB will ban the gas/LP engines traditionally used in RV generators, effective with the 2028 certification model year since all engines on generators must be zero emissions.
In addition, beginning with generator engines produced in the model year 2024, there is a significantly lower allowable emissions standard. Only CARB-compliant generators will be permitted to be sold in California.
RVIA has brought this dilemma to CARB’s attention, but CARB has thus far declined to reconsider its stance, RVIA said.
CARB’s refusal to change its position may be because, starting this year, the regulation makes it possible for RV manufacturers and suppliers to earn and bank credits by offering alternatives to traditional SORE-powered generators, RVIA said.
To have the credits recognized by CARB, companies providing zero-emission solutions (whether they are RV manufacturers or suppliers) will need to certify the system with CARB according to the provisions of Section 2408.2 of the SORE regulation.
“Zero-emission generator” is defined in the regulation as any SORE that generates or stores energy and distributes electrical power while producing zero emissions under any and all possible operational modes and conditions.
Anybody producing or certifying zero-emission generators can generate credits. The credit program is a tiered program with four levels of zero-emission generators (levels 1-4), which are differentiated by energy storage capacity and power delivery. Bigger, more powerful systems generate more credits than smaller/less powerful systems. These credits generated in the 2022-2027 timeframe can be traded or sold to traditional gas/LP SORE manufacturers and used to offset compliance deficits incurred through the sale of SOREs that are not zero emissions. This credit program has the potential to defer the 2028 ban to 2032.
