CARB's Ban on Generators

​CARB Bans RV Generators Starting in 2028,
​Acknowledges Challenges Ban Creates For The RV Industry

by Dyana Kelley, CampCalNOW CEO & President

At its hearing on December 9, the California Air Resources Board (CARB) passed Resolution 21-13-2 (as amended at the hearing) to approve the proposed amendments to the Small Off-Road Engine (SORE) regulation. The SORE regulation applies to all spark ignition engines less than 25 horsepower. All gas and LP-powered RV generators are impacted by the regulation; diesel RV generators are exempt, but other new regulations being developed by CARB will affect off-road diesel engines. The December amendments approved by CARB will lower the emission standards for the gas/LP engines traditionally used in RV generators beginning in the 2024 model year, and will totally ban such engines effective with the 2028 certification model year. Despite efforts by the RV Industry Association and others to have RV generators exempted from the regulation, the ban was approved by the Board as proposed by CARB staff. As discussed below, the resolution was modified at the hearing to reflect the RV industry’s concerns.

Though the proposed amendments were not revised at the hearing, the Board did direct staff to report annually on the status of compliance and the progress being made (or not being made) in developing zero emission solutions. Staff was also directed to issue a more detailed technology readiness assessment in the 2025-2026 timeframe. If this readiness assessment finds that the technology needed for compliance in 2028 is unlikely to be available, consideration will be given to adjusting the timeline.

It is important to note that, starting in 2022, the regulation will make it possible for RV manufacturers and suppliers to earn and bank credits by offering alternatives to traditional SORE-powered generators. 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. These credits can be generated in the 2022-2027 timeframe. When traded or sold to traditional gas/LP SORE manufacturers, the credits can be 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.

In mid-March of this year, Cummins sent a letter to all OEMs informing them that, due to the new emissions standards in CARB’s SORE regulation, they would be unable to supply generator engines that were compliant with the regulation starting in the 2024 model year. RVIA staff sent a letter to CARB in late March to inform them of this decision which will impact RV manufacturers of vehicles destined for the California market. RVIA will continue to interact with CARB staff to advocate that they differentiate fixed-mount stationary generators used in RVs from other portable generators.

Read more for previous updates on the CARB ban.

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Where Things Currently Stand

Update as of 12/22/2021

​Recently there has been varying degrees of information shared about the California Air Resources Board (CARB) ban on generators.  RVIA in conjunction with RVDA has been hard at work to protect the interests of the RV manufacturers and dealers but you may be wondering what effect this will have on your business and most importantly your guests.
 
In layman’s terms, the resolution seeks to ban the “SALE” of gas/LP engines less than 25 horsepower including those permanently installed in RVs.  However, it does not ban the use of them.  Meaning that, your guests may continue to use the generators they currently own but at some point, will not be able to buy one in California regardless of it being a stand alone or installed.
 
The 2022 Small Off-Road Engine (SORE) regulation applies to all spark ignition engines, but diesel RV generators are exempt.  RVIA issued the release below which provides a little more insight. 
 
"At its hearing on Thursday, December 9, the California Air Resources Board (CARB) passed Resolution 21-13-2 (as amended at the hearing) to approve the proposed amendments to the Small Off-Road Engine (SORE) regulation. The SORE regulation applies to all spark ignition engines less than 25 horsepower. All gas and LP-powered RV generators are impacted by the regulation; diesel RV generators are exempt. The amendments approved by CARB will ban the gas/LP engines traditionally used in RV generators, effective with the 2028 certification model year. Despite efforts by RVIA and others to have RV generators exempted from the regulation, the ban was approved by the Board as proposed by CARB staff. As discussed below, the resolution was modified at the hearing to reflect the RV industry’s concerns.

At the hearing, many representatives of the RV industry, including manufacturers and suppliers, the RV Industry Association, the RV Dealers Association, and the California RVDA, testified on the proposed amendments and the need for different treatment for the fixed-mount generators in RVs. The education that RVIA and the other stakeholders did with Board members and staff prior to the hearing did result in several Board members expressing worry about the challenges that lie ahead for the RV industry in complying with the ban. Though the proposed amendments were not revised at the hearing, the Board did direct staff to report annually on the status of compliance and the progress being made (or not being made) in developing zero emission solutions. Staff was also directed to issue a more detailed technology readiness assessment in the 2025-2026 timeframe. If this technology readiness assessment finds that the technology needed for compliance in 2028 is unlikely to be available, consideration will be given to adjusting the timeline.
 
It is important to note that, starting in 2022, the regulation will make it possible for RV manufacturers and suppliers to earn and bank credits by offering alternatives to traditional SORE-powered generators. 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. These credits can be generated in the 2022-2027 timeframe. When traded or sold to traditional gas/LP SORE manufacturers, the credits can be 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.
 
Along with CARB, RVIA will continue to monitor the progress generator manufacturers are making in developing zero emission alternatives to SORE-powered generators and work with RVIA members to educate them on the new credit program and the opportunities it presents. A copy of the SORE regulation as amended and all relating rulemaking documents can be found here.  Anyone having further questions about the ban should contact Michael Ochs, RVIA Director of State Government Affairs at mochs@rvia.org."