First Name | Mark |
---|---|
Last Name | Carlock |
Email Address | mcarlock@foundationccc.org |
Affiliation | Foundation for Cal. Community Colleges |
Subject | Requirement for ASM Testing |
Comment | It has been proposed that consumers wishing to participate in the EFMP submit to an ASM test to ascertain sufficient vehicle functionality. In the conduct of the EFMP pilot program in the South Coast Air Basin, requiring an ASM test, even though free to the potential participant, was seen as significant obstacle to participation. There is also no data correlating the ability to complete an ASM with either the remaining useful life of a vehicle or the mileage accrual rate. As you indicate on the chart provided in the ISOR, that the differential in the emissions of older vehicles compared to newer ones can be substantial and it would be counter to the stated objectives of the program to omit these older, higher-emitting vehicles due to uncertainty regarding usage. It is respectfully suggested that the state consider using their official on-road emission inventory model(EMFAC) to establish an actuarial table predicting remaining useful life of a vehicle according to model year and odometer reading. Such an approach would be more consistent with Moyer Guidelines as well as the modeled effectiveness of programs like EFMP. Staff might consider limiting the ASM requirement to those vehicles that have a project life expectancy of less than 2 years - which would suggest that they would not survive until their next scheduled inspection. We believe that such a consideration will help improve upon the low participation rates achieved in the past as well as save funds that might be better spent on other aspects of the program. Thanks for your consideration in this matter. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2014-05-29 14:40:40 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.