Comment Log Display

Dear Chairman Nichols and Members of the Board,

We are generally in support of the staff proposal that you would be
considering to adopt at the upcoming Board meeting on January 26,
2012. The three sets of Clean Cars regulations have been crafted
keeping in mind that the eventual success of these programs
requires deployment of large volumes of clean cars that use
electricity or hydrogen to power them and can only be accomplished
through a matching national program. Together, they will reduce
foreign oil dependency; improve air quality; and advance
technology.

For more than 30 years we have observed that the vehicle emission
standards adopted in California, eventually lead to similar
standards at the national and international level. In addition,
these regulations have also proved to be a stimulus for developing
newer, cheaper and safer technologies that have eventually spread
worldwide. The staff has a similar vision for these regulations
that would shape the future light-duty vehicle fleet across the
world. 

We concur with the opinion of many groups that the proposal can be
strengthened by increasing the threshold set for over-compliance
and placing a cap on the total percentage vehicles that can be
allowed into this crediting program. However, we recognize that the
agreement between Federal Government, Air Resources Board,
automakers and lack of support from many automakers may be a
limiting factor to address this issue. 

In contrast, we believe that there are no such limiting factors and
urge you to modify the compliance date of particle emissions
standard (1mg/mile) in the Low Emissions Vehicles regulation to be
phased-in from model year 2022 (instead of 2025) as had been
originally planned. The Board is fully aware of the magnitude of
mortality and other adverse health impact of particulate pollution
and the number of air basins violating the fine particle standard.
Thus, we feel it is imperative that you take actions to reduce
particulate pollution as early as feasible. In addition, we feel
that providing extra lead time to gasoline engines and to the
gasoline direct injection technology is against the principle of
the Board being fuel and technology neutral.

We acknowledge the fact that current measurement and monitoring
technologies may have some limitations to assure compliance.
However, in our opinion, providing a 10-year lead time is adequate
to develop technologies that would ensure proper certification and
compliance.  In addition, ARB can choose conduct a review of
technologies in the 2017 timeframe and modify if necessary the
final form, stringency, or the compliance timing of the particle
emissions standard. 
 
We have learned from our conversations with the Manufacturers of
Emission Controls Association (MECA) that our recommended time line
is reasonable and is in fact, more in line with the recent European
Commission decision to establish a particle number emission
standard for light-duty vehicles powered by gasoline direct
injection (GDI) engines as a part of their upcoming Euro 6
light-duty emission standards.  Many auto manufacturers that sell
into the European market are working with MECA members on potential
applications of particulate filters on gasoline direct injection
vehicles. We concur with MECA’s suggestions that ARB needs to make
sure that the same ultra-low PM, Euro 6 GDI engines/technologies
developed in Europe are also utilized in California. 

We urge you to maintain the Board’s history, leadership and
neutrality in setting technology forcing emission standards with
respect to light-duty vehicle particulate emissions.

Sincerely,
Shankar Prasad
Coalition for Clean Air