Comment Log Display

As an APU manufacturer currently in the process certifying a DECS,
the amendments made to Chapter 14 are of great interest to me and
my company.  I am particularly interested in Component Swapping
and Re-Designation Practices as it will affect the maintenance
infrastructure, as well as its efficiency and quality for the end
user.

While this addition will greatly affect large ownership fleets
maintenance practices, it appears to have disregarded the
independent owner-operator who may only have one DECS enabled
auxiliary power unit.  While some business does come from large
fleets, the greater part of sales is done through dealer locations
where individual units are sold and installed.  By only allowing
ownership fleets to swap out DPF‘s during maintenance procedures,
you are effectively creating a double standard.  A fleet will
simply have the luxury of removing the uncleaned DPF and having a
new one installed, of course following the provisions set forth by
the ARB.  Swapping a DPF occurs very quickly, thus allowing the
truck to be on the road in a matter of an hour.  However, for an
independent operator who may only have one APU enabled DECS, it
would require the operator to go to a dealer location, have the
filter removed, sent to the cleaning facility, cleaned, shipped
back and then installed.  This is a procedure that could take days
or weeks depending on the volume of units in the marketplace,
scheduling, etc.  If dealers were permitted to carry a stock of
new and re-conditioned DPF’s available for swapping, you are in
essence giving the owner-operator the same benefits as those given
to the larger fleets.  This scenario provides customers with an
easy, efficient and most importantly cost effective service
procedure.  If the current amendments are allowed to stand, the
independent owner is basically forced to purchase 2 DPF's.  This
method is not cost effective, and will only deter users from
adopting these types of emission reduction strategies.  I strongly
recommend that further amendments be made to Chapter 14: Component
Swapping and Re-Designation Practices, which will encompass all
DECS users and not just ownership fleets. 

As long as proper tracking and maintenance procedures are
followed, there is no reason why the same practices set forth in
the current amendments cannot be extended for dealer locations
and/or DECS product lines.