| First Name | Laurence |
|---|---|
| Last Name | Fromm |
| Email Address | fromm@achatespower.com |
| Affiliation | |
| Subject | Phase in for low load cycle and clean idle regulations |
| Comment | Thank for the opportunity to comment on the Proposed Amendments to the Heavy Duty Engine and Vehicle Omnibus Regulation and Associated Amendments. Some of the proposed amendments enable a phase in for low load cycle and clean idle regulations. I wish to call attention to a recently published technical paper from Achates Power showing that testing and analysis of a 10.6L heavy duty diesel opposed-piston engine indicates the engine is able to comply with the 2027 low load cycle and clean idle regulations with a substantial margin (as well as the FTP and RMC regulations). I've attached the technical note. It can also be found here: https://achatespower.com/wp-content/uploads/2021/06/Achates-Power-Ultralow-NOx-at-Low-Loads-and-Idle.pdf Regards, Larry Fromm |
| Attachment | www.arb.ca.gov/lists/com-attach/102-hdomnibus2020-UTBUMVI7UmBXJVQx.pdf |
| Original File Name | Achates-Power-Ultralow-NOx-at-Low-Loads-and-Idle.pdf |
| Date and Time Comment Was Submitted | 2021-06-25 10:34:57 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.