First Name | Phillip |
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Last Name | Streif |
Email Address | philstreif@vblinc.com |
Affiliation | Vandalia Bus Lines |
Subject | Heavy Duty Engine Derates |
Comment | Dear California Air Resources Board (CARB), I am writing on behalf of the motorcoach industry to urge you to accept the new recommendations from the Environmental Protection Agency (EPA) regarding the extension of the derate schedule for heavy-duty diesel engines. Derating will adversely lead to increased fuel consumption, as the engine has to work harder to perform the same tasks as it would at full power. This can have a negative impact on the environment and can also increase operating costs for fleet owners and operators. In reality when a derate takes place the affect is counterproductive, and doing the exact opposite of CARB's goals in emission reduction. Although engine performance and fuel consumption is an important aspect in regards, we are specifically focused on the safety concerns. CARB must consider the safety risks associated with derating heavy-duty diesel engines and should explore alternative methods of reducing emissions. This may include the use of cleaner fuels, the adoption of more efficient engine technologies, or other innovative solutions. While derating may seem like an effective way to reduce emissions, the fact is it is extremely dangerous. By reducing the power output of an engine, derating can compromise the vehicle's ability to perform certain tasks, such as climbing hills or accelerating quickly. This can lead to situations where the vehicle is unable to operate safely, putting the driver, passengers, and other motorists at risk. There are no circumstances in which an engine should be slowed down below normal operating speeds. Currently we have 4 hours to repair or troubleshoot a vehicle before it is derated to 5mph. That time frame is unrealistic and many times impossible to expect operators to have such a narrow window to make the required repairs. We would like to educate CARB that the nature of our business is very different than other interstate commerce and why we should not be put in this position. First and foremost, we are carrying up to 56 people, not cargo or freight. Most of our passengers include school aged children traveling for school activities, athletic competitions and other academic events. We also move our countries military regularly. Imagine a bus shut down on the interstate carry military personnel to a critical time sensitive function. Our industry also plays a major role in evacuations during natural disasters or other events that require fast mobilization to move citizens out of harms way. California for example experiences wild fires regularly and we are called upon to help get people to safe areas and out of the line of fire. Think of a senior citizen housing facility that has no way to move your grandparents or other citizens that have no method of getting to safety. It is important that we take all necessary steps to protect the health of our citizens and the environment, but we must do so with common-sense that does not compromise safety for travelers. I urge you to consider the potential risks of derating and to work towards finding safer and more effective solutions to reduce emissions. Our concerns must not be taken lightly. The motorcoach industry has voiced the potential hazards and given fair warning to CARB. We believe that if an engine derate results in an accident or other safety incident, that CARB will be responsible for any resulting damages. It is our position that the regulations put forth by CARB must not compromise the safety of those operating the affected vehicles or equipment. Any harm to passengers or drivers would be a result of the careless misunderstanding and lack of cooperation from CARB. We would take action against carb in the form of lawsuits that are related to a derated engine. We ask you to reconsider the decision to require engine derates and to work with industry experts to develop alternative solutions that achieve the desired emissions reductions without sacrificing safety or performance. We are committed to working with CARB to find a mutually beneficial solution to this issue. |
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Date and Time Comment Was Submitted | 2023-04-27 14:17:43 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.