First Name | Anthony |
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Last Name | Wegrecki |
Email Address | wegrecki2@llnl.gov |
Affiliation | Lawrence Livermore National Laboratory |
Subject | In-Use Off-Road Diesel Vehicle Regulation |
Comment | Lawrence Livermore National Laboratory (LLNL) appreciates the opportunity to offer comments on the proposed amendments to the In-Use Off-Road Diesel Vehicle Regulation being considered for adoption on December 16 and 17, 2010. The comments are as follows: 1. Section 2449(f)(2)(E), Affixing EIN Label to Left Side of Vehicle. LLNL recommends that this proposed requirement be removed. Section 2449(f)(2)(B) already requires an EIN label be affixed to the right side of vehicles covered by the regulation. This proposed requirement would be redundant and add addition cost and time burden to fleet operators with little additional benefit. 2. Section 2449.1(a)(2)(A)(2).a.iv, Credit for Early Retirement. LLNL recommends that the early retirement credit earned by fleets for reducing overall horsepower from March 1, 2006 to March 1, 2010 continue to be equal to its full value and continue to be available for meeting the BACT requirement in any compliance year (and furthermore, continue to never expire). Under the proposed amendments, the early retirement credit earned would be reduced to one half its original value, and for large fleets, the early retirement credit may not be used for meeting the BACT requirement for year ending January 1, 2014. The early retirement credit was part of a California budget agreement (Assembly Bill 8 2X) to provide economic relief to off-road diesel fleets severely impacted by the recession and who reduced their fleet size during that period. Fleets are relying on and have been planning their future compliance strategies (including year ending January 1, 2014) based on being able use their earned early retirement credits in full. Implementing the proposed requirement would reduce the economic relief that Assembly Bill 2X set out to provide. |
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Date and Time Comment Was Submitted | 2010-12-15 10:40:38 |
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