First Name | Bob |
---|---|
Last Name | Shepherd |
Email Address | bshepherd@quinnpower.com |
Affiliation | |
Subject | PM Retrofit Using BACT - No Reporting |
Comment | I provided a comment in the 45-day comment period about the new, undue burden of unnecessary fleet reporting for those fleets utilizing the straight BACT schedules (Tables 1 and 2) that installed PM filters prior to January 1, 2014. This change in the regulation that should not have been overlooked at the recent Governing Board hearing represents a major reporting change for fleets that will easily lead to compliance issues. Under the provisions of the current regulation, CARB provided relief from reporting if the straight BACT method was utilized, provided that the fleet followed the rigorous schedule of installing PM filters (or replacement) on 1996 - 2006 heavy-duty engines in vehicles > 26,000# GVWR prior to January 1, 2014. Installation of the PM filters allows fleets to operate these retrofitted trucks until sometime between January 1, 2020 and January 1, 2023 depending upon the engine model year without any vehicle reporting other than for low-use vehicles and the annual affirmation reporting. This relief from reporting has been addressed by CARB at workshops and in their on-going training as an added plus for those electing this path for compliance. Reporting for vehicles with other than 1996 – 2006 engines that were retrofitted still required reporting by January 31, 2014. In an attempt to recognize ‘good-faith’ fleets that followed the proper compliance retrofit requirements of the regulation, CARB made proposed changes in the regulation that is awaiting final approval that would allow for a 3-year extension of the original January 1, 2020 date to January 1, 2023. However, contrary to CARB’s original “no-reporting” relief, CARB will now require fleets to report their entire fleet of heavy duty vehicles to have any extension for any vehicle retrofit before January 1, 2014. This unfair change actually penalizes those that followed the BACT compliance path with the extra, unnecessary reporting. In cases like ours, where we replaced over 75 vehicles with 2010 or better engines and retrofitted over 30 vehicles, such reporting would be a huge undertaking as engine information must be pulled manually from each vehicle’s engine as this information is not available with the VIN data. There are many other fleets like ours that would also be unnecessarily forced to now report. Many of these fleets will likely not understand the ramifications of this change and will suffer undue compliance. In my comment made during the 45-day comment period, I suggested the following changes to sections 2025(f)(2) and 2025(g)(4) to alleviate this now-imposed burden on fleets that elected the BACT approach with no previous fleet reporting: 1. The “no reporting” provision should be retained for vehicles with 1996 – 2006 engines in vehicles > 26,000# GVWR if the PM filter was installed in accordance with Table 2 and a fleet wants to keep the original deadlines for replacement as per Table 2. 2. Reporting would still be required as in the current regulation for retrofitted vehicles > 26,000# GVWR with engines other than 1996 – 2006, or for any vehicles retrofitted on vehicles < 26,000# GVWR. 3. Reporting of an entire fleet would only be required if the fleet desired the extra 3 years for vehicles > 26,000# GVWR with engines other than 1996 – 2006, or for any vehicles retrofitted on vehicles < 26,000# GVWR. Note again, as confirmed by CARB staff, the provision in 2025(g)(4) should only apply to vehicles > 26,000# GVWR with other than 1996 – 2006 engines. Provisions for “no reporting” for vehicles with engines in the 1996 – 2006 range is exempt from reporting as stated in the preamble to 2025(g) if the BACT schedule is utilized. The following language is suggested: In the preambles of 2025(f) and 2025(g) the following sentence must be retained to state reporting is not required if using the straight BACT method for compliance: “Fleet owners are not required to meet the reporting requirements of section 2025(r).” In addition, the following modifications to 2025(f)(2) and 2025(g)(4) are necessary: 2025(f)(2) - Any engine that meets PM BACT prior to January 1, 2014 does not have to be upgraded to a 2010 model year emissions equivalent engine until January 1, 2020 as long as the vehicle remains in the fleet, and the owner meets the reporting and record keeping requirements of sections 2025(r) and 2025(s) for such vehicle. Fleets may extend this deadline to January 1, 2023 for engines that met PM BACT prior to January 1, 2014 provided that all lighter vehicles in the fleet meet the reporting and record keeping requirements of sections 2025(r) and 2025(s) by no later than January 31, 2015. 2025(g)(4) - Any engine that meets PM BACT prior to January 1, 2014 does not have to be upgraded to a 2010 model year emissions equivalent engine until January 1, 2020 as long as the vehicle remains in the fleet, the owner meets the reporting and record keeping requirements of sections 2025(r) and 2025(s) for such vehicle, and the vehicle is in compliance with the schedule set forth in Table 2 above at the end of this extension. Fleets may extend this deadline to January 1, 2023 for engines that met PM BACT prior to January 1, 2014 provided that all heavier vehicles in the fleet meet the reporting and record keeping requirements of sections 2025(r) and 2025(s) by no later than January 31, 2015. Again, the regulation needs to stick to the original CARB incentive of “no reporting” if the BACT path is utilized. Thank you for your consideration. Bob Shepherd |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2014-07-02 11:21:32 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.