Comment Log Display

Dear CARB,
I would like to address the inherent safety implications of your
proposed regulations. It has come to my attention that the addition
of DPF systems to diesel engines is proving problematic in their
current off-road applications. The need for regeneration of the
filter requires conditions that charter boats can't always safely
offer. The result of not performing a filter regeneration is an
intentional loss of power, or in this case, propulsion. In may
circumstances, this can prove to be very dangerous and possibly
deadly, especially for vessels laden with passengers or in rough
weather, or both. It sounds like a great idea to be able to filter
particulates from the emissions, but it seems the the technology is
just still too dangerous for lower engine speed applications at
this point. 

Another concern about the additional DPFs in USCG certified
passenger carrying vessels is whether or not the USCG will even
allow these systems under the current CFRs. Has the USCG had the
opportunity to examine the proposed requirements? Ultimately, they
are the entity that oversees the safety, construction and
modifications to these vessels. Without their input on the
feasibility of these systems, how can the rule making process
proceed? 

I believe we would all like these vessels to have the cleanest
emissions as possible, but the determination of what's possible has
to start with safety. 

Thank you for your consideration,
Brian Collier
SF FISHING INC