First Name | Michael |
---|---|
Last Name | Torrez |
Email Address | Michael.Torrez@bp.com |
Affiliation | BP |
Subject | Low-use vehicle definition |
Comment | As BP has previously submitted, low-use is defined on a vehicle basis rather than an engine basis 13 CCR2449(c)(32) – see definition below. In the case of a two engine vehicle, BP believes that the definition should be clarified that each engine can be separately evaluated and categorized as low-use. BP believes that this definition based on the vehicle was not originally constructed with two-engine vehicles in mind. For example, a crane at the Carson refinery with two engines has one that would qualify as low-use and the other that would not. The pony engine is used frequently and would not quality for low-use. However, it was retrofit with a tier 2 engine in the 2005-2006 timeframe. On the other hand, the drive engine only operates about 36 hours per year and should not be subjected to retrofit or repower based on the utilization of the pony engine. The vehicle replacement cost is prohibitively high, and even the retrofit or repower costs would not be justified by the low emission reduction at this usage rate. BP believes this low-use vehicle definition clarification would provide flexibility and ensure that regulatory investment is made cost-effectively by targeting the best emission reduction opportunities. BP also believes that this change is responsive to broader stakeholder concerns and the board direction on April 22nd regarding flexibility and adopting regulations that are most cost-effective – particularly under these difficult economic circumstances. To that end BP has attached a rough cost analysis comparing the costs and emission reductions comparing the cost of replacing the two engine crane (low use drive T0 engine and normal use T2 lift engine) versus a similar cost of replacing a front end loader (single engine T1 normal use). The analysis based on typical costs, average annual hours of the equipment and vendor quotes, show that replacing the normal use T1 equipment reduces diesel PM emissions reduces approximately ten times as much diesel PM then replacing the crane with a low use T0 engine. Additionally the cost per lb of diesel PM reduced for replacing the crane compared to the front end loader is a little over 13 times more expensive. Thank you for considering our comment. Please contact me with any questions you have. Pertinent definition "(32) “Low-use vehicle” means a vehicle that operated in California less than 100 hours during the preceding 12-month period running from March 1 to end of February. For example, when reporting in 2009, the hours of use between March 1, 2008 and February 28, 2009 would be used to determine low-use status. To be considered a low-use vehicle, the fleet owner must submit engine operation data from a functioning non-resettable hour meter…” |
Attachment | www.arb.ca.gov/lists/on-offroad10/87-rough_crane_drive_engine_cost_analysis.xls |
Original File Name | Rough Crane Drive Engine Cost Analysis.xls |
Date and Time Comment Was Submitted | 2010-12-13 18:30:56 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.