Comment Log Display

Dear CARB,

I wish to express our concerns with the proposal to solve the
Cleaire Longmile VDECS (verified diesel exhaust control system)
problem.

We currently have added DPFs to 154 vehicles.  We took advantage of
the early retrofit credit on 139 vehicles at a cost of over
$2,000,000.00.  This was done at a time that the economy and in
particular construction was crushed in California.  

We had previously given testimony and sent letters advising CARB
that the technology to retrofit concrete trucks that do not create
sustained exhaust was not available.  Almost every DPF requires 260
degrees Celsius 25% - 40% of the time.  The Cleaire Longmile only
requires temperatures of 260 degrees Celsius 7% of the time.  These
retrofits worked well for us.  I have heard countless number of
horror stories from others in our industry about problems that they
had with other brands of DPFs.

There were fires related to engines with higher horse power that
used the Cleaire Longmile.  This prompted a “voluntary recall” of
the existing metal filters.  They were supposed to be replaced with
a certified silicon carbide core.  Cleaire Muffler Modules were
installed temporarily.  

Cleaire went out of business and ESW CleanTech Inc. acquired the
assets of Cleaire.  When ESW CleanTech contacted me to remove the
remaining metal filters I said that they are working fine and I did
not want to remove them.  I was told that if we did not allow them
to remove the metal filters we would not be eligible to have the
silicon carbide core installed when they become available.  That
doesn’t sound like a voluntary recall to me.

In the CARB Mail-Out #MSC 13-04 the CA Air Resources Board stated
that they “will be working closely with fleets, dealers, and parts
suppliers to minimize the impact of the Cleaire closure.”  We have
never heard from them since then regarding the Cleaire LongMile.

CARB verified these systems.  They had to have a five year
warranty.  Cleaire stated in their letter dated 11/20/12 that “In
the past 12 years, Cleaire has delivered over 18,000 compliant
systems, many still in operation long after the 5 year warranty
period.  With that said we are not satisfied with the CARB’s
proposal to have to replace these filters 5 years after the recall
notice.  This means that after six years we have a 100% replacement
rate of the entire system.

CARB should stand behind the systems that they verified.  If there
are costs related to replace the core or the entire system CARB
should pay those costs.  We purchased these retrofits knowing that
we would be running these trucks until 2022.  We cannot purchase
120 new trucks five years early at an additional cost of over
$25,000,000.00.  This cannot be done and still meet all of the
other many CARB requirements that we face both on and off road.

Sincerely,

Mike Cook
Purchasing/Fleet Manager