Comment Log Display

I have read over the 2025(f)(2) and 2025(g)(4) and the way it seems
to be worded it would suggest that in order to get any extension
for any vehicle retrofit done before 1/1/14, all the vehicles in
the fleet would need to be reported. Under the original BACT,
reporting was not required to get the extension to 2020 for
retrofitted vehicles > 26,000# GVWR and engines between 1996 and
2006. If you are now making reporting of all vehicles a requirement
to get the extension to 2023, I believe this is really penalizing
those that did the right thing under BACT before 1/1/14 to have
them now be required to report. If this is the intention, then I
would perhaps make this suggestion:

1. No reporting necessary if the PM filter is installed before
1/1/14 and they want to keep the original 1/1/2020 deadline.

2. Reporting of their entire fleet would only be required if they
wanted the extra 3 years.

While the extension to 2023 would sound great to those that
complied or did more effort than they should have by 1/1/14, the
disincentive of reporting now to get any extension far outweighs
any elation.

The regulation needs to stick to the original concept of no
reporting if the BACT path is utilized.

Thank you.

Bob Shepherd