Comment Log Display

Donaldson Company Inc. is pleased to provide comments on ARB’s
proposed amendments to the verification procedure, warranty and
in-use compliance requirements for existing on-road, off-road and
stationary diesel fueled vehicles and equipment.  Donaldson is a
worldwide filtration solution provider to the transportation
industry.  Our Exhaust/Emissions business has been producing VDECs
for both the California and EPA market for more than a decade.  We
have designed and manufactured hundreds of thousands of emission
systems for both the OEM and retrofit customers.

While Donaldson appreciates the proposed changes to lessen the cost
impact of the in-use compliance requirements, the numerous changes
and additions to the rules more than offset the cost benefit to the
manufacturers.  In addition, several of the rule changes increase
the business risk of producing these devices without providing any
measurable benefit to California’s clean air efforts.

Donaldson understands the pressure ARB is under to address the
safety of retrofit systems.  Unfortunately, the proposed rule
generate a potentially unequal playing field where its possible
that some devices are subject to more stringent scrutiny than other
devices.  Section 2706 (w) 2 allows ARB to require both safety
testing and design modifications.  However, there are no criteria
or established procedures identified.  Without such procedures or
standards, there is no way for a manufacturer to determine what is
acceptable and what is not from ARBs perspective.  As with most
devices it is conceivable to generate a test that uses
unrealistically harsh conditions that result in a device failure. 
This section makes it possible for a test or design to be imposed
on one device that wouldn’t apply to others.  We would propose that
any safety rules be based on accepted industry standard practices,
are objective, and apply equally to all devices whether OEM or
retrofit produced.  

Donaldson agrees that the vehicle pre-assessment described in
section 2706 (t) is in the best interest of all parties.  However,
2706 (t) (4) imposes a 15 day window before device installation on
the timeframe that a basic engine assessment must be conducted. 
This timeframe is unnecessarily prescriptive and imposes a burden
on the commercial relationship between the manufacturer, installer,
and end user.   The timeframe for completing a basic engine
assessment should be left to those that are responsible for the
accuracy and timeliness of the installation.

Section 2708 (b) makes it more difficult to obtain a verification
by requiring every test meet the emissions target rather than a
simple average.  While this is not a significant impact for Level 3
PM reduction, it is more problematic for NOx reduction.  There is
currently one VDEC approved by ARB that exceeds 50% NOx reduction. 
This verification was granted in 2005.  Making it more difficult to
achieve a target NOx reduction would appear counter-productive,
when there are few NOx reduction VDECs currently available.  We
also question if this approach to require every test pass the
standard has been previously applied to emissions testing.  Using
an average is industry accepted practice with most tests that
involve some degree of variability.  For example, the SAE standard
J1667 which is used for opacity testing and relied upon to
determine acceptable engine performance, uses an average of 3 tests
with a boundary on the testing variability.  

Donaldson has made a significant investment in the development of
products and business infrastructure to supply the California
retrofit market with emission reduction technologies.  We believe
that there is still a good fit between the products we provide and
the need for clean air devices.  However, the added costs required
to comply with ever changing ARB rules is making it more difficult
to justify ongoing investment in the retrofit product line.  We
would urge ARB to assess each of the new rules discussed above as
well as those identified by the Manufacturers of Emissions Controls
Association for their absolute need and benefit as they pertain to
the performance and reliability of VDECs.