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Ironman would like to provide input on specific aspects of the
Draft Regulation to Control Emissions from In-Use On-Road
Diesel-Fueled Heavy-Duty Drayage Trucks. Ironman is currently one
of the significant providers of Retrofit devices and installations
in California. Ironman hopes that our comments and suggestions,
based on insight and experience, might be beneficial in enhancing
the ARB regulation. 

The 2 years provided to complete Phase 1 of the Drayage truck rule
would not be a concern if the retrofits were completed in a
balanced manner over the 24 month period. In Ironman’s experience
with the Solid Waste Collection Vehicle Rule and the Fleet Rule
for Public Agencies & Utilities, most fleets focus on the
“just-in-time” strategy.  80% of the individuals affected by the
ARB emissions rule delay compliance as long as possible, in this
case compliance would be delayed to the last quarter of 2009. This
“just-in-time” strategy creates a peak in DPF manufacturing &
installation labor demand and therefore puts a severe strain on
resources to complete the requirements of retrofitting by the
deadline. 

Ironman believes that drafting a regulation that encourages a
balanced retrofit program through different incentives would be
most helpful. This balanced program can be achieved by
implementing a schedule of deadlines and progressively requiring
certain percentages of the fleets to achieve compliance. This
approach would allow all funding resources, retrofit
manufacturers, installers and compliance regulators to be more
cohesive in supporting the Drayage fleets to achieve the goal of
100% compliance in a balanced and timely fashion.  

A second method for a balanced program would be to develop a
tiered incentive and provide early adopters in 2008 with a higher
dollar incentive towards the retrofit. The fleets that delay
compliance until the final half of 2009 would receive a lower
incentive. This would provide fleets with the financial incentive
to get the work done as early as possible, emission reductions
would be realized sooner, and everyone would benefit from a more
balanced approach in meeting the deadline. 

Ironman trust that you find this input constructive in formulating
and finalizing the new Drayage Truck regulation. We look forward to
working with ARB and the Drayage Truck owners to assist in
providing “Emission Compliance with Confidence™”.