Comment Log Display

Please see attached letter from the Santa Clara Valley
Transportation Authority (VTA).    We are concerned that the ARB's
efforts to force compliance with On Board Diagnostics of regulation
1971.1 on heavy duty Diesel Hybrid applications, and the
requirement for a single party certification of OBD, will have the
unintentional effect of eliminating new Diesel Hybrid Transit buses
from California. 
      	The Transit bus market is separate and much smaller than the
truck market, and in the case of Diesel Hybrid systems, the
supplier base is different.    The additional development costs of
complying are spread over a relatively small number of vehicles. 
Since this is an effort only California is requiring at this time,
the total number of vehicles involved is even smaller, making
compliance economically impractical.   Rather than endure the extra
costs of development and the risk of fines if they are unable to do
so, Diesel Hybrid Transit bus suppliers will simply abandon the
California market.   
	Please refer to the attached letter for details on the situation
in the Transit bus market and the supporting reasoning for VTA's
position. 
	VTA requests that for the Transit bus segment of the Diesel Hybrid
market, the ARB instead match the EPA schedule for compliance.  
This will allow Californians to continue to enjoy the undeniable
environmental benefits of Diesel Hybrid buses, while allowing the
ARB to have confidence that progress will proceed on the
certifications issues surrounding OBD. 

James Wilhelm
VTA 
Senior Engineer