Comment Log Display

Lawrence Livermore National Laboratory (LLNL) appreciates the
opportunity to offer comments on the proposed amendments to the
In-Use Off-Road Diesel Vehicle Regulation being considered for
adoption on December 16 and 17, 2010.  The comments are as
follows:

1.	Section 2449(f)(2)(E), Affixing EIN Label to Left Side of
Vehicle.  LLNL recommends that this proposed requirement be
removed.  Section 2449(f)(2)(B) already requires an EIN label be
affixed to the right side of vehicles covered by the regulation. 
This proposed requirement would be redundant and add addition cost
and time burden to fleet operators with little additional benefit.

2.	Section 2449.1(a)(2)(A)(2).a.iv, Credit for Early Retirement. 
LLNL recommends that the early retirement credit earned by fleets
for reducing overall horsepower from March 1, 2006 to March 1, 2010
continue to be equal to its full value and continue to be available
for meeting the BACT requirement in any compliance year (and
furthermore, continue to never expire).  Under the proposed
amendments, the early retirement credit earned would be reduced to
one half its original value, and for large fleets, the early
retirement credit may not be used for meeting the BACT requirement
for year ending January 1, 2014.  The early retirement credit was
part of a California budget agreement (Assembly Bill 8 2X) to
provide economic relief to off-road diesel fleets severely impacted
by the recession and who reduced their fleet size during that
period.  Fleets are relying on and have been planning their future
compliance strategies (including year ending January 1, 2014) based
on being able use their earned early retirement credits in full. 
Implementing the proposed requirement would reduce the economic
relief that Assembly Bill 2X set out to provide.