Comment Log Display

 	
Donaldson Company, Inc.
1400 West 94th Street
Bloomington, MN  55431   USA	
Mailing Address
PO Box 1299
Minneapolis, MN  55440   USA



STATEMENT FROM DONALDSON COMPANY, INC.
ON THE AIR RESOURCES BOARD’S
PROPOSED AMENDMENTS TO THE
REGULATIONS FOR IN-USE OFF-ROAD
AND IN-USE ON-ROAD DIESEL-FUELED 
FLEET REGULATIONS


December 17, 2010


Donaldson Company, Inc. is pleased to provide comments on the ARB’s
proposed amendments to the regulations covering in-use on-road and
off-road vehicles.  Donaldson understands the need for industry
economic relief that is driving the proposed changes.  We support
the Manufacturers of Emission Control Association (MECA)
recommended changes to the proposal in an effort to identify
additional opportunities for emission reductions.

Donaldson is headquartered in Minneapolis, Minnesota, and is a
leading worldwide provider of filtration systems and replacement
parts.  The company serves customers in the industrial and engine
markets with a product mix which includes air and liquid filters
and exhaust and emission control markets.

Donaldson is also a member of the Manufacturers of Emission Control
Association (MECA) and has been actively working with EPA and
California ARB Diesel Risk Reduction Plan (DRRP) and EPA’s
Voluntary Diesel Retrofit Program (VDRP).  Donaldson presently has
Verified retrofit technologies and is a leading supplier for both
ARB’s DRRP program and for EPA’s VDRP.  Specific reference and
background to Donaldson’s emission control technologies may be
accessed from our corporate web site at
www.donaldson.com/emissions.

In addition to support of MECA’s overall comments or positions
regarding ARB’s proposed amendments, Donaldson also wishes to
provide specific comments concerning certain aspects of ARB’s staff
proposal.  ARB consideration of a few key modifications to the
proposal that would achieve further emission reductions while
providing additional opportunities for verified retrofit
technologies.

For the On-Road rule, key requested modifications include:

•	Add mandatory PM retrofits for 1994 – 1997 trucks over 26,000
pounds with extended life before turnover is required to achieve
additional early PM reductions.
•	Incentivize installation of ARB or EPA verified Level 1 or Level
2 retrofits on under 26,000 pound trucks before turnover to provide
additional reductions in toxic exhaust emissions from the medium
duty fleet.
•	Add mandatory PM retrofits for school buses under 26,000 pounds
and prioritize incentive funding to cover the costs.

For the Off-Road rule, key requested modifications include:

•	Inclusion of a retrofit for life provision for up to 15% of the
fleet horsepower until January 2013 and double credits for
retrofits installed up to one year prior to the compliance date as
a way to incentivize early PM reductions via retrofits.
•	Add mandatory PM retrofits on high use equipment (>500 hours)
that remains in the fleet  and does not have a diesel particulate
filter.

Donaldson also requests near term reviews with ARB staff and short
term ARB interim policy guidance on various approaches that would
provide economic relief to retrofit device manufacturers and insure
that verified technologies are available when they are needed.

Donaldson believes that more can be done to further streamline the
verification process by increasing the cooperative effort to
harmonize the application and test plan approval process with U.S.
EPA to better move toward true reciprocity of the two verification
processes.

Streamlined, more cost effective verification procedures are
suggested such as:

•	Establishing a more streamlined verification process to broader
applications within a given sector (examples:  Off-Road tracked
vehicles, high horsepower Dual exhaust systems).
•	Establish an engineering or running change procedure for
non-emission critical part changes with notification but without
ARB approval need.

Additional streamlined, more cost effective in-use testing
procedures are suggested such as:

•	Consider change of current 50 unit threshold to 500 unit sales
trigger for in-use compliance to harmonize with EPA 500 unit sales
trigger.
•	Allow use of data obtained from vehicles that operate outside of
California.
•	Allow legacy retrofits where feasible to only do Phase 2 testing
(showing long term performance).

In overall summary, we urge the Board to adopt the proposed changes
to the fleet regulations and also request near term ARB policy
guidance adjustments for existing verification and in-use
compliance procedures.

In closing, we commend the Air Resources Board and staff members
continuing efforts with healthy air quality, and in implementing
the Diesel Risk Reduction Plan.  Donaldson intends to provide
continued commitment and support of ARB’s objectives and looks for
continued cooperative effort with ARB staff and other
stakeholders.

Thank you,

Julian Imes

Director, Advanced Technology &
Government Affairs
Donaldson Company, Inc.