Comment Log Display

December 15, 2010
 
Mary Nichols, Chairman 
California Air Resources Board
1001 I Street 
Sacramento, CA 95812 

RE: 	Proposed Amendments to the Regulations to Reduce Emissions of
Diesel Particulate Matter, Oxides of Nitrogen and Other Criteria
Pollutants from In-Use On-Road Diesel Fueled Vehicles, Off-Road
Diesel Fueled Fleets, and LSI 2010 


Dear Chairman Nichols:

NAFA Fleet Management Association (NAFA) is the world’s premier
fleet professional organization, representing members from all
facets of the fleet industry including public and private fleets.
The 2100 vehicle fleets managed by NAFA’s 3,000 members
collectively total more than 3.5 million vehicles, of which more
than 1.1 million are trucks, and of those over 350,000 are medium
and heavy- duty trucks. The NAFA CARB Advisory Council has reviewed
the proposed regulatory actions and respectfully submits the
following public comment.

NAFA’s Council recommends increasing all vehicle and equipment
minimum usage exemption parameters (mileage and hours of
operation). This will provide a small measure of relief to public
and private fleets which have been incredibly impacted by the
current economic situation. It is no secret that this state has
been especially hard hit by the recession and that current diesel
vehicle operation and usage is far below projections due to the
economic environment. Additionally, there is a general lack of
retrofit devices available for larger equipment such as
construction and heavy GVW forklifts; especially older equipment.
Increasing minimum usage parameters would allow fleets to make
better use of existing units for which no suitable retrofit device
exists and therefore greatly aid fleets struggling just to remain
in business with minimal impact to overall projected diesel
emissions.

NAFA’s Council recommends that in order to provide equity if
implementation is delayed, CARB should identify and provide
preferential incentives to fleets that have already made efforts to
comply with CARB regulations. Fleets that committed to early or as
scheduled compliance made significant financial investments in
vehicles and other capital assets. These fleets will be at a severe
competitive disadvantage against other similar businesses with
fleets that did not take any compliance actions. Some possible
options include establishing a preferential priority for grant
funding for these fleets, establishing tax credits or incentives
for these fleets, or providing additional equipment
“grandfathering” opportunities for those fleets that may take
advantage of them. NAFA looks forward to working with CARB staff to
develop a plan to ensure equity for those fleets that made good
faith efforts to comply with CARB regulations.




NAFA’s Council also recommends that CARB consider allowing use of
up to B20 biodiesel blends as a means of compliance or partial
compliance, especially with off-road equipment. There is a severe
lack of available retrofits for much of the older and larger
off-road equipment. Those retrofit devices that are available are
unproven and costly. While there have been concerns expressed in
the past regarding NOx emissions when using biodiesel, NOx
emissions are for all practical purposes neutral with B20
biodiesel.  DOE’s National Renewable Energy Laboratory confirms the
positive impact of B20 on emissions of HC, CO, and PM and states
that “the data are insufficient for users to conclude anything
about the average effect of B20 on NOx, other than that it is
likely very close to zero” in their “Biodiesel Handling and Use
Guide, Fourth Edition”.  Allowing B20 biodiesel use as a compliance
measure is a low cost solution to immediately lower PM emissions
and generally increase the usage of lower carbon content and
renewable biodiesel in California.

NAFA’s Council also recommends that CARB consider waiving
certification requirements for manufacturers willing to build
alternative fuel off-road and construction equipment. There are
fleets willing to consider alternative fuel off-road equipment
options; however the equipment is not currently available. Part of
the problem is that the low volume of sales cannot justify the
expense of undergoing CARB certification. In order to jumpstart
innovation and expansion in the area of alternative fuel off-road
and construction equipment, NAFA recommends CARB survey the
manufacturers of this equipment for sale in California to determine
if waiving CARB certification of this equipment would stimulate
development in this area.

In closing, NAFA supports CARB’s efforts to reduce vehicle
emissions and appreciates CARB’s commitment to amend existing rules
in acknowledgement of the current economic situation and
corresponding change to projected vehicle and equipment emissions
that the rules were originally based upon. NAFA greatly appreciates
the opportunity to comment on the proposed rulemaking and we look
forward to continue working together with CARB staff in the
future.


Sincerely,




Richard E. Battersby
Chairman, NAFA CARB Advisory Council