First Name | Larry |
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Last Name | Rennacker |
Email Address | LarryR@Arrow-Tek.com |
Affiliation | |
Subject | 15 Day Notice Revised Truck and Bus Regulation |
Comment | Text at (j)(2)(C) allows the use of excess off-road regulation PM VDECS credits to meet truck and bus PM BACT requirements, and visa versa. In general the same model year off-road engine emits significantly more PM than the same model on-road engine. In addition, the same passive or active PM VDECS costs at least 25% more in off-road applications than in on-road applications. It would therefore be in all parties best interests to give excess off-road PM VDECS’ additional credit when used to meet on-road PM BACT requirements. I would suggest a minimum of 25%. So, for example, if a 300 hp of off-road piece of equipment were retrofit generating an excess credit, the amount of credit when applied to the Truck and Bus PM BACT would be at 375 hp. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2011-06-03 16:17:22 |
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