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Comment 23 for In-Use Off-Road Diesel-Fueled Fleets and Off-Road Large Spark Ignition Engine Fleet Requirements (on-offroad10) - 15-1.

First NameLarry
Last NameRennacker
Email AddressLarryR@Arrow-Tek.com
Affiliation
Subject15 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.

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Original File Name
Date and Time Comment Was Submitted 2011-06-03 16:17:22

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