Comment Log Display

As BP has previously submitted, low-use is defined on a vehicle
basis rather than an engine basis 13 CCR2449(c)(32) – see
definition below. In the case of a two engine vehicle, BP believes
that the definition should be clarified that each engine can be
separately evaluated and categorized as low-use.  BP believes that
this definition based on the vehicle was not originally constructed
with two-engine vehicles in mind.  

For example, a crane at the Carson refinery with two engines has
one that would qualify as low-use and the other that would not. 
The pony engine is used frequently and would not quality for
low-use.  However, it was retrofit with a tier 2 engine in the
2005-2006 timeframe.  On the other hand, the drive engine only
operates about 36 hours per year and should not be subjected to
retrofit or repower based on the utilization of the pony engine. 
The vehicle replacement cost is prohibitively high, and even the
retrofit or repower costs would not be justified by the low
emission reduction at this usage rate.  

BP believes this low-use vehicle definition clarification would
provide flexibility and ensure that regulatory investment is made
cost-effectively by targeting the best emission reduction
opportunities.  BP also believes that this change is responsive to
broader stakeholder concerns and the board direction on April 22nd
regarding flexibility and adopting regulations that are most
cost-effective – particularly under these difficult economic
circumstances. 

To that end BP has attached a rough cost analysis comparing the
costs and emission reductions comparing the cost of replacing the
two engine crane (low use drive T0 engine and normal use T2 lift
engine) versus a similar cost of replacing a front end loader
(single engine T1 normal use). The analysis based on typical costs,
average annual hours of the equipment and vendor quotes, show that
replacing the normal use T1 equipment reduces diesel PM emissions
reduces approximately ten times as much diesel PM then replacing
the crane with a low use T0 engine. Additionally the cost per lb of
diesel PM reduced for replacing the crane compared to the front end
loader is a little over 13 times more expensive.

Thank you for considering our comment.  Please contact me with any
questions you have.

Pertinent definition

"(32) “Low-use vehicle” means a vehicle that operated in California
less than 100 hours during the preceding 12-month period running
from March 1 to end of February. For example, when reporting in
2009, the hours of use between March 1, 2008 and February 28, 2009
would be used to determine low-use status. To be considered a
low-use vehicle, the fleet owner must submit engine operation data
from a functioning non-resettable hour meter…”