Comment Log Display

    We have used air resources board fleet calculator to determine
what are status will be in order to comply with section 2449 title
13 article 4.8 chapter 9. We have sent attachments to show our cost
and to show you how we have arrived at them. We feel that these
costs are extreme, our figures are based on real quotes which we
have given to air resource staff members. We have read through
appendix H “modeling the cost and emission reductions”. Pg H-10 pg
H-11 cost of repowering and cost of retrofitting with PM VDECS. We
have given quotes to ARB staff members. The real cost today are in
some cases over double what the model says they should be. 
    We would like to see the 20% retrofit a year change to 10%
retrofit per year, at 10% per year it would be more cost effective
and would allow technology to catch up and would still serve its
purpose. If you look at the data we have sent you it will show you
that it will take 58.0803% of our net profit to pay for retrofit PM
VDECS in the first year alone. If you add in what it will take to
meet the NOx target, it will take a total of 66.628% of our net
profit. 
   
  At this time 4/18/2007 we have found not one verified NOx level
3 device that can handle Caterpillar 300 to 600hp ranges. 
   
   At this time 4/18/2007 we have found only one manufacturer of a
level 3 PM VDECS to handle Caterpillar 300 to 600hp ranges. 
 
     We have quotes on this PM device and we have seen
demonstrations of this device we have serious concerns about the
safety and of double and tripling these devices in order to make
them function properly. We also have serious problems with the
warranty of this device. In the warranty it states that you have
to present the device to a dealer when there is a problem if the
device can be repaired it will be returned to you within 30 days.
If the unit has to be replaced the time frame extends to 90 days
or when a replacement unit becomes available. These units are
extremely expensive and there is not one contractor that can
afford to have his machine sit for up to 90 days. These are very
big problems that need to be addressed. 
   At this time 4/18/2007 our banking institution has declined to
fund the PM VDECS units. A letter to this effect has been given to
ARB staff members. Please reconsider your position in this matter.