Comment Log Display

The current Verification of Diesel Emissions Reduction Strategies
regulation specifically excludes Natural Gas as alternative fuel
in direct conflict with the CEC and the Governor's Energy Advisory
Panel's objective to increase Natural gas use as an alternative
fuel.
Under the current regulations, the only options available to fleet
owners are to install expensive exhaust treatments that only
increase operating and fuel costs, the carbon footprint of each of
these vehicles, and may actually increase the NOx output. There is
NO BENEFIT TO THE END USER, and therefore no economic incentive to
be in compliance.
Allowing these fleet owners to convert existing in-use engines to
run on Natural gas gives them an opportunity to meet current and
future standards quickly and inexpensively while actually
decreasing their operating costs through fuel and maintenance
savings. This provides an economic incentive that actually
benefits the business owner and thus the economy.
NOx and PM reductions are so much more dramatic with Natural gas
that both the South Coast and San Joaquin areas should be able to
attain federal air quality standards ahead of schedule, as fleet
owners now have an incentive to be in compliance.All this and a
decrease in Carbon footprint of 20-80%, thereby taking the lead in
reducing Carbon output.
The verification of technologies scheme does not need to be
changed to allow use of Natural Gas conversion technology. All
that needs to be done is to give up on the distinction between
spark and compression ignited engines. There should be no
distinction. Simply continue to define engines by their intended
Horsepower output as you do currently, and allow providers of this
technology to have their products verified in the same manner as
the EGR and SCR providers. 
Under current regs, Natural Gas converted engines must go through
a complete certification process as a unique NEWLY Manufactured
engine. This means each individual engine is required to go
through this process at a cost of $100,000 or more. A requirement
which precludes anyone from ever doing a conversion.
At the Port of Long Beach UTR project (the one listed on the front
page of the ARB website), two Natural Gas converted 5.9 liter
Cummins engines are being tested and have performed excellently,
exceeding all expectations. But SSA can't actually move forward
with converting the fleet as it would cost nearly $2Billion
dollars to certify all 2000 UTRs that have this type of engine.
If the ARB would simply level the playing field, and allow this
conversion technology to be certified in the same manner as the
SCR and EGR technologies, the ARB could see the entire Long Beach
port realize a PM reduction of 99.9%, and HC, Carbon and NOx
reductions of 80% on average. This would be accomplished in a
three year time frame.
Change the regulation please.