Comment Log Display

C.A.R.B. 
 
 
I have watched the over-all averages of various fleets go down
substantially in the past (5) years or more. We used to fail about
(1) in every (10) trucks tested; back in 1999 and 2000. Today the
failure rate is about (1) in every (50) trucks tested. This is due
to numerous factors. I.E: older equipment being fazed out of use,
more diligent maintenance programs, lower sulfur content fuel, and
........ fear of prosecution for "fooling around" with engine fuel
management systems. 
 
The yearly mandated Opacity tests are the main thing that is
driving the movement toward higher compliance and lower over-all
emissions that have benefited our State.
 
I believe the new regulations covering In-use, Off-road
construction equipment would see the same levels of improvement
and compliance as the  In-use, On-road (Truck Fleets) have if
yearly "Opacity" testing was mandated in the same manner as it has
been with the truck fleets. It is the simplest and most reliable
"final test" to verify the impact (success?) of all the required
changes to Off-road equipment. All the pledged engine
replacements, exhaust system additions/modification, and other
expensive procedures required of Equipment Owners will be much
harder to quantify and verify without the simple test results of a
yearly Opacity Test reading done in the field. It is  a relatively
inexpensive, quick, and accurate, hands-on test that shows the
results of millions of dollars of capital investments.
 
Please consider this verification method in your final analysis of
the program. I truly believe that the yearly Opacity Test
requirements is the best, most efficient way to ensure the success
of your over-all program to reduce dangerous diesel particulate
emissions from In-use, Off-road, construction equipment.
 
 
 
Ray Biasotti
Owner 
T&D Transport  
Pleasant Hill, CA.