Comment Log Display

Response to Rulemaking 2008-12-11 Notice 15 Day – Truck and Bus
Regulation Changes

The California Bus Association (CBA), representing intercity,
passenger stage corporations and charter bus companies is hereby
responding to the California Air Resources Board Notice of
modifications to the regulation.

CBA supports the following 15 Day Notice modifications and
expansions of the rule:

It expands the definition of “heavy duty diesel vehicle” to
include “motorcoach” in new Section 2025(d)(39).

It modifies the definition of “NOx Exempt Vehicles” to include
motorcoaches since they are exempt from the NOx performance
requirements until 2017 under Section 2025(d)(56)(E).

Section 2025(g)(2) is added so that fleets that have motorcoaches
can comply with a separate NOx percent limit schedule as “MC NOx
BACT”.

Consistent with the above changes, Section 2025(g) Table 2
(Percent of Total Fleet) option adds a separate compliance path for
motorcoaches.

Section 2025(h)(2)(C) provides a definition of the NOx target for
motorcoaches in determining the NOx target rate option (fleet
averaging option) for motorcoaches in a fleet.

Consistent with Section 2025(h)(2)(C), Table 3 lists the fleet NOx
targets for motorcoaches.   

A new section 2025(l) has been added to “provide motorcoaches an
exemption from the NOx requirements until January 1, 2017…”. The
new motorcoach NOx values are used for the two options in Table 2
or Table 3.  

New section 2025(p)(1)(D) adds motorcoaches to the NOx exempt list
until January 1, 2017. 

The amendments in this 15 day notice as cited above will
materially benefit both the environment and all motorcoach patrons.


Our industry is recognized as a leader in contributing to the
reduction of traffic congestion and airbourne criteria pollutants
such as NOx, PM, and also CO2. 

The continued sustainability of the entire motorcoach industry to
serve fixed route and charter demand depends on a regulatory scheme
that balances the ability of our industry to remain in business
while reducing mobile source emissions.

The changes in the regulation referred to in this response are a
positive step in this direction.

Chris Riddington
President
California Bus Association