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Comment 11 for Statewide Truck and Bus Regulation 2008 (truckbus08) - 15-2.

First NameTom
Last NameMcCloskey
Email Addresstmcclosk@pacbell.net
Affiliation
SubjectIs this true?
Comment
Is this true?  Isn't there a way to get more CNG vehicles on the
road?  This would reduce emissions of all kinds and reduce oil
imports.  More CNG vehicles would help bring home the troops from
the Middle East.  Let's get some plans in the works to command
additional CNG vehicles...

I am a Director of a Company that has been converting diesel and
gasoline engines to run on CNG for more than a decade. I can tell
you that the biggest hurdle to adoption of CNG technology in the
USA has been the turf war between CARB (the California Air
Resources Board) and the US EPA over just who exactly is the
overlord of exhaust emissions.
These two agencie's unwillingness to streamline, clarify or adjust
regulations for new technology is legendary.
My company currently has the product and capability to convert 85%
of existing in use heavy duty diesel engines to run more
efficiently ( more power, zero PM, 30% less CO2, etc) on CNG or LNG
than on any form of "clean diesel fuel" for less than $10,000 per
engine, but CARB won't allow it...
In California, thousands of trucking, construction and
agricultural diesels must be retro-fitted with Particulate Matter
(PM) filtration systems or be moved out of the state by this
December. The cost of these systems range from $8,000-$25,000 per
engine. This ruling will wipeout entire businesses, and thousands
of jobs. The retrofitting of these diesel engines actually causes
them to use more fuel for the same work, thereby increasing our
dependence on foreign oil, and actually increasing Green House Gas
production.
CARB will not allow conversion of these very same engines to run
on CNG, even though it pays for itself through decreased fuel
costs, eliminates PM pollution ( the target of all this
legislation), and decreases CO2 and GHG production as dictated by
AB32.
Conversion fulfills all the goals, but CARB won't let it happen.
HOW are they stopping it?
According to CARB, if you convert an existing in use heavy duty
diesel engine to run on CNG or LNG, they consider it a BRAND NEW
engine, and the converting party must now Guarantee/Warranty the
motor as if new. For on road engines, this means for 500,000 miles,
and the engine must meet 2012 exhaust emissions standard. Doesn't
matter if the engine is 10, 20 or 50 years old.
Additionally, as a BRAND NEW motor, each model/engine variant must
be CARB and EPA certified to pass the 2012 standard at a cost of
over $350,000 per engine per model per year of production.
What if you sell retrofit filters instead? You only have to
warranty your retrofit equipment for two years, and there is no
requirement to warranty the motor at all. If your system kills the
engine, too bad for the owner...
Certification of these retrofits involves a simple durability
testing, and they can be certified across a Family of motors
covering many variants and model years with a single
certification..
We actually sell the PM filters to other companies here in CA
making retrofit kits, but we pulled out of that business ourselves
because it is THE WRONG SOLUTION.
If CARB would simply allow CNG conversion to be treated the same
as the retrofit kits, we could convert thousands of AG pumps in the
Central Valley, and eliminate a large reason why they are a federal
"non-attainment" area in terms of clean air. We could convert the
entire fleet of container carriers at the Ports of LA and Long
Beach, allowing them to expand operations as they would now fall
well below the air pollution cap that has held back expansion. This
creates JOBS.

Attachment
Original File Name
Date and Time Comment Was Submitted 2009-10-19 11:03:37

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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