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LAKEPORT UNIFIED SCHOOL DISTRICT
Transportation Department / From the desk of David Norris /
Director of Transportation
2503 Howard Ave, Lakeport, CA  95453	
707/262-3022    Fax 707/262-3034

November 7, 2008

Dear ARB Board Members, Please take into consideration the
following issues when making your decisions on the proposed
regulation; In-Use Heavy-Duty Diesel-Fueled Vehicles.

Lake County Air Quality Management District; Exempt all busses
that only operate inside of air districts that are in attainment.

Low-use vehicles exemptions; currently the regulation allows an
exemption for busses that accumulate 1,000 miles per year or less.
This regulation should be increased to 2,000 miles per year to
allow school districts to use these busses as back up busses to
fill in when the daily operating busses are out of service for
safety inspections and repairs. By adding exhaust retrofit devices
the down time for service, inspection and regeneration will be
increased.

Match waivers 20%; Presently the proposal is to allow only 20% of
the busses that are funded are eligible for match waivers for air
districts that comply totally with air quality standards; Lake
County is the only one in the state. Lake County Air Quality
District cannot receive AB 923 funds from DMV fees. This means less
revenue for all Lake County school districts to comply with lower
emissions program. It is imperative that the match waiver be
extended to all bus replacements grants.

Electrical Infrastructure; The regulation allows for $20,000 to
complete each retrofit. Out of the $20,000 the install is about
$16,000 and $2,500 for maintenance, which leaves about $1,500 for
electrical infrastructure. LUSD applied for 7 retrofits, which
leaves us with $10,500 for electrical infrastructure. Our proposal
came in at $38,127. Will ARB cover the balance of $27,627?

Lake County Air Quality Management District (bus replacement
only); Lake County is unique, as it is the only county in the state
that is in compliance with state air quality standards. The funds
allocated to Lake County should be spent on bus replacements only.
Each school district would be able to replace at least 2 busses
each, based on the funds allocated. These busses would be on daily
runs immediately, and would deliver the best performance (cleaner
exhaust, longer range and fuel economy). In addition they would
last for the next 20 years. It does not make good sense to spend
$20,000 on a retrofit device on a bus that has used up ½ to 2/3 of
its life.
Lake County Air Quality Management District (exempt all busses or
fully fund); Lake County does not have a problem with air quality
so either totally exempt or fully fund school busses in Lake
County. Reward air districts for meeting state standards.
Smoke test; Is the smoke necessary to continue after we are in
full compliance with the law.

The Yellow School Bus has been an essential part of providing
public education to the children of Lakeport. It is part of the
fabric of this American institution, the very foundation in how we
educate our children. In California we have developed a system that
has proven to be the safest form of transportation in the world. We
have the strictest regulations relating to the construction and use
of the school bus and the education and training of our drivers.
Lets not, over under fund this new regulation, which appears to be
mandated, to the point that we can’t afford to operate them.

Sincerely,

David Norris