Comment Log Display

The proposed regulations as currently written place an unfair
burden on the use of clean fuel technology, particularly Natural
Gas. Conversion of existing in-use diesel powered Buses and Trucks
to run on Natural Gas is a widely adopted technology outside of the
United States. Adoption of this Technology here in California is
the ONLY possible way we can meet the AB 32 Global Warming Act
deadlines.
Unfortunately, current certification for VDECS and BACT make no
mention of Natural gas conversion as a viable option. This is due
to CARBs definition of Diesel versus "Large Spark Ignition
Engines". Essentially any diesel motor converted to run on Natural
gas, that now has a spark ignition, is now considered a Large Spark
Ignition motor, and must be certified as a BRAND NEW motor, and
must meet 2010 on road emissions standards. 
This is NOT the same criteria used for certifying VDECS and BACT
for existing older engines. Additionally, certification of these
converted motors must be then done on a model year, make and engine
designation basis, rather than just for engine families as for
current VDECS and BACT.
The advantages of converting these exact motors/vehicles to
Natural Gas from both an environmental and economic standpoint have
been well documented in other countries. The current regulations,
as written, eliminates any chance of California being in compliance
with AB 32 and puts an economically insurmountable barrier to
certification of Natural Gas conversion technology solidly in
place.
The emissions strategy as currently outlined in this proposed
regulation will place an economic burden upon California business
owners for which there will be no possibility of economic benefit.
Conversion to Natural Gas for these fleets, where possible, will
actually save these fleet owners in fuel and maintainence costs,
with 100% conversion ROI usually realized with in the first year of
operation. This CANNOT be said for any other emissions strategy.
Before you adopt ANY further regulations for emissions of existing
in-use engines, you MUST level the playing field for Natural Gas
Conversion technology to compete against exhaust after treatment
systems as an emissions strategy.

Dr. John Reed
Director, Omnitek Engineering