Comment Log Display

December 9, 2008
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812-2815

Dear Chairperson Nichols and Members of the Board:
Mike Campbell & Associates is actively exercising “green”
technologies and practices, and is pleased with many of
California’s measures to reduce harmful emissions and air pollution
from all facets of life.  We are already employing alternative
fuels (Biodiesel), new transport technologies (electric standby on
Transportation Refrigerated Units), and innovative logistics
programs (Turnpike GPS systems) to realize better fuel economy and
more environmentally-sound practices.  Overall, we support the
ARB’s regulations that should help clean the air quality throughout
California.
Still, the ARB’s Statewide In-Use Diesel Truck and Bus Rule may
not yet be without fault.  There are a couple of issues that seem
to stand out when reading through the proposed regulation.  
The first hitch in the ARB’s rule seems to be with the BACT
scheduling.  After surveying the jumbled compliance dates, it does
not seem sensible to require some of the newer model trucks to
comply with Particulate Matter (PM) constraints (MY2005-2006)
before older trucks (MY2000-2002).  The ARB’s BACT schedule is not
chronological and does not seem to offer the best quality of
emissions reductions in the time constraints that it is looking
for.  The DTCC has penned an alternative schedule which
structurally follows the ARB’s schedule, but is organized in a more
chronological order and accounts for the present unavailability of
some reduction technologies (for nitrogen oxides – NOx) thus far. 
This schedule is clearer, more concise, and still delivers the
emissions reduction that the ARB seeks within the time frame that
the ARB has dictated.
After spending considerable time attempting to apply the ARB’s
fleet average model, I have found that the numbers are inaccurate. 
Using the calculations provided – and attached to this letter – I
recognized that trucks that use Tier 3 PM DPFs and proper NOx
filters will never meet the highest level of emissions reduction,
even though the regulation states that they will.  The numbers fall
short of the ARB’s requirements and could affect entire fleets in
the future.  These numbers and calculations need to be revised
(along with the ARB’s online calculators) so that they help
retrofitted trucks meet the ARB’s standards.
Again, Mike Campbell & Associates is encouraged by the efforts of
the ARB and will continue to work with the organization to promote
clean air for California.  However, we want to be certain that each
aspect of this regulation is validated as true and keeps us moving
in the right direction: toward a brighter, cleaner future.

Sincerely,

Andy Cox
Environmental Manager

(Please see attacment for further information and statistics.)