Comment Log Display

The proposed method merits consideration of alternative plans,
primarily due to the present plan's economic improbability for any
measure of success.  The recent past with electric de-regulation
made this state the object of many lessons; please do not create
another debacle with the trucking.
One principle feature of the proposed rule is the 'Best' available
control technology.  With the present rule, the retrofit DPF device
is essentially the only acceptable solution.  However, the word
"best" is an oxymoron.  The technological "best" is a 2010 engine
with matched SCR filter.  A mandate toward a retrofit filter may
not provide the overall solution being sought as it will relegate
limited economic resources toward a retrofit technology which may
include an upgraded engine. These engines which were not designed
for the retrofit filter from a backpressure standpoint or an oil
consumption standpoint.  The use of Level I and II devices should
be allowed as part of this emission reduction plan.  
My one truck is operated less than 2000 (two thousand) miles
annually (and passes the smoke test).  With the proposed rule, at
the end of 2012 it will need a filter.  There is no filter
available for the engine so we must change the engine and add a
filter  - big bucks necessary with (1) no financing options and (2)
not being able to 'pass the cost on' for the mileage utilized.  
As a suggestion, why not provide an option for a level 1 or 2
device with a five or ten thousand mileage limit?  If this was
allowed for far less cost, then the funds would hopefully diverted
to a used 2010 truck in say around 2015 or 2016 where the economy
must certainly be better.
I recently noticed a specific business sector has recently
arranged for a mileage cap and deadline extension in order to
absolutely exempt some vehicles - any reason level 1 or 2 devices
were not invoked to at least obtain some of the credit needed to
meet the EPA mandated targets?
Please consider suggestions being offered and provide a clean air
solution that we can all live with - yes, literally so for many
folks.
Sincerely,  Robert Dorazio PO Box 604, Avila Beach,CA 93424 (San
Luis Obispo County)