Comment Log Display

Mary Nichols, Chair
Members of the Board
California Air Resources Board

The ARB has steadfastly denied fuel additives a place in the
emissions reductions business, although the Technical Support
Document (TDS) for the proposed Truck and Bus Regulations does
state up to 50% reductions in PM are feasible.  Understandably,
VDCES are more effective: therefore ARB wrote regulations
supporting that industry, a multi-billion dollar bonanza for (out
of state) manufacturers of VDECS.

However, ARB has banned aftermarket fuel additives that make
emission reduction claims from use in VDECS retrofits.  Why?  It
seems few in the aftermarket fuel additive industry were aware of
this component of the law, including the Automotive Specialty
Products Association.  It isn’t mentioned in the TDS.  No fuel
additive companies show up on the list of companies contacted.  I
spent years trying to get ARB to consider fuel additives for
emission reductions, and was in constant contact with a long list
of ARB staff.  For years, diesel additives as possible control
technologies were put on upcoming workshop agendas, but Gary Yee
and others at ARB told me “diesel additives are on the back
burner”, and not to come to the meetings.  Apparently, that was
inaccurate.   In fact, I only discovered this ban was law in August
2008, when ARB sent out Advisory #379 to inform people on the
e-mail list it was now illegal to put an aftermarket fuel additive
that makes any performance claim into a VDECS equipped truck.  If
additives were discussed in one of the many VDECS workshops, it was
only discussed with those VDECS stakeholders, since the law also
gives them control over the fuel additive industry.  

The amount of meticulous research data ARB has amassed to
formulate health effects models, estimate premature deaths,
estimate costs of medical visits, costs of VDECS, fuel costs, fleet
modernization costs, maintenance costs, its mind boggling.   I have
no doubt that hundreds, if not thousands of ARB scientists,
engineers, staff, lawyers, economics experts, outside consultants,
etc., have gathered in Sacramento to evolve these hundreds of pages
of data, formulating this law.  However, I have gone through a
dozen documents pertaining to this upcoming VDCES regulation on
trucks, including the TDS, and I can't find any studies, data, or
reference to fuel additives causing harm to VDECS, such that ARB
would need to regulate the industry out of business.  Additives are
necessary to prevent fuel failures that impact emergency
operations, including first responders.  Without fuel additives,
there are situations where lives are at stake.  

The only mention I can find in the TDS that might be a source of
ARB’s concern is one brief note of ash being formed by fuel
additives, although the TDS then states that the majority of ash
that impacts VDECS comes from lubricating oil additive packages,
not from fuel additives.  

The World Fuel Charter, of which all of the OEM’s are signatory
to, state no fuel additives that form ash are allowed.  The EPA
doesn’t allow ash-forming inorganic, non-CHONS (Carbon, Hydrogen,
Oxygen, Nitrogen, Sulfur) additives in road fuels, and both the EPA
and CARB have laws in place that make it illegal to sell or use a
fuel additive that can harm emission control equipment or that
raise emissions.  This new law is redundant, and bans excellent
products with decades of safe, effective use, and many companies
have solid empirical data to support their claims.

The main body of rules, the Technical Support Document, (TDS)
acknowledges fuel additives can lower PM up to 50%.  Additives
could extend the life of a VDECS, or at least lower the maintenance
caused by PM, but simply by stating so makes them illegal.  In
conversation with ARB staff regarding fuel oxidation, contamination
from water and microbial growth, buildup of carbon deposits in the
combustion chamber, intake deposits, and injector deposits, all of
which are going to exist in VDECS equipped trucks, and all are
likely more damaging to VDCES then fuel additives, seems to have
been overlooked.  At least, there is no evidence in the TDS that it
has been considered.  

This part of the law is not a well thought out, and needs to be
revisited before this law is implemented.