First Name | Jeff |
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Last Name | McDonald |
Email Address | jmcdonald@rigmasterpower.com |
Affiliation | |
Subject | End User Device Component Swapping |
Comment | As an APU manufacturer currently in the process certifying a DECS, the amendments made to Chapter 14 are of great interest to me and my company. I am particularly interested in Component Swapping and Re-Designation Practices as it will affect the maintenance infrastructure, as well as its efficiency and quality for the end user. While this addition will greatly affect large ownership fleets maintenance practices, it appears to have disregarded the independent owner-operator who may only have one DECS enabled auxiliary power unit. While some business does come from large fleets, the greater part of sales is done through dealer locations where individual units are sold and installed. By only allowing ownership fleets to swap out DPF‘s during maintenance procedures, you are effectively creating a double standard. A fleet will simply have the luxury of removing the uncleaned DPF and having a new one installed, of course following the provisions set forth by the ARB. Swapping a DPF occurs very quickly, thus allowing the truck to be on the road in a matter of an hour. However, for an independent operator who may only have one APU enabled DECS, it would require the operator to go to a dealer location, have the filter removed, sent to the cleaning facility, cleaned, shipped back and then installed. This is a procedure that could take days or weeks depending on the volume of units in the marketplace, scheduling, etc. If dealers were permitted to carry a stock of new and re-conditioned DPF’s available for swapping, you are in essence giving the owner-operator the same benefits as those given to the larger fleets. This scenario provides customers with an easy, efficient and most importantly cost effective service procedure. If the current amendments are allowed to stand, the independent owner is basically forced to purchase 2 DPF's. This method is not cost effective, and will only deter users from adopting these types of emission reduction strategies. I strongly recommend that further amendments be made to Chapter 14: Component Swapping and Re-Designation Practices, which will encompass all DECS users and not just ownership fleets. As long as proper tracking and maintenance procedures are followed, there is no reason why the same practices set forth in the current amendments cannot be extended for dealer locations and/or DECS product lines. |
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Original File Name | |
Date and Time Comment Was Submitted | 2008-10-01 06:58:25 |
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