Comment Log Display

I support the idea of improving our air quality, however the
current methods being put into place will destroy our economy. The
ARB needs to step back and look at the bigger picture of how
changes being made to policy will effect usage our natural
resources and the economy. Many older light duty diesels on the
road have had modifications performed that greatly improve their
efficiency, reducing the amount of fuel used and by extension
lessening the amount of exhaust gasses expelled. Under the new
regulations these modifications will become illegal.

For example, on a model year 2000 Ford light duty diesel truck
utilizing a 7.3L Navistar diesel engine approximately 17mpg average
was achieved on 500PPM low sulfur diesel fuel. With the switch to
15PPM ultra low sulfur diesel mpg dropped to an average of 14mpg.
With slight changes to timing and fuel pressure fuel mileage was
brought back up to 17mpg. Thus with the assumption of $3 per gallon
and 35 gallons per fill-up, mileage per tank is reduced from 595
miles per tank to 490 miles per tank. And cost to the consumer has
gone from $1,760 per 10,000 miles to $2,140 per 10,000 miles. With
new regulations requiring inspections on older vehicles and CARB
approval for all parts, cost to the consumer will increase by $380
per 10,000 miles just for fuel. This dose not take into account the
money lost from the removal of the modifications, the extra 126
gallons of diesel fuel burned with exhaust gasses entering the
atmosphere, and taxpayer money needed to run the new inspection
programs.

Diesel smog equipment has been mostly absent until the 2008 model
year light duty diesel vehicles, and many pre 2008 light duty
diesel vehicles were purchased with now illegal modifications
already in place. Change should not be mandated to pre 2008 light
duty diesel vehicle owners. These pre 2008 vehicles will slowly
phase out due to age, there is no need to waist tax payer money
going after such a small minority of vehicles, nor is there a need
to waist these vehicle owner's money. New smog regulations should
only be put into place for 2008 and newer model year light duty
diesel vehicles that already have smog management equipment.

The only possible outcome from smog checking pre 2008 light duty
diesel vehicles is to further burden an already decremented
economy. The tax payers will spend more on inspections, the owners
will spend more on unnecessarily replacing equipment and more
fossil fuels will be burned and put into the atmosphere.