Comment Log Display

  
Donaldson Company, Inc.
1400 West 94th Street
Bloomington MN
55431-2370	Mailing Address:
PO Box 1299
Minneapolis MN
55440-1299 U.S.A.	Tel. 952.887.3131
Fax 952.887.3155
www.donaldson.com




STATEMENT FROM DONALDSON COMPANY, INC.
ON THE AI RESOURCES BOARD’S
PROPOSED REGULATORY AMENDMENTS TO THE
VERIFICATIUON PROCEDURE, WARRANTY AND IN-USE
COMPLIANCE REQUIREMENTS FOR IN-0USE STRATEGIES TO
CONTROL EMISSIONS FROM DIESEL ENGINES

January 27, 2010


Donaldson Company, Inc. is pleased to provide testimony in overall
support of ARB’s proposed amendments to the verification procedure,
warranty and in-use compliance requirements for existing on-road,
off-road and stationary diesel-fueled vehicles and equipment.

Donaldson is headquartered in Minneapolis, Minnesota, and is a
leading worldwide provider of filtration systems and replacement
parts.  The Company serves Customers in the industrial and engine
markets with a product mix which includes air and liquid filters
and exhaust and emission control markets.

Donaldson is also a member of the Manufacturers of Emission
Control Association (MECA) and has been actively working with EPA
and California ARB staff to develop and provide diesel retrofit
control technology in support of ARB’s Diesel Risk Reduction Plan
(DRRP) and EPA’s Voluntary Diesel Retrofit Program (VDR). 
Donaldson presently has Verified retrofit technologies and is a
leading supplier for both ARB’s DRRP program and for EPA’s VDRP. 
Specific reference and background to Donaldson’s emission control
technologies may be accessed from our corporate web site at
www.donaldson.com/emissions.

Donaldson supports overall MECA comments or positions regarding
ARB’s proposed amendments.  Donaldson does wish to provide,
however, additional comments concerning certain aspects of ARB’s
staff proposal.

Specifically, Donaldson has concerns over aspects of proposed
changes to the maintenance requirements, Section 2706(h) for VDECS.
 In subsection (2) proposed changes require that applicants provide
detailed maintenance information sufficient to enable an owner to
properly maintain the VDECS without requiring services be provided
exclusively by the applicant or the applicant’s distributor.

MECA and Donaldson have previously shared our concerns with ARB
relating to the use of independent third party cleaning services
with some type of approval process by the VDECS supplier. 
Donaldson is concerned about potential damage that improper
cleaning can cause VDECS cores by untrained personnel using
inappropriate cleaning equipment.  We believe ARB should create an
approval process to minimize VDECS damage risk.

As an example of this type of approval process, Donaldson now has
Certified Dealers in California that currently offer Donaldson
approved Level 3 diesel filter cleaning services.  These dealers
are Donaldson Certified, have Donaldson cleaning equipment and have
been trained to provide Donaldson approved cleaning services for
Level 3 diesel filters.

End users who seek to complete Donaldson approved in-house Level 3
Diesel filter cleaning need to work through a Donaldson Certified
Dealer in California.  The Donaldson Certified Dealer will offer
Donaldson cleaning equipment and provide necessary training to end
users to gain Donaldson approval of the Level 3 diesel filter
cleaning process.

Donaldson also suggests responsibility clarifications for the
proposed change in Section 2706(t) relating to pre-installation
compatibility assessment.  In subsection (4), ARB indicates the
need for installers to conduct a proper due diligence of the engine
prior to installing a VDECS and maintaining all records associated
with the conclusion of compatibility.  Donaldson supports MECA
statement comments that flexibility should be allowed in these
requirements but also suggests that pre-installation assessments
and associated documentation requirements be mutual
responsibilities of the equipment owner and the VDECS installer.

In closing, we commend the Air Resources Board and its staff
members for continuing efforts with healthy air quality and in
implementing the Diesel Risk Reduction Plan.  Donaldson intends to
provide continued commitment and support of ARB’s objectives and
looks for continued cooperative effort with ARB staff and other
stakeholders.

Sincerely,

Donaldson Company, Inc.



Julian Imes
Director, Advanced Technology
  and Government Affairs
Exhaust/Emissions




Julian.Imes@Donaldson.com
Office:  952/887-3730