Comment Log Display

To:  Clerk of the Board, Air Resources Board
1001 I Street, Sacramento, CA 95814

http://www.arb.ca.gov/lispub/comm./bclist.php

fax 916-322-3928

 The State of California 
Air Resources Board Amendments to the zero emissions bus
regulation

In response to the mailed package I was sent for comment:

Comments to the CARB zero emission public comment period.  Our
product is the TriTrack, which could conceivably replace buses
with personalized taxi-like service to either a city or a school
district.  The method to replace a large number of seats on a
traditional bus is to go much faster delivering people or students
to their individual destinations.  The biggest change that the
TriTrack requires is the building of more elevated infrastructure
around the present city layout.  While this may seem an impossible
task at impossible cost it is not.  The TriTrack guideway is
intended to be very low cost and built in a fraction of the time
it normally takes to improve a city’s mobility.  The idea for bus
replacement is to take the same driving staff as the bus
enterprise now, but instead of putting that work force out on the
streets in lumbering big box transit they would be driving much
faster 4-passenger all electric un-tethered electric cars that
have an infinite range while in the bounds of the city and the
city’s suburbs.  

There are many gains that are made by converting to this newer
approach.  The air pollution will be essentially zero and the
energy used will be drastically less.  Also this will be lower
cost both initially and operationally.  School children will no
longer have to endure long bus rides to school and back home but
rather they only sit in the seat for the time it takes to take 3
children home at high speed.  This will give them more study time
or more family time before homework.  

We are not sure how to amend the document to include the
possibility of exchanging buses for TriTrack cars driven by the
same staff as the buses.  It would seem like there could be
wiggle-words in the document that describe the net effect and then
let technology fill the answers with hardware and systems. 
Although well meaning, the document does unduly cater to the
diesel engine manufacturers lobbyist.  This is odd since it is
their poor invention that has caused the problem.  The document
reads more like a planned obsolescence scheme to buy and trash
diesel equipment with a phased cleanup.  That sends the wrong
message that we should reward the makers of the offending
machinery with multiple future purchases.  I am sure you are aware
of the gasoline hybrid buses that pollute a fraction of what the
diesel hybrid buses emit at a lower cost.  Because the hybrid
electric portion provides the boost on takeoff a normal car engine
with full catalytic converter can be used.  I do not understand why
governments are so inclined to continue to buy diesel especially
for school buses.  They should be immediately banned until they
are cleaner than gasoline versions with full exhaust treatment to
the state of the art.  It is like the big three are playing a big
game by holding back every single step of the way and only
shipping product that barely meets that year’s requirements.  This
document falls right into that master scheme by specifying that
buses bought in the short term are for sure going to be scrap
before their normal wear-out.  On this point it seems this
document is on the wrong side of the pollution issue.  Gasoline
buses are cheaper to purchase and hiring mechanics to drop new gas
engines in every 200,000 miles at factory crate prices is much
cheaper than the initial purchase bump for being a nasty diesel. 


I have one other suggestion for the document and that is to refer
to these low emitting vehicles as low emitting and put a number on
that typical pollution based on the energy mix for the power
company in the area.  This will do more good than you would think
giving the public true measured information rather than painting
them too clean.  The net effect is the public has a hard time
understanding why they are called “zero” when it is painfully
obvious that they are not truly zero emitting.  Even if we
consider the solar version of the TriTrack where the energy needed
to power these cars with wheels retracted is less than the energy
that can be taken from the sunshine that comes down onto the right
of way for the guideway, the factory that made the solar panel did
use some pollution source to make them initially.  This is a tiny
number but still not zero.  It would be like truth in advertising
to actually assign the best estimate of the pollution used to
build and power each vehicle system so the public has correct
information and they can believe the answers.  The per-passenger
NOx pollution for a TriTrack compared to a per-passenger diesel
bus from 1989 is a 99.5% reduction in pollution.  It is
unfathomable that these diesel engines are so dirty but that has
been hidden from the public for too long.  How bazaar is it that
diesel engines are allowed to pollute based on the nameplate brake
horsepower.  That entire rating system is ridiculous.  It should be
measured per passenger and the bus-with-engine should be considered
as a system.  All they have to do to a nonconforming engine is up
the horsepower rating and then magically it is allowed to pollute
more and that is OK.  Well that is not OK but an artifact of a
flawed measurement system.  Also diesels are allowed to emit that
start up black plume and that is not counted in the measure of
pollution.  That gets a total free pass in the measuring method
yet our children’s lungs do not have a valve that they can shut
off to not breath that black plume that gets by the present
measurement system.  If you can’t go electric or solar then as a
bare minimum save $4,000 per bus and buy gasoline and make sure
they don’t leave off the converter just because they can.  The gas
hybrids are probably the best immediate solution if you have to
continue with big box transit.  I saw nothing that requires these
diesels to remain clean burning.  There is a discrepancy between
the projected life of the engine and the projected life of the
pollution bolt-ons to clean up the NOx.  It will do no good to
have a urea tank that stops functioning at 90,000 miles if the
engine runs another 300,000 miles.  Where is the provision that
provides a metric for total miles driven or how hard the driver
pushing the equipment?  These measures are token at best unless
they realistically represent the pollution that will result from
the irresponsible purchase of yet more diesels with large
displacements.  

A quick progress report on the TriTrack.  We have been accepted
into the Automotive X PRIZE race.  We are one of 30 competitors
representing 5 countries.  The Automotive X PRIZE is from the same
folks who brought the space X PRIZE and the prize money is
significant for this next challenge.  Our patented battery swap
technology combined with our patented circular cross section
guideway car, even driven on the street, will give us a huge
advantage in this race.  It is the fastest car that still gets 100
mpg equivalent while seating four passengers comfortably.  Things
are starting to move quickly now.  All-electric is what the public
believes is the long term answer so our suggestion is to skip some
of the more polluting intermediate steps and go for the goal.  

Thank you for the opportunity to input to this document.  

Jerry Roane	
101 S. Laurelwood Drive    -- and Palo Alto CA
Austin, TX 78733
512-263-5344  512-294-1960cell  JRoane@TriTrack.net  
www.TriTrack.net