| Comment | Lawrence Livermore National Laboratory (LLNL) appreciates the
opportunity to offer comments on the proposed amendments to the
In-Use On-Road Heavy Duty Diesel Vehicle Regulation (Truck and Bus
Regulation) being considered for adoption on December 16 and 17,
2010. The comments are as follows:
1. Section 2025(d)(40), Definition of Low Use Vehicle. LLNL
recommends that the hour use limit for vehicles with power take-off
be increased from 100 hours per year to 200 hours per year. This
would harmonize the low use definition in this regulation with the
proposed low use definitions in CARB’s other vehicle regulations
such as the Large Spark Ignition Engine Regulation and the In-Use
Off-Road Diesel Vehicle Regulation.
2. Section 2025(n)(2), Requirements for Two-Engine Sweepers. LLNL
recommends that Tier 0 auxiliary engines (greater than 50
horsepower) on two engine sweepers be allowed to operate up to 200
hours per year after January 1, 2014. This limit would be
consistent with the low use limits for engines covered in the Large
Spark Ignition Engine Regulation and in the In-Use Off-Road Diesel
Vehicle Regulation.
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