| Comment | Text at (j)(2)(C) allows the use of excess off-road regulation PM
VDECS credits to meet truck and bus PM BACT requirements, and visa
versa. In general the same model year off-road engine emits
significantly more PM than the same model on-road engine. In
addition, the same passive or active PM VDECS costs at least 25%
more in off-road applications than in on-road applications. It
would therefore be in all parties best interests to give excess
off-road PM VDECS’ additional credit when used to meet on-road PM
BACT requirements. I would suggest a minimum of 25%. So, for
example, if a 300 hp of off-road piece of equipment were retrofit
generating an excess credit, the amount of credit when applied to
the Truck and Bus PM BACT would be at 375 hp.
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