Comment Log Display

Dear California Air Resources Board (CARB),
I am writing on behalf of the motorcoach industry to urge you to
accept the new recommendations from the Environmental Protection
Agency (EPA) regarding the extension of the derate schedule for
heavy-duty diesel engines.
Derating will adversely lead to increased fuel consumption, as the
engine has to work harder to perform the same tasks as it would at
full power. This can have a negative impact on the environment and
can also increase operating costs for fleet owners and operators. 
In reality when a derate takes place the affect is
counterproductive, and doing the exact opposite of CARB's goals in
emission reduction.
Although engine performance and fuel consumption is an important
aspect in regards, we are specifically focused on the safety
concerns.  CARB must consider the safety risks associated with
derating heavy-duty diesel engines and should explore alternative
methods of reducing emissions. This may include the use of cleaner
fuels, the adoption of more efficient engine technologies, or other
innovative solutions.
While derating may seem like an effective way to reduce emissions,
the fact is it is extremely dangerous. By reducing the power output
of an engine, derating can compromise the vehicle's ability to
perform certain tasks, such as climbing hills or accelerating
quickly. This can lead to situations where the vehicle is unable to
operate safely, putting the driver, passengers, and other motorists
at risk.  
There are no circumstances in which an engine should be slowed down
below normal operating speeds.  Currently we have 4 hours to repair
or troubleshoot a vehicle before it is derated to 5mph.  That time
frame is unrealistic and many times impossible to expect operators
to have such a narrow window to make the required repairs.  
We would like to educate CARB that the nature of our business is
very different than other interstate commerce and why we should not
be put in this position.  First and foremost, we are carrying up to
56 people, not cargo or freight.  Most of our passengers include
school aged children traveling for school activities, athletic
competitions and other academic events.  We also move our countries
military regularly.  Imagine a bus shut down on the interstate
carry military personnel to a critical time sensitive function. 
Our industry also plays a major role in evacuations during natural
disasters or other events that require fast mobilization to move
citizens out of harms way.  California for example experiences wild
fires regularly and we are called upon to help get people to safe
areas and out of the line of fire.  Think of a senior citizen
housing facility that has no way to move your grandparents or other
citizens that have no method of getting to safety.  
It is important that we take all necessary steps to protect the
health of our citizens and the environment, but we must do so with
common-sense that does not compromise safety for travelers. I urge
you to consider the potential risks of derating and to work towards
finding safer and more effective solutions to reduce emissions.
Our concerns must not be taken lightly.  The motorcoach industry
has voiced the potential hazards and given fair warning to CARB. 
We believe that if an engine derate results in an accident or other
safety incident, that CARB will be responsible for any resulting
damages. It is our position that the regulations put forth by CARB
must not compromise the safety of those operating the affected
vehicles or equipment.  Any harm to passengers or drivers would be
a result of the careless misunderstanding and lack of cooperation
from CARB.  We would take action against carb in the form of
lawsuits that are related to a derated engine.
We ask you to reconsider the decision to require engine derates and
to work with industry experts to develop alternative solutions that
achieve the desired emissions reductions without sacrificing safety
or performance. We are committed to working with CARB to find a
mutually beneficial solution to this issue.