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Comment 16 for Greenhouse Gas Heavy Duty Vehicles (SmartWay) (ghghdv08) - 45 Day.

First NameAndy
Last NameCox
Email Addressacox@mcalog.com
AffiliationMike Campbell & Associates
SubjectARB's HD GHG rule
Comment
December 9, 2008
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812-2815

Dear Chairperson Nichols and Members of the Board:
Mike Campbell & Associates is actively exercising “green”
technologies and practices, and is pleased with many of
California’s measures to reduce harmful emissions and air pollution
from all facets of life.  We are already employing alternative
fuels (Biodiesel), new transport technologies (electric standby on
Transportation Refrigerated Units), and innovative logistics
programs (Turnpike GPS systems) to realize better fuel economy and
more environmentally-sound practices.  Overall, we support the
ARB’s regulations that should help clean the air quality throughout
California.
However, our company has found flaws in some regulations that may
have been overlooked by the ARB.  In preparation for the upcoming
AB32 Heavy Duty Greenhouse Gas regulation, Mike Campbell &
Associates decided to test some of the SmartWay-inspired
aerodynamics technologies that the ARB is requiring for 53-foot
trailers.  We have attached our results of the testing which was
performed with a 53-foot fully-loaded long haul trailer across
approximately 500 miles of (mostly) highway travel: ideal
conditions for testing aerodynamics. 
The ARB initiated this regulation considering the success of the
US EPA’s SmartWay program.  However, the ARB has not utilized the
federal voluntary program as decisively as possible.  We have made
the argument that the federal SmartWay program was meant as a
complete package, not individual components thereof.  In the
attached pages, you can find statistics that show that solely
relying on aerodynamic technologies does not account for the
majority of the federal SmartWay program’s reduction of emissions. 
There are many other components to the US EPA’s SmartWay program
that should be examined if the ARB intends to base a California law
upon it.
Further, the ARB has never conducted any studies on the proposed
regulation regarding actual application.  The numbers for a federal
program are going to display different outcomes than a state whose
truck speed limit is 55 MPH.  All of the federal testing was
performed at speeds of 62 MPH.  This 7 MPH reduction could account
for more fuel efficiency (and less greenhouse gas emission) than
adding any aerodynamics to a trailer.
Again, Mike Campbell & Associates is encouraged by the efforts of
the ARB and will continue to work with the organization to promote
clean air for California.  However, we want to be certain that each
aspect of this regulation is validated as true and keeps us moving
in the right direction: toward a brighter, cleaner future.

Sincerely,

Andy Cox
Environmental Manager
(Please see attachment for more information)

Attachment www.arb.ca.gov/lists/ghghdv08/20-hd_ghg_letter.pdf
Original File NameHD GHG letter.pdf
Date and Time Comment Was Submitted 2008-12-09 10:03:50

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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