First Name | Andy |
---|---|
Last Name | Cox |
Email Address | acox@mcalog.com |
Affiliation | Mike Campbell & Associates |
Subject | ARB'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 Name | HD 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.