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We wanted to comment regarding the Innovative Technology Regulation
proposed in 2016.  We have advocated a change in the outdated
regulations that catered to the passenger vehicle volumes to
justify the certification costs for some time.  As you are aware,
the commercial truck and bus markets are small by comparison. This
regulation that allows limited quantities of new technologies get
into the field to gather real world data on emissions and
performance, is invaluable to suppliers of these new and innovative
technologies.  The ITR 2016 regulation allows minimal quantities of
emerging technologies into field trials without extensive testing
and data collection.  This phased approach allows manufacturers to
work with local California fleets to trial and implement the
technologies while collecting valuable data for them and the ARB. 
While we think there is still much ground to cover regarding full
integration into OEM chassis and OBD compliance, this regulation is
a step in the right direction.

We strongly support the passage and 'fast track' implementation of
this regulation to allow emerging technologies to begin to make an
impact on air quality as soon as possible.  Many new technologies
from many companies are in the works which will assist in achieving
clean air goals set by the ARB.  Failure to implement this
regulation quickly will result in the 'status quo' air quality
improvement, which is not sufficient to reach the stated goals.