Regarding 2449.1(f) Renewable Diesel
Requirements on page 84, are (dedicated and non-dedicated) snow
removal vehicles required to use Renewable Diesel? Also, are
non-snow removal diesel vehicles required to use Renewable Diesel
at high elevations in the winter? We have had major troubles
in the past with Renewable Diesel gelling in the winter at the
higher elevations during January 2017 (Caltrans Districts affected
include 2,3,9, and 10).
Multiple storage tanks and snow vehicles were rendered
inoperable as a result.
Another thing to keep in mind is that a diesel vehicle can
fill up with renewable diesel at a low elevation location and then
drive up to a freezing location. In this scenario, a driver can be left stranded
in an area with low cell reception or the vehicle may even become
inoperable on the roadway during a blizzard with low
visibility.
Regarding 2449(d)(9)(B) Compliance After the
Final Target Date on page 30, it states:
(B) Beginning January 1, 2024, for large and
medium fleets, and on January 1, 2028, for small fleets, fleets
must meet the Tier phase-out requirements in section 2449.1(c).
Vehicles exempt from BACT under sections 2449.1 (b)(2) and (3) are
not exempt from the Tier phase-out requirements in section 2449.1
(c). Beginning January 1 2024, all fleets must meet the renewable
diesel requirements in section 2449.1(f).
Are snow removal vehicles now subject to these
phase-out requirements? I think previously CARB mentioned
that snow removal vehicles would be exempt, correct?
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