First Name | John |
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Last Name | Schuricht |
Email Address | jschuricht@anscv.com |
Affiliation | |
Subject | Light duty diesel smog inspections are only necessary for 2008 and new vehicles |
Comment | I support the idea of improving our air quality, however the current methods being put into place will destroy our economy. The ARB needs to step back and look at the bigger picture of how changes being made to policy will effect usage our natural resources and the economy. Many older light duty diesels on the road have had modifications performed that greatly improve their efficiency, reducing the amount of fuel used and by extension lessening the amount of exhaust gasses expelled. Under the new regulations these modifications will become illegal. For example, on a model year 2000 Ford light duty diesel truck utilizing a 7.3L Navistar diesel engine approximately 17mpg average was achieved on 500PPM low sulfur diesel fuel. With the switch to 15PPM ultra low sulfur diesel mpg dropped to an average of 14mpg. With slight changes to timing and fuel pressure fuel mileage was brought back up to 17mpg. Thus with the assumption of $3 per gallon and 35 gallons per fill-up, mileage per tank is reduced from 595 miles per tank to 490 miles per tank. And cost to the consumer has gone from $1,760 per 10,000 miles to $2,140 per 10,000 miles. With new regulations requiring inspections on older vehicles and CARB approval for all parts, cost to the consumer will increase by $380 per 10,000 miles just for fuel. This dose not take into account the money lost from the removal of the modifications, the extra 126 gallons of diesel fuel burned with exhaust gasses entering the atmosphere, and taxpayer money needed to run the new inspection programs. Diesel smog equipment has been mostly absent until the 2008 model year light duty diesel vehicles, and many pre 2008 light duty diesel vehicles were purchased with now illegal modifications already in place. Change should not be mandated to pre 2008 light duty diesel vehicle owners. These pre 2008 vehicles will slowly phase out due to age, there is no need to waist tax payer money going after such a small minority of vehicles, nor is there a need to waist these vehicle owner's money. New smog regulations should only be put into place for 2008 and newer model year light duty diesel vehicles that already have smog management equipment. The only possible outcome from smog checking pre 2008 light duty diesel vehicles is to further burden an already decremented economy. The tax payers will spend more on inspections, the owners will spend more on unnecessarily replacing equipment and more fossil fuels will be burned and put into the atmosphere. |
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Date and Time Comment Was Submitted | 2010-01-23 15:02:19 |
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