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Comment 74 for Informal Public Comments on the Proposed Advanced Clean Fleets Rulemaking (acf-comments-ws) - 1st Workshop.
First Name: Chris
Last Name: Hall
Email Address: chrishall@prodigy.net
Affiliation:
Subject: Backup Vehicle Exemption
Comment:
In the proposed changes to heavy vehicles, the discussion of backup vehicle exemptions included proposals to require snap tests every 6 months instead of annually. This fails to recognize that backup vehicle exemptions limit those trucks to being driven no more than 1000 miles per year. Thus a snap test every six months would require a test every 500 miles, or less than one tank of diesel fuel. This would put an undue hardship on the owners of these trucks due to the high cost of the snap tests on older trucks. In our case the tests are $160 per truck because we cannot drive them into Bakersfield since this would require 100 miles roundtrip, thereby greatly reducing the mileage the truck can be driven. Also, there is little liklehood that there would be significant reduction in emissions through increased monitoring due to the low mileage involved. The mileage limitation originally was imposed to accomplish two purposes: 1) Reduce the overall emissions from the trucks by greatly restricting their mileage. 2) Enable small businesses to continue using equipment that they could otherwise not afford to replace. Increasing the frequency of snap tests on these vehicles to every 6 months would put additional burdens on small business owners, driving them out of business. Chris Hall
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Date and Time Comment Was Submitted: 2021-10-11 16:18:06
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