Mr. Sunseri,

Per our discussion, I have compiled a list of ARB comments based on the Cummins West slides that were provided to me.

PLEASE NOTE THE FOLLOWING:

PORTABLE EQUIPMENT COMMENTS

1.            The title of the slide is incorrect.  There is no such thing as a “portable equipment ATCM”  The ATCM is for diesel engines only.  A better title for the slide would be “Portable Engine ATCM”

2.            The first sub-bullet states “Registration is currently required on all portable engines”.  This is untrue.  There are a few rural air districts that do not require a permit unless the engine is very large.  Most urban air districts only require permits for engines 50 bhp or greater.  This sub-bullet should say “Permits are required by air districts for most portable engines >50 bhp”

3.            The sub-bullet that states “Through PERP (state) or local air district” is misleading.   Registration in PERP is not required, ever.  It would be better to say “Option to register with PERP (state)”.

4.            The sub-bullet that states “After July 30, 2011 – no NEW registrations for engines that do not meet current tier” is inaccurate.  There are other ways to get an engine registered in PERP other than being current tier.  They are listed in section 14 of Form 2 and in question 16 of our Frequently Asked Questions (FAQ) document here:  http://www.arb.ca.gov/portable/perp/perpfaq.pdf

5.            There should be mention of the fact that if an engine is not eligible for PERP, the owner has the option to seek permits from the local air districts.

 OFF-ROAD EQUIPMENT REGULATION COMMENTS

For the bullet that outlines the adding vehicle requirements (it’s not completely incorrect, it’s just misleading). T0s and T1s are NOT currently banned. The bans cannot go into effect until we’ve received authorization to enforce the Off-road regulation from the U.S. EPA. Once we have that, we will begin (or rather shortly thereafter) enforcing the adding vehicle requirements.  

PUBLIC AGENCY RULE COMMENTS

The Group 4 date is incorrect. Fleets with a 2007 or newer engine that DOES NOT meet the .01g bhp engine standard have until Dec 31, 2012 to come into compliance (not 2011 as stated).

Because of the sensitivity of this matter, the comments are being sent to Cummins West and ARB will discuss the issue with them to avoid future misunderstandings.  If you or any member of your organization have comments or questions, please feel free to contact me at the number listed below.

Regards,
EZ

Eloy Florez, REA

California Air Resources Board

Air Pollution Specialist

MSCD-RIS

9480 Telstar Avenue, No. 1

El Monte, CA 91731

626.350.6525

626.575.6699