CALIFORNIA
AIR
RESOURCES
BOARD
Please
note
that
this
November
5,
1998
Board
meeting
was
recorded
in
two
parts
by
two
court
reporters.
Part
1
concludes
on
page
166
and
Part
2
begins
on
page
167
and
includes
its
own
Index.

PUBLIC
HEARING
TO
CONSIDER
THE
"
LEV
II"
)
AND
"
CAP
2000"
AMENDMENTS
TO
THE
)
CALIFORNIA
EXHAUST
AND
EVAPORATIVE
)
EMISSION
STANDARDS
AND
TEST
PROCEDURES
)
FOR
PASSENGER
CARS,
LIGHT­
DUTY
TRUCKS
)
98­
12­
1
AND
MEDIUM­
DUTY
VEHICLES,
AND
TO
THE
)
EVAPORATIVE
EMISSION
REQUIREMENTS
FOR
)
HEAVY­
DUTY
VEHICLES.
)
___________________________________________)

TRANSCRIPT
OF
PROCEEDINGS
November
5,
1998
9530
Telstar
Avenue
El
Monte,
California
REPORTED
BY:
Lynne
R.
Rutledge
CSR
No.
11091
Our
File
No.:
1­
49953
APPEARANCES
OF
BOARD
MEMBERS:

Chairman
Dunlap
Mr.
Calhoun
Supevisor
DeSaulnier
Ms.
Edgerton
Dr.
Friedman
Mr.
Parnell
Supervisor
Patrick
Ms.
Rakow
Ms.
Riordan
Supervisor
Roberts
Supervisor
Silva
INDEX
Proceedings
PAGE
Call
to
Order
1
Pledge
of
Allegiance
1
Roll
Call
1
Opening
Remarks
by
Chairman
Dunlap
2
AGENDA
ITEM:

98­
12­
1
Public
Hearing
to
Consider
the
"
LEV
II"
10
and
"
CAP
2000"
Amendments
to
the
California
Exhaust
and
Evaporative
Emission
Standards
and
Test
Procedures
for
Passenger
Cars,
Light­
Duty
Trucks
and
Medium­
Duty
Vehicles,
and
to
the
Evaporative
Emission
Requirements
for
Heavy­
Duty
Vehicles
Introductory
Remarks
by
Chairman
Dunlap
10
Staff
Presentation
Mike
Kenny
11
Annette
Guerrero
13
Jim
Schoning
40
Public
Coments
Kelly
Jensen
53
Vic
Weiser
60
Till
Stoeckenius
65
Kelly
Brown
72
Matt
Kevnick
87
Charlie
Kitz
93
Peter
Welch
99
Manuel
Cunha
105
Mike
Wade
110
Kevin
Cullen
114
Sam
Leonard
121
William
Innes
132
Barbara
Kiss
136
Greg
Dana
138
Wolfgang
Groth
142
Dick
Shaw
147
Andy
Frank
151
Bruce
Bertelsen
157
Roland
Hwang
166
1
CHAIRMAN
DUNLAP:
Will
the
November
meeting
2
of
the
California
Air
Resources
Board
please
come
to
3
order.
Will
the
audience
please
rise
and
join
the
Board
in
4
the
Pledge
of
Allegiance.

5
(
Pledge
recited.)

6
CHAIRMAN
DUNLAP:
Thank
you.
Ms.
Hutchins,

7
will
you
please
call
the
roles.
Ann,
will
you
please
call
8
the
role.

9
ANN:
Calhoun?

10
MR.
CALHOUN:
Here.

11
ANN:
DeSaulnier?

12
SUPERVISOR
DESAULNIER:
Here.

13
ANN:
Edgerton?

14
MS.
EDGERTON:
Here.

15
ANN:
Friedman?

16
DR.
FRIEDMAN:
Here.

17
ANN:
Parnell?

18
MR.
PARNELL:
Here.

19
ANN:
Patrick?

20
SUPERVISOR
PATRICK:
Here.

21
ANN:
Pat
Riordan?

22
MS.
RIORDAN:
Here.

23
ANN:
Roberts?

24
SUPERVISOR
ROBERTS:
Here.

25
ANN:
Silva?

1
1
SUPERVISOR
SILVA:
Here.

2
ANN:
Chairman
Dunlap?

3
CHAIRMAN
DUNLAP:
Here.

4
Thank
you.
What
I'd
like
to
do
prior
to
5
getting
into
our
sole
agenda
item
today
is
I
would
like
to
6
call
up
Firoz
Razul,
who
is
president
and
CEO
of
Ballard
­­

7
Firoz,
if
I
could
get
you
to
come
forward
­­
who
will
give
8
us
a
brief
presentation
but
will
also
present
a
fuel
cell
9
demonstrator
unit
to
the
Board.
I'm
pleased
to
have
Firoz
10
with
us.
He's
come
to
us
from
British
Columbia
His
11
company
is
very
important
to
us
in
the
technology
area.
So
12
welcome.

13
We
are
pleased
to
hear
what
you
have
to
say
14
this
morning.

15
FIROZ
RAZUL:
I'm
Firoz
Razul,
president
and
16
chief
executive
officer
of
Ballard
Power
Systems.

17
Mr.
Chairman,
Members
of
the
Air
Resources
18
Board,
it
is
a
pleasure
to
be
with
such
an
important
body
19
and
to
be
in
Southern
California
on
a
day
when
you
are
once
20
again
addressing
such
critical
issues
such
as
the
21
protection
of
our
environment
and
the
restoration
of
air
22
quality.
The
California
Air
Resources
Board,
under
the
23
leadership
of
John
Dunlap,
has
done
so
much
over
the
years
24
to
improve
air
quality
throughout
this
region.

25
But
more
than
this,
the
Air
Resources
Board,

2
1
through
its
actions,
has
had
a
profoundly
positive
impact
2
on
environmental
policy
throughout
North
America
and
the
3
world,
particularly
in
promoting
responsible
energy
4
technologies.
For
that,
we
all
owe
you
a
tremendous
debt
5
of
gratitude
and
we
will
for
years
to
come.

6
At
Ballard,
our
vision
is
the
power
to
7
change
the
world
with
the
support
of
our
strategic
8
partners
­­
the
Ford
Motor
Company,
Daimler
Benz
or
soon
9
Daimler
Chrysler.
The
Ballard
family
in
developing
fuel
10
cells
and
fuel
cell
applications
to
provide
clean,
quiet,

11
reliable,
and
efficient
power
for
a
number
of
markets.

12
Whether
you
drive
a
car
or
ride
a
bus
to
work,
fuel
cell
13
power
will
take
you
there.
When
you
turn
on
the
light
14
switch
in
your
kitchen
or
go
to
work
in
the
morning,
fuel
15
cells
will
provide
the
power
to
homes
and
hospitals,
office
16
buildings
and
factories.
If
you
need
power
for
your
camper
17
or
in
remote
parts
of
the
world,
fuel
cells
will
provide
18
it,
and
they
will
do
it
without
the
harmful
emissions
19
produced
by
traditional
combustion
agents.

20
The
Air
Resources
Board
has
led
the
way
in
21
promoting
fuel
cell
technology
not
just
by
talking
about
it
22
but
in
actively
working
to
educate
everyone
to
the
benefits
23
of
fuel
cells
and
other
clean
environmental
technologies.

24
As
an
expression
of
Ballard's
appreciation
for
your
25
efforts,
it
is
our
pleasure
to
deliver
to
you
and
the
3
1
citizens
of
California
a
100­
watt
Ballard
portable
2
fuel­
cell
generator.

3
Everyone
should
have
the
opportunity
to
4
learn
more
about
clean
energy
technologies,
and
we
know
how
5
much
the
Air
Resources
Board
is
looking
forward
to
using
a
6
fuel
cell
to
do
so.

7
We
are
proud
of
the
long
meaningful
8
relationship
that
Ballard
has
had
with
the
state
of
9
California.
We
are
proud
to
have
one
of
our
Ballard
family
10
members
DBB
Fuel
Cells
in
Poway,
California.
Several
years
11
ago,
the
South
Coast
Air
Quality
Management
District
12
provided
partial
funding
for
our
prototype
fuel
cell
13
busses.
And
soon
after,
California
gave
us
a
very
early
14
opportunity
to
demonstrate
that
fuel
cell
busses
can
and
15
will
be
the
clean
transportation
mode
for
our
cities.
And
16
today,
we
are
proud
to
join
California
in
showing
everyone
17
that
fuel
cells
are
not
only
the
power
of
the
future,

18
they're
today's
reality.

19
Last
month
Ballard
hosted
the
world's
first
20
round
table
discussion
on
fuel
cell
technology,
which
was
21
web
cast
live
on
the
internet
to
an
international
audience.

22
We
were
honored
to
be
joined
that
day
by
Secretary
Rooney
23
and
Lynne
Edgerton.
Like
all
of
you
true
champions
for
24
clean
energy
technology
including
fuel
cells,
during
that
25
meeting
Ms.
Edgerton
stated
and
I
quote,
"
I'm
confident
4
1
that
just
as
the
internal
combustion
engine
was
the
power
2
choice
for
the
20th
century,
fuel
cells
will
be
the
choice
3
for
the
21st
century."
Ms.
Edgerton,
we
couldn't
agree
4
more.
We
are
on
the
cusp
of
the
21st
century
today,
and
5
Ballard
is
ready
to
meet
that
challenge.

6
Ballard
thanks
you
Mr.
Chairman
for
7
permitting
us
to
be
a
part
of
your
legacy
here
at
the
Air
8
Resources
Board,
and
we
wish
you
every
success
in
the
9
future.
We
thank
every
member
of
the
Board
for
allowing
us
10
to
participate
in
your
legacy
as
one
of
the
most
11
influential
and
environmental
agencies
in
the
world.
And
12
we
thank
you
for
showing
the
people
of
California
that
fuel
13
cells
are
more
than
just
a
promise.
We
have
indeed
the
14
power
to
change
the
world.

15
Thank
you
very
much.

16
CHAIRMAN
DUNLAP:
Thank
you.
He's
going
to
17
give
us
a
fuel
cell
first
before
you
pepper
him.

18
Thank
you
very
much.
Thank
you,
and
we
19
appreciate
your
kind
words.
And
I
must
say,
as
I've
gotten
20
to
know
you
and
your
company,
I've
appreciated
the
fact
21
that
you've
devoted
some
time
to
educate
us
as
to
what
the
22
potential
is
worldwide
in
fuel
cells,
and
it
has
meant
a
23
lot
to
us
to
really
be
able
to
pull
for
technology
that
has
24
such
a,
we
believe,
great
potential.

25
So
with
that,
if
you're
willing,
can
we
ask
5
1
you
a
couple
questions?
I
know
Mr.
Parnell
and
Ms.

2
Edgerton
would
like
to
ask
you
a
few
things.

3
MR.
PARNELL:
I'm
just
wondering
in
view
of
4
trying
to
understand
practical
applications,
where
are
you
5
in
terms
of
having
fuel
cells
developed
and
ready
to
drop
6
into
a
vehicle
such
as
we
saw
out
front
today?
Could
you
7
expound
on
that
just
a
bit?

8
FIROZ
RAZUL:
Mr.
Parnell,
over
the
last
few
9
years,
we
have
been
working
to
develop
the
technology
to
10
demonstrate
that
it
has
the
performance
that
is
equivalent
11
or
better
than
existing
technology,
and
I
believe
Ballard
12
has
been
able
to
demonstrate
that.

13
The
challenge
today
for
us
is
to
maintain
14
that
performance
and
deliver
the
technology
at
a
lower
15
cost,
and
this
is
where
our
partnerships
with
the
Ford
16
Motor
Company
and
with
Dymler
Benz
or
Dymler
Chrysler
soon
17
has
been
very
important
in
helping
us
get
those
18
technologies
into
high­
volume
manufacturing
to
be
able
to
19
be
competitive
with
today's
technology.

20
So
over
the
next
few
years,
we
will
be
21
working
to
start
to
produce
the
technology
that
we
have
22
developed,
and
I'm
optimistic
it
will
be
in
many
different
23
applications
including
automobiles
and
busses
in
much
less
24
time
than
most
people
expect.

25
MR.
PARNELL:
Thank
you
very
much.

6
1
MS.
EDGERTON:
Thank
you.
Thank
you
so
much
2
for
all
your
contributions.
They
have
just
been
enormous
3
and
for
the
opportunity
to
participate
with
you,
I
thank
4
you
as
well.

5
Could
you
give
us
some
numbers
for
the
6
people
of
California
to
look
forward
to
in
terms
of
fuel
7
cell
vehicles,
light­
duty
vehicles
in
the
future,
and
can
8
you
give
us
some
dates
as
to
what
your
target
dates
are
for
9
seeing
significant
numbers
of
fuel
cell
vehicles
on
the
10
road
in
California?
I
don't
want
to
put
you
in
a
box.
I
11
don't
want
you
to
say
anything
you
don't
feel
comfortable
12
saying.
But
if
there
are
projections
that
you
can
make
13
that
can
be
then
reported
to
people
in
California,
I
think
14
it
would
be
very
exciting
for
them
to
hear.

15
FIROZ
RAZUL:
We
are
a
developer
of
a
16
component
which
is
a
very
important
part
of
the
power
17
system
of
the
future,
which
is
the
fuel
cell.

18
Our
objective
is
to
have
the
technology
19
ready
early
in
the
2000­
2001
time
frame
for
all
the
20
companies
to
then
start
to
integrate
those
into
design
and
21
integrate
those
into
their
vehicles.
And
the
design,
the
22
development
and
design
of
a
vehicle
varies
by
manufacturer.

23
It
can
be
as
low
as
three
or
four
years
or
as
high
as
seven
24
years.

25
And
from
that
point
in
time,
the
oil
7
1
companies,
once
they
are
comfortable
that
the
technology
2
works
to
their
satisfaction,
they
will
then
start
to
design
3
the
fuel
cell
into
their
vehicles.
So
exactly
when
they
4
decide
to
announce
a
car
with
the
fuel
cell,
I
think
is
5
really
both
a,
I'm
sure,
a
competitive
information
on
their
6
part
and
that's
a
decision
they
would
make.
That
would
not
7
be
a
decision
we
would
participate
in.
However,
our
8
objective
is
to
be
ready
for
them
to
make
their
decision
as
9
early
as
possible.

10
MS.
EDGERTON:
Is
it
correct
that
I've
seen
11
data
that
where
Ballard
is
discussing
100,000
fuel
cell
12
vehicles
on
the
road
around
2004?

13
FIROZ
RAZUL:
I
think
a
number
of
auto
14
companies
­­
there
are
about
six
auto
companies
today
that
15
have
made
some
sort
of
public
statement
that
they
intend
to
16
have
fuel
cell
vehicles
available
in
the
2004­
2005
time
17
frame.
I
think
the
numbers
vary.
One
of
our
projections
18
for
preparing
a
manufacturing
facility
for
this,
as
far
as
19
a
supplier
for
the
automotive
industry,
is
in
the
order
of
20
those
numbers.

21
But
I
think
that's
not
a
commitment
from
us.

22
Obviously,
we
don't
put
the
vehicles
on
the
road,
but
we
23
certainly
are
preparing
to
manufacture
in
the
quantities
of
24
between
100,000
and
250,000
ready
for
automotive
companies
25
to
be
able
to
use
the
technology
in
their
vehicles.

8
1
MS.
EDGERTON:
Let
me
follow
up
a
little
bit
2
because
it
is
relevant
to
this
hearing.
Today,
obviously,

3
we're
adopting
standards
that
would
apply
from
2004
on,

4
and
this
is
the
time
frame
in
which
you
envision
your
fuel
5
cells
being
very
increasingly
used
by
the
auto
companies
6
and
comprising
in
an
increasing
number
of
vehicles
on
the
7
road.

8
With
respect
to
larger
vehicles
such
as
9
sports
utility
vehicles,
would
you
envision
your
fuel
cell
10
as
being
able
to
power
them
and
at
very
low
emissions,
near
11
zero
emissions?

12
FIROZ
RAZUL:
The
fuel
cell
is
a
modular
13
power
source.
As
you
are
aware,
we
have
busses
today
14
running
on
fuel
cells
as
we
have
in
the
city
of
Chicago
and
15
Vancouver.
So
the
size
is
not
an
issue.
It
is
a
question
16
of
the
models
that
the
auto
companies
decide
to
introduce
17
fuel
cells
in
first.
I
think
that's
a
decision
we
haven't
18
heard
what
vehicles
they've
selected
yet.
We
will
19
certainly
be
prepared
to
put
a
fuel
cell
in
any
size
20
vehicle.

21
MS.
EDGERTON:
So
there
is
nothing
to
22
preclude
the
auto
companies
from
running
sports
utility
23
vehicles
on
fuel
cells,
selling
them
at
the
same
price
in
24
that
time
frame?

25
FIROZ
RAZUL:
I
can
only
speak
about
the
9
1
technology,
and
certainly
we
expect
the
technology
to
be
2
ready.
I
think
when
and
how
they
introduce
the
vehicles,

3
as
I
said,
is
not
in
our
control.

4
MS.
EDGERTON:
Thank
you.

5
CHAIRMAN
DUNLAP:
Are
we
done
peppering
our
6
friend
and
colleague?
Thank
you
very
much.
I
appreciate
7
your
time.
I
look
forward
to
keeping
abreast
in
your
8
progress.

9
All
right.
I'd
like
to
acknowledge
we
have
10
been
joined
by,
I
think,
one
or
two
other
are
Board
11
members;
so
we
have
our
entire
Board
here
today.

12
Let's
move
into
our
sole
agenda
item
13
98­
12­
1.
It's
a
public
hearing
to
consider
the
"
LEV
II"

14
and
"
CAP
2000"
amendments
to
the
California
exhaust
and
15
evaporative
emission
standards
and
test
procedures
for
16
passenger
cars,
light­
duty
trucks,
and
medium­
duty
vehicles
17
and
to
the
evaporative
emission
requirements
for
heavy­
duty
18
vehicles.

19
The
proposal
today
is
regarded
as
one
of
the
20
most
significant
mobile
source
items
for
Board
21
consideration
this
year.
The
proposed
LEV
II
amendments
22
target
emission
reductions
from
light­
duty
vehicles
as
23
required
under
the
state
implementation
plan
for
ozone
24
attainment.
These
amendments
modify
the
low­
emission
25
vehicle
program
initially
adopted
by
this
Board
in
1990.

10
1
Also
proposed
are
CAP
2000
amendments
to
modify
motor
2
vehicle
certification
and
in­
use
compliance
requirements.

3
At
this
point,
I
would
like
to
ask
Mr.
Kenny
4
to
introduce
the
item
and
begin
the
staff's
presentation.

5
Mike?

6
MR.
KENNY:
Thank
you,
Mr.
Chairman
and
7
Members
of
the
Board.
Good
morning.

8
The
primary
impetus
for
the
proposed
9
amendments
comes
from
the
ARB's
obligation
under
the
state
10
implementation
plan
adopted
by
the
Board
in
1994.
State
11
implementation
plan
contains
mobile
source
Measure
M2
which
12
calls
for
the
adoption
of
technology
based
control
13
strategies
for
light­
duty
vehicles
beginning
with
the
2004
14
model
year.

15
The
plan
specifies
for
this
measure
and
16
emission
reduction
of
25
tons
per
day
of
reactive
organic
17
gases
plus
oxides
of
nitrogen
in
the
South
Coast
Air
Basin
18
in
2010.
In
addition
to
Measure
M2,
SIP
recognizes
that
19
the
greater
Los
Angeles
area,
designated
as
extreme
ozone
20
non­
attainment,
may
need
to
rely
on
the
development
of
21
further
technology
measures
to
meet
an
additional
75
tons
22
per
day
of
reactive
organic
gases
plus
oxides
of
nitrogen
23
emission
reduction.

24
This
has
been
commonly
referred
to
in
the
25
past
as
our
black
box.
The
proposed
amendments
are
11
1
intended
to
achieve
emission
reduction
targets
of
M2
and
2
over
two­
fifths
of
the
emission
reductions
in
that
black
3
box.
The
proposed
LEV
II
amendments
are
a
comprehensive
4
set
of
modifications.
They
include
the
application
of
5
passenger
car
exhaust
emission
standards
to
most
sport
6
utility
vehicles,
pickup
trucks
and
minivans;
and
lower
7
exhaust
standards
for
all
light­
duty
vehicles.

8
Other
amendments
include
evaporative
9
emission
standards,
more
stringent
requirements
for
the
10
phase­
in
of
cleaner
vehicles,
additional
mechanisms
for
the
11
generation
of
zero­
emission
vehicle
credits,
and
numerous
12
technical
modifications.
Also
proposed
are
CAP
2000
13
amendments
that
consist
of
streamlining
the
current
motor
14
vehicle
certification
requirements
while
strengthening
the
15
in­
use
compliance
requirements.

16
Extensive
research
and
test
programs
were
17
conducted
to
determine
the
technological
feasibility
of
the
18
proposed
LEV
II
exhaust
and
evaporative
emission
19
standards.
These
involved
over
4,000
hours
of
testing
20
time.
The
results
of
staff's
testing
indicate
that
the
21
LEV
II
standards
are
technologically
feasible.
The
22
estimated
emission
benefits
for
the
proposed
adoption
of
23
these
standards
are
51
tons
per
day
oxides
of
nitrogen
and
24
6
tons
per
day
of
reactive
organic
gases
in
the
South
Coast
25
Air
Basin
by
2010.

12
1
The
estimated
cost
effectiveness
of
the
2
staff's
proposal
averages
approximately
$
1
per
pound
of
3
pollutant
reduced.
Annette
Guerrero
of
the
LEV
II
team
4
will
now
provide
the
background
for
the
staff's
proposal
5
and
present
staff's
recommendation
for
the
Board's
action.

6
Annette?

7
ANNETTE
GUERRERO:
Could
I
have
someone
dim
8
the
lights,
please.
Thanks.

9
Thank
you,
Mr.
Kenny.
Good
morning,

10
Chairman
Dunlap
and
Members
of
the
Board.
Welcome
to
our
11
mobile
source
test
facility
here
in
El
Monte.

12
Today
I
will
be
presenting
staff's
proposed
13
revisions
to
California's
low
emission
vehicle
program.
As
14
mentioned
in
the
opening
remarks,
the
proposal
before
you
15
today
is
one
of
the
most
significant
mobile
source
items
16
for
Board
consideration
this
year.
It
achieves
large
17
emission
reductions
and
implements
on
schedule
Measure
M2
18
of
the
SIP.
It
is
also
probably
the
most
complex
as
it
19
affects
every
mobile
source
regulation.
In
our
20
presentation
today,
I
will
describe
for
you
the
key
21
elements
of
our
proposal.

22
I'll
start
with
some
brief
background
and
23
some
review
of
the
regulations,
present
the
key
elements
of
24
the
emission
proposal,
present
the
results
of
our
25
technological
feasibility
and
cost
analysis,
and
summarize
13
1
the
environmental
impact
and
cost
effectiveness
of
LEV
II.

2
And
lastly,
I'll
explain
some
of
the
outstanding
issues.

3
To
begin,
I'd
like
to
give
you
some
4
background
and
some
review
of
the
current
regulations.

5
As
Mr.
Kenny
mentioned
in
his
opening
6
remarks,
the
primary
impetus
for
this
Board
item
comes
from
7
mobile
source
Measure
M2
of
the
SIP,
in
which
the
Board
8
committed
to
reduce
reactive
organic
gas
or
ROG,
plus
9
oxides
of
nitrogen
(
NOx)
emissions
by
25
tons
per
day
in
10
the
South
Coast
Air
Basin.
This
green
box
here.

11
The
SIP
also
requires
us
to
make
significant
12
progress
in
reducing
emissions
by
another
75
tons
per
day.

13
This
is
the
so­
called
black
box.
As
I
will
demonstrate
14
later,
the
proposed
LEV
II
amendments
are
expected
to
15
achieve
the
NOx
emission
reduction
goals
of
Measure
M2
and
16
also
provide
significant
NOx
emission
reductions
which
will
17
further
shrink
the
black
box.
In
addition
to
the
18
reductions
to
the
South
Coast
Air
Basin,
this
proposal
19
would
also
achieve
needed
statewide
emission
reductions
for
20
NOx,
carbon
monoxide,
and
also
fine
particulate
matter.

21
Today's
proposal
is
an
evolution
of
the
22
original
Low­
Emission
Vehicle,
or
LEV
I
Program,
that
was
23
adopted
by
you
in
1990.
The
key
elements
of
California's
24
LEV
Program
include
the
introduction
of
four
increasingly
25
stringent
emission
categories
­­
transitional
low­
emission
14
1
vehicle
or
TLEV,
low­
emission
vehicle
or
LEV,
ultra­
low
2
emission
vehicle
or
ULEV,
and
finally
zero
emission
vehicle
3
or
ZEF.

4
In
addition,
considerable
compliance
5
flexibility
is
built
into
the
program
for
the
introduction
6
of
low­
emission
vehicles.
A
manufacturer
may
choose
which
7
portion
of
its
fleet
is
certified
to
each
of
these
8
standards
as
long
as
the
average
hydrocarbon
exhaust
9
emissions
of
its
entire
fleet
meets
a
fleet
average
10
requirement.
The
only
required
percent
phase
in
is
that
11
10
percent
of
the
fleet
must
be
certified
as
ZEVs
in
2003.

12
The
original
LEV
Program
has
completed
its
13
fourth
model
year
of
implementation,
is
on
schedule,
and
14
meeting
emission
reduction
and
cost
targets.
Currently,
43
15
percent
of
the
'
98
model
year
vehicles
are
certified
as
16
TLEVs,
another
26
percent
of
the
fleet
is
certified
as
17
LEVS,
and
Honda
introduced
the
first
gasoline
powered
ULEV
18
this
past
model
year
as
well.
The
LEV
I
Program
will
be
19
fully
implemented
by
2003.

20
The
original
enhanced
evaporative
21
regulations
were
also
adopted
by
the
Board
in
1990.

22
Evaporative
emissions
are
hydrocarbon
vapors
that
escape
23
mainly
from
the
vehicle
fuel
and
evaporative
control
system
24
into
the
atmosphere
and
can
originate
from
the
on­
board
25
canister,
permeation
through
hoses,
joints,
and
plastic
15
1
fuel
tanks,
and
other
sources.
The
enhanced
regulations
2
require
that
motor
vehicles
be
designed
to
more
effectively
3
control
the
three
types
of
fuel
evaporative
emissions
­­

4
diurnal,
hot
soak,
and
running
loss.

5
Diurnal
emissions
occur
when
a
vehicle
is
6
parked
and
are
caused
by
daily
ambient
temperature
changes.

7
Hot
soak
emissions
occur
immediately
after
a
8
fully
warmed­
up
vehicle
is
stationary
with
the
engine
9
turned
off
and
are
due
to
high
under
hood
temperatures.

10
Running
loss
emissions
occur
when
the
fuel
11
heats
up
during
driving
and
can
originate
from
numerous
12
sources.

13
Staff
will
only
be
proposing
modifications
14
to
the
diurnal
plus
hot­
soak
emission
standards
in
the
15
evaporative
proposal
today.

16
With
that
brief
background,
I
will
now
17
explain
the
key
exhaust
and
evaporative
elements
of
the
18
LEV
II
proposal,
beginning
with
exhaust
and
followed
by
the
19
evap
proposal.

20
Staff
is
proposing
three
major
modifications
21
to
the
LEV
tailpipe
regulations.
The
first
is
a
22
requirement
that
sport
utility
vehicles,
pickup
trucks,
and
23
minivans
meet
the
same
emission
standard
as
cars.
The
24
second
is
lower
tailpipe
standards
for
all
light­
and
25
medium­
duty
vehicles.
The
third
provides
partial
ZEF
16
1
credits
for
near­
zero
emitting
vehicles.

2
Perhaps
the
most
defining
element
of
LEV
II
3
is
the
proposal
that
sport
utility
vehicles,
pickup
trucks,

4
and
minivans
be
required
to
meet
the
same
emission
5
standards
as
cars.
The
current
trend
toward
the
use
of
the
6
sport
utility
vehicles
and
pickup
trucks
for
personal
7
transportation,
coupled
with
their
ever­
increasing
8
popularity
representing
nearly
half
of
new
vehicle
sales,

9
has
greatly
altered
the
usage
patterns
of
this
vehicle
10
segment
and
increased
their
impact
on
air
quality.
It
is
11
now
the
norm
for
these
vehicles
to
be
used
for
personal
12
transportation.

13
However,
under
current
regulations,
these
14
vehicles
have
separate,
less
stringent
emission
standards
15
because
they
have
been
traditionally
used
for
work
purposes
16
and
had
more
rigorous
duty
cycles.
This
trend
has
a
17
substantial
impact
on
air
quality
because,
although
these
18
vehicles
are
used
as
passenger
cars,
SUVs
and
light
trucks
19
emit
one­
and­
a­
half
to
two­
and­
a­
half
times
the
emissions
20
per
mile
as
a
passenger
car,
as
you
can
see
from
this
21
chart.

22
The
medium­
light
trucks
in
the
red
bar
of
23
this
chart
include
the
Jeep
Grand
Cherokee,
the
Chevy
24
Blazer,
Ford
Explorer,
and
all
minivans.
The
vehicles
25
included
in
the
bar
on
the
right­
hand
side
of
the
chart
are
17
1
the
Ford
F150
pickup
truck,
the
Ford
Expedition,
the
Dodge
2
Ram
1500
pickup
truck,
and
the
Chevy
Suburban.

3
For
this
reason,
staff
is
proposing
that
4
most
trucks
included
in
this
chart
­­
that
is,
trucks
under
5
8,500
pounds
gross
vehicle
weight
­­
be
subject
to
the
same
6
emission
standards
as
cars.

7
The
second
element
of
the
LEV
II
proposal
is
8
lower
emission
standards
and
increased
durability
9
requirements
for
passenger
cars
and
light
trucks.
Some
of
10
the
new
standards
in
the
LEV
II
proposal
are
listed
in
this
11
table
in
green.
Two
of
the
more
important
standards
staff
12
is
proposing
include
a
75­
percent
reduction
in
NOx
for
LEVs
13
and
ULEVs
to
.05
grams
per
mile,
and
a
new
emission
14
category,
super
ultra
low­
emission
vehicle
or
SULEV.

15
All
of
these
emission
categories
include
16
increased
durability
requirements
to
120,000
miles
or,

17
optionally,
150,000
miles.
You'll
notice
that
staff
is
18
proposing
to
retain
the
current
TLEV
standards
to
allow
19
manufacturers
additional
flexibility
for
their
more
20
difficult
to
control
vehicles.
Diesel
vehicles
would
21
likely
certify
to
the
TLEV
standard.
Because
the
new
SULEV
22
category
contains
some
additional
features,
I'll
discuss
23
that
later
in
the
presentation.
Also
not
listed
on
this
24
table
are
the
special
standards
being
proposed
for
25
medium­
duty
work
trucks
under
8,500
pounds
GVW.

18
1
Another
element
of
the
LEV
II
exhaust
2
proposal
is
the
new
flexible
implementation
schedule
where
3
a
manufacturer
can
choose
the
standards
category
to
which
a
4
vehicle
may
certify
as
long
as
the
emissions
of
their
5
entire
product
line
meet
a
fleet
average
NMOG
requirement.

6
In
other
words,
as
long
as
the
manufacturer
meets
the
two
7
curves
on
this
chart,
it
can
tailor
its
implementation
to
8
its
own
product
schedule.
As
you
can
see
from
this
chart,

9
the
fleet
average
and
NMOG
requirement
would
decline
from
10
LEV
I
levels
in
2003
through
2010.

11
There
are
two
separate
curves
because
the
12
ZEF
requirement
is
linked
only
to
passenger
cars
and
the
13
lightest
trucks.
The
second
less
stringent
curve
has
been
14
established
for
heavier
light
trucks
and
sport
utility
15
vehicles
because
zero­
emission
vehicles
are
not
required
in
16
this
class.

17
There
are
several
other
compliance
18
flexibility
options
available
to
a
manufacturer
when
19
implementing
LEV
II.
For
example,
fleet
average
credit
20
trading
is
allowed
between
passenger
cars
and
light
trucks.

21
In
addition,
manufacturers
may
continue
to
sell
LEV
I
22
vehicles
through
the
2006
model
year.
Truck
models
used
23
principally
for
work
are
provided
with
a
less
stringent
24
tailpipe
standard,
and
an
optional
TLEV
standard
is
25
provided
which
recognizes
the
low­
emission
deterioration
19
1
rates
of
diesel
engines.

2
The
first
element
of
the
evaporative
3
proposal
is
lower
emission
standards.
The
proposed
4
standards
represent
a
50­
to
75­
percent
reduction
from
5
current
standards,
depending
on
vehicle
category.
Today,

6
using
certification
data,
approximately
20
percent
of
the
7
'
99
model
year
cars
have
certified
evaporative
emission
8
levels
lower
than
the
staff's
proposed
standards.
For
9
example,
one
of
the
largest
vehicles,
the
Chevy
Suburban,

10
can
already
comply
with
the
proposed
standards
in
its
11
category.

12
The
second
element
is
the
increased
13
durability
requirement
from
10
years
or
100,000
miles
to
15
14
years
or
150,000
miles.
We
are
proposing
this
because
15
there
are
concerns
that
significant
evaporative
emission
16
deterioration
may
occur
for
vehicles
more
than
10
years
17
old.
Current
data
show
that
more
than
20
percent
of
the
18
California
vehicle
fleet
is
between
10
and
15
years
old.

19
The
proposal
would
require
manufacturers
to
demonstrate
20
that
the
evaporative
emission
components
remain
durable
as
21
the
vehicles
become
old.

22
The
last
element
of
the
evaporative
proposal
23
is
the
implementation
schedule.
The
proposed
24
implementation
schedule
is
phased
in
over
three
years,

25
starting
in
the
2004
model
year.
In
the
first
year,
40
20
1
percent
of
the
manufacturer's
vehicle
fleet
would
be
2
required
to
comply
with
the
proposed
evaporative
standard
3
with
100­
percent
compliance
being
required
by
the
2006
4
model
year.
At
the
manufacturers'
request,
an
optional
5
alternative
phase­
in
schedule
has
been
added
to
allow
6
compliance
flexibility
to
a
manufacturer.

7
I'll
move
now
to
the
next
section
of
our
8
presentation,
which
covers
the
technological
feasibility
of
9
the
standards.
First
I'll
discuss
the
tailpipe,
followed
10
again
by
the
evap.

11
With
industry
generally
conceding
that
the
12
proposed
tailpipe
standards
can
be
met
by
passenger
cars
13
and
the
lightest
trucks,
staff
focused
its
resources
on
14
demonstrating
that
the
proposed
standards
are
feasible
for
15
sport
utility
vehicles
and
heavier
trucks.
Staff
used
the
16
lowest
emitting
vehicle
currently
available
in
this
sector,

17
the
Ford
Expedition.

18
Staff
installed
advanced
catalyst
systems
19
with
air
injection
on
several
Expeditions
that
were
20
obtained
from
catalyst
suppliers,
such
as
the
one
shown
21
here.
The
catalysts
were
aged
to
simulate
50,000
miles
of
22
use,
using
the
procedure
that
Ford
uses
to
ensure
that
even
23
work
trucks
that
are
loaded
with
cargo
or
used
for
towing
24
will
comply
with
emission
standards
in
use.
It's
also
25
important
to
note
that
testing
was
conducted
using
21
1
California
Phase
II
cleaner
burning
gasoline
to
demonstrate
2
the
feasibility
of
the
proposed
standards.

3
Staff
was
able
to
conduct
seven
tests
using
4
these
advanced
catalysts
which
demonstrate
that
the
Ford
5
Expedition
can
meet
the
proposed
LEV
II
standards.
The
6
average
of
the
seven
tests
is
compared
to
the
proposed
7
LEV
II
standard
in
this
slide.
Staff
could
not
modify
8
vehicle
software
so
that
the
computer
control
of
the
fuel
9
and
air
matched
the
characteristics
of
the
advanced
10
catalysts.
Manufacturers
will
have
over
five
years
to
11
perform
this
optimization,
and
we
believe
this
will
result
12
in
emissions
well
below
the
LEV
II
standards.

13
This
list
identifies
some
of
the
available
14
technologies
that
could
be
used
by
industry
to
lower
15
emissions
further.
They
include
use
of
individual
cylinder
16
fuel
control,
retarded
spark
timing
at
startup,
hydrocarbon
17
traps,
and
many
others
shown.
Many
of
these
are
now
in
use
18
on
selected
models.

19
Based
on
our
test
results,
staff
concludes
20
that
the
proposed
standards
are
feasible.
This
is
21
especially
true
given
what
expert
automotive
engineers
can
22
achieve
given
their
available
resources
and
experience
and
23
given
that
more
than
five
years'
lead
time
remains
before
24
implementation
begins.
The
flexible
phase­
in
provisions
we
25
have
provided
provide
eight
years
before
the
more
difficult
22
1
to
control
models
must
comply.
Based
on
their
successful
2
track
record
and
meeting
the
tough
standards
this
Board
has
3
adopted,
we
have
no
doubt
the
auto
manufacturers
will
be
4
able
to
comply.

5
Also,
as
a
historical
note,
automobile
6
manufacturers
testified
they
were
uncertain
they
could
meet
7
the
LEV
or
ULEV
standards
when
adopted
by
the
Board
in
8
1990;
yet
today,
ULEV
compliant
models
are
being
sold
in
9
California.

10
Turning
now
to
the
proposed
evap
standards,

11
feasibility
was
demonstrated
by
vehicle
modification
and
12
testing
by
ARB
staff
and
through
information
and
data
13
gathered
from
automotive
manufacturers.
The
ARB
test
14
programs
involved
more
than
testing
of
20
vehicles.
Shown
15
here
is
a
vehicle
placed
in
our
evaporative
test
facility
16
enclosure
which
is
located
directly
behind
the
back
wall
of
17
this
room.

18
When
a
vehicle
is
tested,
the
enclosure
is
19
completely
sealed
so
that
the
evaporative
test
is
conducted
20
on
the
whole
vehicle.
This
is
important
to
note
because
21
the
measured
evaporative
emissions
include
both
non­
fuel
22
and
fuel
emissions.
Examples
of
non­
fuel
sources
include
23
paint,
sealants,
interior
trim,
adhesives,
and
tires;
while
24
fuel
evaporative
emissions
result
from
canister
losses
and
25
the
permeation
of
hydrocarbon
vapors
through
fuel
hoses,

23
1
joints,
and
plastic
fuel
tanks.

2
One
of
our
test
programs
was
conducted
to
3
investigate
potential
methods
of
reducing
evaporative
4
emissions
from
fuel
sources.
Total
vehicle
evaporative
5
emissions
were
reduced
to
.3
grams
per
test
on
average,

6
well
below
the
proposed
passenger
car
standard
of
.5
grams
7
per
test.
The
average
fuel
and
non­
fuel
evaporative
8
emissions
were
estimated
to
be
.1
and
.2
respectively.
As
9
you
can
see,
the
non­
fuel
emissions
are
a
substantial
10
portion
of
the
whole
vehicle
evaporative
emissions.
Thus,

11
appropriate
allowances
in
the
proposed
standards
are
12
provided
for
these
emissions.

13
I
would
like
to
note
that
the
modification
14
made
on
the
vehicles
to
reduce
the
evaporative
emissions
15
were
not
production­
intended;
however,
they
are
analogous
16
to
modifications
that
can
be
used
by
manufacturers
on
17
production
vehicles.
For
example,
while
our
fuel
hoses
18
were
wrapped
to
reduce
permeation
vapors
in
the
test
19
program,
manufacturers
could
use
low­
permeation
hoses
or
20
reduce
the
length
of
the
hoses
to
meet
the
standards.

21
To
further
illustrate
the
viability
of
fuel
22
source
emission
reductions,
a
'
98
Toyota
Camry
was
modified
23
with
production
low­
permeation
fuel
hoses,
better
sealing
24
hose
connections,
and
a
low­
permeation
fuel
pump
gasket.

25
Other
modifications
included
the
addition
of
a
hydrocarbon
24
1
filter
to
capture
engine
breathing
losses
and
a
better
2
sealed
fuel
cap.
With
these
evaporative
system
3
improvements,
the
vehicle
tested
at
.23
grams
per
test.

4
This
is
less
than
half
the
proposed
standard.

5
Beside
the
improved
technologies
used
in
the
6
Camry
study,
staff
has
also
identified
a
number
of
other
7
improvements
to
the
fuel
and
evaporative
systems
that
can
8
be
used
to
reduce
evaportive
emissions.
Many
of
these
9
potential
technologies
are
already
being
used
in
production
10
vehicles
today,
although
they
may
not
be
used
concurrently
11
on
the
same
vehicle
to
achieve
the
lowest
possible
12
evaporative
emission
levels
as
a
system.
The
types
of
13
technologies
include
improvements
aimed
at
reducing
14
permeation
emissions
from
the
fuel
tank,
evaporative
losses
15
from
the
canister,
and
design
modifications
to
reduce
the
16
number
of
permeation
sources.

17
Although
the
evaporative
feasibility
18
demonstration
as
published
in
the
staff
report
is
19
considerably
robust,
manufacturers
continue
to
have
20
concerns
regarding
the
evaporative
data
used
to
set
the
21
stringency
level
of
the
proposed
standards.
To
address
22
these
concerns,
staff
conducted
additional
testing
after
23
the
publication
of
the
staff
report.

24
First,
the
Toyota
Camry
study
was
conducted
25
to
address
industry's
concern
that
we
did
not
use
25
1
production­
type
components
to
demonstrate
feasibility.
In
2
that
study,
staff
used
production
improvements
to
reduce
3
the
evaporative
emissions,
and
the
vehicle
evaporative
4
emissions
were
reduced
sufficiently
to
comply
with
the
5
proposed
standard
with
headroom.

6
A
second
industry
concern
was
that
there
was
7
insufficient
non­
fuel
data
to
represent
the
different
8
vehicle
models.
As
mentioned
earlier,
non­
fuel
emissions
9
result
from
paint,
interior
trim,
adhesives,
and
tires.

10
Since
non­
fuel
emissions
are
measured
as
part
of
the
whole
11
vehicle
evaporative
emissions,
an
allowance
in
the
proposed
12
standard
is
given
for
these
emissions.
Staff
tested
six
13
additional
vehicles,
and
the
test
results
were
consistent
14
with
the
existing
data­
set.
Including
industry
15
information,
the
non­
fuel
emission
data­
set
covered
21
16
vehicle
models
and
was
used
to
ensure
adequate
non­
fuel
17
allowance
in
the
proposed
standards.

18
Finally,
industry
continued
to
comment
that
19
the
evaporative
emission
variability
is
so
high
that
it's
20
difficult
to
duplicate
emission
results
from
one
vehicle
to
21
another.
In
response,
five
Toyota
Corollas
were
recently
22
brought
in
for
testing.
The
Corolla
model
was
chosen
23
because
it
already
complies
with
the
proposed
standard.

24
The
test
results
showed
that
variability
from
vehicle
to
25
vehicle
was
relatively
low,
and
the
headroom
allowed
in
the
26
1
proposed
standard
more
than
sufficiently
accounts
for
this
2
variability.
This
and
previously
described
test
programs
3
demonstrated
that
the
proposed
evaporative
standards
are
4
technologically
feasible,
especially
given
the
lead
time
of
5
more
than
five
years.

6
I'd
now
like
to
discuss
some
of
the
special
7
features
of
our
proposed
SULEV
standard.
In
the
past
few
8
years,
the
ZEF
requirement
has
been
successful
in
spawning
9
a
large
variety
of
extremely
low­
emission
vehicle
10
technologies
that
are
capable
of
achieving
emissions
very
11
close
to
the
power
plant
emissions
that
occur
from
charging
12
battery­
powered
electric
vehicles.

13
Staff
believes
that
allowing
these
14
exceptionally
clean
vehicles
to
fulfill
a
portion
of
the
15
ZEF
requirement
would
promote
the
continued
development
and
16
commercialization
of
high­
performance,
battery­
powered
17
electric
and
zero­
emitting
fuel
cell
vehicles
while
also
18
encouraging
advanced
technology
vehicles
with
the
potential
19
for
extremely
low­
emission
performance.

20
For
this
reason,
staff
is
proposing
that
21
SULEVs
that
meet
certain
additional
criteria
would
be
22
eligible
to
receive
a
partial
ZEF
allowance.
The
proposal
23
before
you
today
provides
additional
flexibility
to
vehicle
24
manufacturers
in
meeting
the
ZEF
requirements
and
will
also
25
encourage
development
of
a
variety
of
near
zero­
emission
27
1
technologies.
It
is
important
to
note,
however,
that
staff
2
is
not
proposing
any
revisions
to
the
10­
percent
ZEF
3
requirement.

4
In
order
to
receive
a
partial
ZEF
allowance,

5
a
manufacturer
must
meet
a
rigorous
set
of
criteria
which
6
are
predicated
on
achieving
equivalent
emission
performance
7
to
a
zero­
emitting
vehicle.
Here
are
some
examples
of
how
8
the
calculation
works.
In
the
first
row,
the
gasoline
9
powered
SULEV
that
meets
OBD,
warranty,
and
emission
10
standards
at
150,000
miles
and
has
zero­
evaporative
11
emissions
but
with
no
zero­
emission
vehicle
range
would
12
receive
a
partial
ZEF
allowance
of
.2.

13
A
natural
gas
SULEV
meeting
the
same
14
baseline
requirements
would
receive
an
allowance
of
.4
15
because
it
uses
a
cleaner
fuel.

16
The
gasoline
hybrid
SULEV
with
a
20
mile
17
all­
electric
range
capable
of
off­
vehicle
recharging
would
18
receive
a
partial
ZEF
allowance
of
.6.

19
A
fuel
cell
vehicle
with
an
on­
board
20
methanol
reformer
which
has
no
NOx
emissions
could
receive
21
a
ZEV
allowance
of
.7,
while
a
stored
hydrogen
fuel
cell
22
vehicle
which
is
emission
free
could
be
eligible
for
the
23
full
partial
ZEF
allowance
of
1.

24
Finally,
even
though
I've
highlighted
the
25
key
elements
of
LEV
II,
there
are
several
technical
28
1
amendments
worthy
of
note.
Staff
has
worked
extensively
2
with
industry
to
achieve
consensus
on
these
items.
The
3
amendments
include
a
substantial
streamlining
of
the
motor
4
vehicle
certification
process
which
reduces
the
5
manufacturer's
cost
of
compliance,
a
face
lift
to
the
smog
6
index
label,
protocol
for
vehicles
utilizing
direct
ozone
7
reduction
technologies,
and
updates
to
the
test
procedures
8
for
ZEVs
and
hybrid
electric
vehicles.

9
One
of
the
more
unique
modifications
10
concerns
the
protocol
for
direct
ozone
reduction
11
technologies.
Staff
is
proposing
to
grant
credits
to
12
vehicles
equipped
with
technologies
that
directly
eliminate
13
atmospheric
ozones.
One
such
technology
that
would
qualify
14
for
credits
consists
of
a
catalyst
coating
applied
to
the
15
vehicle
radiator
­­
this
so­
called
"
smog­
eating
radiator"

16
Premair.
Under
the
proposed
protocol,
a
vehicle
system
17
that
is
shown
to
effectively
reduce
atmospheric
ozone,
is
18
durable,
and
can
be
monitored
by
the
on­
board
diagnostic
19
system
would
be
eligible
to
receive
credit
towards
meeting
20
the
hydrocarbon
emission
standards.

21
Now
that
I've
discussed
the
technological
22
feasibility,
I'd
like
to
talk
about
the
results
of
our
cost
23
analysis.
Our
analysis
includes
our
estimate
of
the
24
incremental
retail
cost
per
vehicle
of
the
ULEV
II
exhaust
25
standards,
the
cost
per
vehicle
of
the
evaporative
29
1
proposal,
and
finally
the
cost
savings
for
CAP
2000.

2
Staff's
cost
methodology
is
the
same
as
used
3
in
other
recent
rule
makings
and
includes
variable,

4
support,
investment,
and
dealership
costs.
Based
on
5
staff's
analysis,
the
average
incremental
cost
of
the
ULEV
6
II
compared
to
a
ULEV
I
ranges
from
$
71
for
passenger
cars
7
to
$
209
for
a
light
heavy­
duty
truck
just
under
8,500
8
pounds
GVW.
Staff
focused
on
the
incremental
cost
of
a
9
ULEV
because
we
anticipate
that
declining
fleet
average
10
requirements
will
call
for
nearly
all
vehicles
to
be
ULEVs
11
by
2010.

12
Comparisons
of
1990
estimates
for
the
LEV
I
13
program
with
actual
costs
for
a
1998
model
complying
with
14
the
LEV
II
standard
has
shown
our
cost
estimation
15
methodology
to
be
reliable.

16
This
same
cost
methodology
was
used
to
17
determine
the
cost
of
compliance
of
the
evaporative
18
standards.
The
retail
cost
for
evaporative
standards
is
19
estimated
to
be
$
25
per
vehicle.

20
Although
I
have
only
briefly
mentioned
this
21
proposal
early
in
the
presentation,
it
is
worthy
of
note
at
22
this
time
because
of
the
potential
cost
savings
to
23
manufacturers.
Staff
has
been
working
closely
with
US
EPA
24
and
the
automotive
industry
to
develop
a
streamlined
motor
25
vehicle
certification
process
coupled
with
an
enhanced
30
1
in­
use
compliance
emission
testing
program
commonly
known
2
as
CAP
2000.
The
goal
of
this
program
is
to
divert
the
3
significant
resources
presently
devoted
to
pre­
sale
4
certification
and
redirect
them
toward
in­
use
compliance
in
5
order
to
provide
greater
assurance
that
the
vehicles
are
6
actually
complying
with
the
standards
in
use.

7
Based
on
staff's
analysis,
the
potential
8
cost
savings
attributable
to
certification
streamlining
9
range
from
a
minimum
of
$
36
million
per
year
to
a
maximum
10
of
approximately
$
57
million
per
year
to
the
automotive
11
industry.
With
annual
California
sales
in
excess
of
12
1.7
million
vehicles,
this
amounts
to
an
average
reduction
13
of
approximately
$
28
per
vehicle.

14
Thus,
the
net
cost
impact
of
the
proposed
15
ULEV
II
exhaust
and
evaporative
standards
minus
the
cost
16
savings
for
CAP
2000
would
be
about
$
107
per
vehicle
17
averaged
over
a
manufacturer's
entire
product
line,

18
Finally,
I'm
going
to
discuss
the
air
19
quality
benefits
and
cost
effectiveness
of
the
LEV
II
20
proposal.

21
To
estimate
the
emission
benefits
of
LEV
II,

22
staff
used
the
emission
inventory
model
EMFAC7G
which
was
23
approved
by
the
Board
earlier
this
year.
The
methodology
24
was
performed
for
vehicles
in
the
South
Coast
Air
Basin
25
because
this
was
the
target
for
SIP
Measure
M2
and
the
31
1
black
box.

2
Based
on
our
analysis,
the
total
estimated
3
exhaust
and
evaporative
emission
reductions
from
LEV
II
for
4
passenger
cars
and
light­
duty
trucks
and
medium­
duty
5
vehicles
are
7
tons
per
day
ROG
and
51
tons
per
day
NOx
in
6
the
South
Coast
Air
Basin
in
2010.
You
can
also
see
from
7
this
chart
that,
as
more
of
the
vehicle
fleet
is
turned
8
over,
the
benefits
continue
to
increase
to
20
tons
per
day
9
ROG
and
130
tons
per
day
NOx
in
2020.

10
We
are
pleased
to
have
developed
a
proposal
11
that
exceeds
the
emission
reduction
commitment
of
SIP
12
Measure
M2.
As
shown
in
the
chart,
we
fall
slightly
short
13
of
achieving
the
required
ROG
reductions
shown
in
the
blue
14
bar
on
the
left
but
exceed
the
NOx
emission
reduction
15
commitment
shown
in
the
blue
bar
on
the
right.

16
The
extra
NOx
emission
reductions
will
help
17
make
up
shortfalls
we
have
encountered
in
implementation
of
18
other
SIP
measures
and
contribute
to
reducing
the
size
of
19
the
black
box.
Even
with
these
reductions,
we
will
still
20
have
to
search
for
additional
reductions
to
meet
our
SIP
21
commitments.

22
Finally,
staff
estimates
that
the
average
23
cost­
effectiveness
of
the
exhaust
and
evaporative
proposal
24
including
CAP
2000
savings
is
approximately
$
1.00
per
pound
25
of
ROG
plus
NOx
reduced
with
the
range
being
approximately
32
1
$.
50
to
$
1.39.
This
is
very
cost
effective.
Industrial
2
measures,
for
example,
typically
are
about
$
5.00
per
pound
3
of
emissions
reduced.

4
This
slide
shows
the
cost­
effectiveness
of
5
LEV
II
compared
to
other
mobile
source
measures
adopted
by
6
the
Board.
As
you
can
see,
the
cost­
effectiveness
of
7
LEV
II,
shown
on
the
right,
compares
very
favorably
to
8
other
mobile
source
control
measures.

9
There
are
several
areas
where
staff
was
10
unable
to
reach
consensus
with
industry
and
other
affected
11
interests.
The
main
issues
concern
additional
compliance
12
flexibility,
the
proposal
for
extended
warranty
13
requirements,
and
the
proposed
evaporative
standards.
I
14
will
discuss
each
of
these
concerns
separately.

15
The
auto
manufacturers
submitted
an
16
alternative
tailpipe
proposal
they
maintain
is
more
17
feasible
than
the
proposal
before
you
today.
This
proposal
18
contains
additional
emission
categories
and
less
stringent
19
standards
in
almost
every
category,
than
those
being
20
proposed
by
staff.
In
some
cases,
the
standards
proposed
21
by
the
auto
industry
are
more
than
three
times
higher
than
22
those
proposed
by
staff,
especially
standards
concerning
23
sport
utility
vehicles.

24
The
automotive
industry
contends
that
their
25
proposal
achieves
the
emission
reduction
goals
of
SIP
33
1
commitment
Measure
M2
and
also
contributes
to
the
mobile
2
source
emission
reductions
needed
for
the
black
box.

3
However,
their
proposal
falls
short
of
staff's
proposal
by
4
approximately
7
tons
per
day.
This
loss
more
than
doubles
5
in
2020
as
the
fleet
turns
over.

6
Staff
examined
their
proposal
to
determine
7
whether
further
modifications
to
our
proposed
emission
8
standards
could
be
made
that
would
accommodate
the
auto
9
industry's
concerns
while
still
maintaining
the
emission
10
reductions
for
LEV
II.
However,
staff
was
unable
to
11
further
modify
the
LEV
II
proposal
without
seriously
12
impacting
the
emission
reductions
of
LEV
II.

13
A
major
reason
for
this
is
the
flexibility
14
that
is
already
built
into
the
LEV
II
regulations.
All
of
15
the
modifications
considered
by
staff
were
affected
by
16
these
flexibilities
and,
if
utilized,
would
further
dilute
17
the
emission
reductions
anticipated
by
our
proposal.
Based
18
on
our
demonstration
of
technological
feasibility
and
19
cost­
effectiveness,
it
is
staff's
conclusion
that,
given
20
the
large
amount
of
emission
reductions
needed
to
21
demonstrate
attainment
of
the
ozone
air
quality
standards
22
and
the
importance
of
further
reducing
ambient
23
concentrations
of
fine
particulates,
acceptance
of
the
auto
24
industry
proposal
would
adversely
impact
our
ability
to
25
achieve
our
air
quality
goals.

34
1
Nonetheless,
staff
did
respond
to
many
of
2
the
auto
industry's
requests
by
including
a
provision
3
allowing
4
percent
of
the
heavier
trucks
to
certify
to
4
laxer
standards,
a
150,000
mile
only
TLEV
standard
that
5
allows
diesel
vehicles
to
continue
to
participate
in
the
6
program
while
they
pursue
improved
emission
reduction
7
technology,
an
additional
year
for
phasing
in
the
standards
8
combined
with
a
more
flexible
means
of
calculating
the
9
phase­
in
rate
each
year,
a
more
gradual
decline
in
the
10
fleet
average
NMOG
for
the
truck
category,
and
less
11
stringent
in­
use
compliance
standards
for
the
first
two
12
years
that
a
vehicle
meets
the
new
standards.
This
reduces
13
the
risks
of
recall.

14
We
believe
the
availability
of
these
15
flexibilities
makes
the
changes
advocated
by
the
auto
16
industry
unnecessary.
In
addition,
staff
worked
with
17
industry
during
the
comment
period
and
is
proposing
further
18
modifications
which
are
set
forth
on
the
table
in
the
back
19
of
the
room.

20
Another
issue
of
concern
to
independent
21
vehicle
repair
facilities
is
the
proposed
150,000
mile
22
warranty
requirements
for
SULEVs
eligible
for
a
partial
ZEV
23
allowance
and
the
eight­
year,
100,000
mile,
high­
cost
parts
24
warranty
for
vehicles
certifying
to
the
optional
150,000
25
mile
standards.
The
aftermarket
parts
industry
is
35
1
concerned
that
an
increase
in
warranty
requirements
would
2
shift
business
away
from
independent
repair
facilities
3
towards
the
dealership.

4
However,
staff
believes
that
any
shift
from
5
the
independents
to
dealerships
would
be
slight,
although
6
we
do
share
the
concerns
of
these
small
business
owners
and
7
have
committed
to
work
with
them
over
the
next
18
months
to
8
address
these
issues.
Staff
believes
that
society
will
9
significantly
benefit
from
increased
warranty
requirements
10
because
vehicles
will
be
more
durable
and
the
number
of
11
vehicles
with
malfunctions
that
go
unrepaired
will
be
12
substantially
reduced.
This
will
have
a
significant,

13
positive
impact
on
cost
to
consumers
and
air
quality.

14
In
general,
the
automotive
industry
has
15
commented
that
the
proposed
evaporative
standards
are
too
16
stringent
and
that
numerically
higher
evaporative
standards
17
would
be
more
appropriate.
Their
argument
focuses
on
three
18
main
issues.

19
First,
industry
contends
that
the
in­
use
20
compliance
risk
of
the
proposed
evaporative
standards
is
21
high.
Evaporative
emissions
may
occur
at
many
point
22
sources
in
the
fuel
and
evaporative
system,
which
could
23
increase
the
likelihood
of
unanticipated
problems
in
the
24
field.
This
may
potentially
result
in
the
failure
of
the
25
evaporative
standards
in
use.

36
1
Secondly,
industry
contends
that
existing
2
data
on
non­
fuel
evaporative
emission
levels
are
sparse
and
3
do
not
comprehensively
represent
all
the
different
types
of
4
vehicle
models.
Since
an
allowance
in
the
proposed
5
standards
is
given
for
these
emissions,
industry
argues
6
that
the
sparse
data­
set
does
not
allow
an
accurate
7
assessment
of
the
non­
fuel
allowance.

8
Finally,
industry
contends
that,
because
9
many
of
the
potential
technologies
to
reduce
fuel
10
evaporative
emissions
are
already
being
used
on
production
11
vehicles,
few
improvements
can
be
made
to
further
reduce
12
evaporative
emissions.

13
The
ARB
test
program
shows
that
the
proposed
14
evaporative
standards
are
technologically
feasible
by
15
modifying
the
vehicle
to
use
the
best
evaporative
emission
16
components.
However,
to
alleviate
manufacturer
concerns
of
17
in­
use
recall
risk,
it
would
be
reasonable
to
provide
18
in­
use
recall
flexibility
that
allows
manufacturers
to
19
correct
minor
unanticipated
mistakes
and
failures
that
20
could
occur
with
new
evaporative
designs
during
the
early
21
years
of
introduction.
This
would
give
the
manufacturers
22
time
to
conduct
accelerated
field
tests
to
verify
that
23
their
designs
are
durable.
This
modification
is
described
24
in
the
15­
day
handout;
however,
staff
will
be
making
25
further
modifications
to
that
language.

37
1
Secondly,
the
current
non­
fuel
data
set
used
2
to
determine
the
allowance
in
the
proposed
standards
3
consists
of
data
from
21
vehicle
models
and
represents
4
vehicles
from
the
major
manufacturers.
Staff
believes
that
5
the
data
set
is
broad
enough
to
give
a
representative
6
profile
the
majority
of
non­
fuel
emission
levels
expected
7
on
the
vehicles.

8
Thirdly,
staff's
research
shows
that
9
practically
no
single
vehicle
has
all
of
the
best
available
10
technologies
in
the
fuel
and
evaporative
system;
therefore,

11
further
reductions
of
evaporative
emissions
are
possible
as
12
confirmed
in
staff's
test
programs.
Furthermore,
some
13
models
already
comply
with
the
proposed
evaporative
14
standards,
and
20
percent
of
current
model
year
cars
have
15
certified
emission
levels
below
the
standards.

16
Finally,
a
technology
review
of
the
proposed
17
standards
in
the
year
2000
will
resolve
any
remaining
data
18
issues.

19
Since
the
public
release
of
the
staff
20
report,
staff
has
been
continually
dialoging
with
industry
21
to
find
additional
consensus
on
the
proposal.
In
response
22
to
comments
from
industry,
staff
is
proposing
the
following
23
additional
modifications
to
the
original
proposal
which
24
will
be
released
for
a
15­
day
public
comment
period
25
following
this
hearing:

38
1
(
1)
To
allow
a
.02
gram
per
mile
NOx
credit
2
for
current
clean
sport
utility
vehicles
and
heavier
trucks
3
that
meet
the
LEV
I
PC
standards
before
2004.

4
(
2)
The
adoption
of
a
less
stringent
in­
use
5
evaporative
standard
for
the
first
three
years
of
a
6
proposed
standard.
As
I
noted
earlier,
the
text
in
the
7
handout
will
be
further
modified.

8
(
3)
To
allow
manufacturer
to
certify
to
a
9
lower
partial
ZEF
SULEV
exhaust
standard
to
offset
10
evaporative
emissions
above
the
zero­
evap
standard.

11
(
4)
To
sunset
the
optional
TLEV
NOx
and
PM
12
standards,
and
in
2007
replace
them
with
lower
standards.

13
Staff
is
also
proposing
several
technical
14
and
clarifying
amendments
based
on
comments
received
from
15
industry
and
others,
subsequent
to
the
release
of
the
staff
16
report.

17
In
conclusion,
staff
believes
that
the
18
proposal
before
you
today
is
not
only
technologically
19
feasible,
but
it
is
the
most
cost­
effective
approach
to
20
achieving
our
air
quality
goals.
It
reflects
changes
from
21
the
original
proposal
to
address
many
of
industry's
22
concerns.
Staff,
therefore,
recommends
that
the
Board
23
adopt
our
proposal.

24
That
concludes
our
presentation,
and
we'd
25
like
to
answer
questions
you
have
at
this
time.

39
1
CHAIRMAN
DUNLAP:
Okay.
Thank
you.
I
2
particularly
appreciate
the
fluid
nature
of
the
tailend
of
3
the
proposal.
Mike,
for
you
and
Tom,
getting
back
to
us
4
about
some
of
the
changes
that
have
been
in
that
period.

5
What
I
think
I'd
like
to
do
is
ask
6
Mr.
Schoning,
Jim,
would
you
please
address
the
process
7
prior
to
today
by
which
this
item
came
before
us
and
share
8
any
concerns
or
comments
you
may
have
with
the
Board.

9
MR.
SCHONING:
Thank
you,
Mr.
Chairman.
I'd
10
be
pleased
to.
As
you
heard
from
staff
in
some
detail,

11
this
measure
stems
from
the
fact
that
in
1990
California
12
adopted
the
most
stringent
emission
and
exhaust
regulations
13
ever
for
light­
and
medium­
duty
vehicles
in
the
14
low­
emission
program.
Several
developments
since
then,

15
such
as
the
increasing
population
growth
in
vehicle
miles
16
traveled
and
particularly
changes
in
consumer
taste
17
available
and
emission
control
technology,
staff
has
18
reached
the
conclusion
that
it
is
time
for
more
stringent
19
vehicle
emission
standards.

20
You'll
hear
many
opinions
from
witnesses
21
today,
both
pro
and
con,
on
the
feasibility
and
22
cost­
effectiveness
of
the
proposal
before
you.
The
issues
23
are
large,
and
they
will
have
a
comparable
impact
on
the
24
future
of
California's
air
quality
and
its
business
25
climate.
My
job
here
is
to
discuss
how
staff
has
worked
40
1
with
stakeholders
to
bring
the
item.

2
A
total
of
two
workshops
were
conducted.

3
Staff
aired
their
initial
LEV
II
and
CAP
2000
proposals
in
4
a
public
workshop
on
December
9
and
10
of
last
year,

5
attended
by
more
than
100
persons
who
listened
to
6
presentations,
in
some
cases
made
their
own
presentations
7
to
ARB
staff
response
to
the
initial
proposal.

8
In
attendance
were
the
automobile
9
manufacturers
­­
Ford,
General
Motors,
Chrysler,

10
Volkswagen,
Isuzu,
Volvo,
Mazda,
Honda,
Mitsubishi,
Toyota,

11
Nissan,
Mercedes
Benz,
Suzuki,
Rolls­
Royce,
Land
Rover,

12
Porsche,
BMW,
and
Subaru
­­
as
well
as
their
13
associations
­­
the
American
Auto
Manufacturers
14
Association,
Association
of
International
Automobile
15
Manufacturers,
and
Engine
Manufacturers
Association.

16
Other
manufacturers
present
included
Navstar
17
and
Cummins.
And
other
trade
associations
that
sent
18
representatives
were
Manufacturers
of
Emission
Control
19
Association,
MECA,
Western
States
Petroleum
Association,

20
the
Western
Propane
Gas
Association,
and
the
American
21
Petroleum
Institution.

22
Research
and
development
manufacturing
and
23
consulting
businesses
were
also
represented
by
Inglehard
24
Corporation,
Abacas
Technologies,
MCO
Technology,
Arcada
25
Southwest
Research
Institute,
Methanex,
Pureberg,
and
AC
41
1
Propulsion.

2
Environmental
organizations
in
attendance
3
included
the
Natural
Resource
Defense
Council,
Coalition
4
for
Clean
Air
and
the
Union
of
Concerned
Science.

5
Since
then
­­
and
that
initial
workshop
and
6
continuing
until
this
very
hearing
today,
staff
has
met
7
with
individual
manufacturers
and
related
trade
8
associations
on
each
of
the
major
components
of
the
9
proposal
solicited,
additional
details
relevant
to
10
technological
feasibility,
and
cost­
effectiveness.

11
Staff
discussed
the
proposal
many
times
with
12
the
auto
manufacturers
and
the
trade
associations
just
13
mentioned
as
well
as
the
Association
of
Industry
and
14
Government
for
Emissions
Research,
Cummins,
and
with
the
15
California
Automotive
Task
Force
comprised
of
the
16
after­
market
repair
and
auto
parts
industries,
service
17
station,
repair
shop
owners,
equipment
manufacturers,

18
automotive
teachers,
and
parts
wholesale.

19
Staff
met
with
environmental
organizations
20
often,
including
Natural
Resources
Defense
Council,
the
21
Coalition
of
Air
of
Concerned
Scientist,
and
Sierra
Club.

22
And
members
of
the
California
Environmental
Dialogue
also
23
met
with
the
staff.

24
In
addition,
staff
held
focused
meetings
on
25
components
of
the
proposal.
Public
meetings
specifically
42
1
on
the
CAP
2000
proposal
was
held
last
April
28.
Staff
2
continued
meeting
with
an
informal
working
group
which
was
3
formed,
which
included
the
United
States
Environmental
4
Protection
Agency
and
the
auto
manufacturers.

5
As
you
heard
from
staff,
they
worked
closely
6
with
the
Society
for
Automotive
Engineers
to
develop
the
7
hybrid
electric
vehicle
test
procedures,
held
at
least
13
8
conference
calls
with
the
related
SAE
subcommittee
in
9
addition
to
meeting
with
Toyota,
Honda,
Subaru
and
Nissan.

10
Final
focused
area
was
the
evaporative
11
emissions
component,
and
staff
again
met
with
the
auto
12
manufacturers
and
their
associations,
AAMA
and
AIAM.

13
Altogether
from
December
of
last
year,
at
14
present
staff
recorded
over
65
separate
meetings
with
15
interested
and
involved
stakeholders.

16
A
second
public
workshop
was
held
on
July
22
17
of
this
year.
More
than
150
persons
signed
in.
The
18
purpose
of
this
workshop
was
to
obtain
input
on
changes
19
staff
made
in
response
to
input
they
received
from
the
20
initial
proposal
previous
December.
While
all
of
the
21
stakeholders
who
attended
the
December
workshop
attended
22
this
workshop,
and
associations
who
were
not
recorded
as
23
attending
the
December
workshop
included
Fiat,
Renault,

24
Lamberguini,
ARCO,
Chevron,
Gilbarco
Inc.,
Artech,

25
Specialty
Equipment
Manufacturers
Association,
CSMI,
Arrow
43
1
Environment,
researchers
from
the
University
of
California,

2
Partnerships
for
a
New
Generation
Vehicle,
Basch,
Swedish
3
Office
of
Science
and
Technology,
California
Trucking
4
Association,
the
Advanced
Lead
Acid
Battery
Consortium,
Cal
5
Start,
the
Auto
Parts
and
Service
Alliance,
Separate
6
Energy,
Los
Angeles
Department
of
Water
and
Power,

7
San
Diego
Gas
and
Electric,
Edison
EV,
California
8
Electrical
Vehicle
Transportation,
Coalition
Methanol
9
Institute,
the
Automobile
Club
of
California,
Pansonic,

10
Samsung,
California
Manufacturers
Association,
South
Coast
11
Air
Quality
Management
District,
and
the
San
Diego
Air
12
Pollution
Control
District
as
well
as
the
California
State
13
Energy
Commission.

14
Staff
evaluated
all
comments,
in
particular
15
those
regarding
technological
feasibility
and
16
cost­
effectiveness
issues.
Staff
has
continued
to
receive
17
and
evaluate
proposals
following
distribution
of
the
staff
18
report.

19
Staff
report
itself
was
published
20
September
11,
was
mailed
to
more
than
a
thousand
21
individuals,
and
was
posted
on
our
internet
site.
It
was
22
downloaded
more
than
400
times
at
last
count.
And
I
would
23
share
with
you
also
what
we
received
in
the
way
of
letters
24
and
telephone
calls.
Our
public
information
office
has
25
logged
some
847
calls
with
all
but
one
supporting
the
44
1
proposal.
ARB
has
received
a
total
of
4,394
letters
of
2
support
and
some
238
letters
of
opposition.

3
As
your
ombudsman
with
a
special
charge
in
4
federal
statute
to
look
to
the
interest
of
small
business,

5
I
would
be
remiss
if
I
did
not
tell
you
that
you
will
hear
6
the
concerns
today
of
the
after­
market
repair
and
parts
7
industries
as
to
the
possible
detrimental
impact
upon
their
8
ability
to
continue
as
our
partners,
depending
upon
how
the
9
warranty
aspect
of
the
measure
affects
them.
I
know
you'll
10
hear
further
testimony
in
that
regard.

11
But
in
conclusion,
we
find
staff
has
12
conducted
extensive
outreach
and
assured
participation
by
13
the
full
spectrum
of
affected
and
interested
parties.

14
CHAIRMAN
DUNLAP:
Thank
you,
Mr.
Schoning.

15
I
appreciate
that
overview.

16
What
I'd
like
to
do
at
this
point
is
ask
my
17
Board
member
colleagues
if
they
have
any
questions
of
this
18
staff
relative
to
the
presentation.
We
will
remind
them,

19
as
well
as
the
audience,
that
we
have
some
45
people
that
20
have
signed
up
to
testify;
so
I
would
ask
the
Board
to
21
focus
the
early
questions
on
essential
points,
and
I'll
22
allow
you
during
the
course
of
give­
and­
take
with
the
23
witnesses
that
you
can
develop
your
questions
further
24
there.

25
So
we
will
start
with
Mr.
Calhoun.
Joe?

45
1
MR.
CALHOUN:
I'd
like
to
focus
my
question
2
on
technological
feasibility.
Since
the
inception
of
the
3
emission
control,
as
best
as
I
can
remember,
always
had
4
different
standards
for
trucks.
And
so
it's
important
to
5
focus
on
the
­­
I
think,
it's
important
to
focus
on
the
6
technological
feasibility.
It's
my
understanding
that
you
7
chose
a
Ford
truck
primarily
because
it
has
the
best
8
technology
available;
is
that
correct?

9
MR.
CACKETTE:
Yes.

10
MR.
CALHOUN:
You
show
an
average
of
the
11
test
results
for
seven
vehicles.
There
were
more
testing,

12
obviously,
than
that,
were
there
not?

13
MR.
CACKETTE:
Yes.

14
MR.
CALHOUN:
How
many
tests
did
you
run
15
altogether?

16
CHAIRMAN
DUNLAP:
For
the
court
reporter,

17
just
introduce
yourself.

18
STEVE
ALBU:
Steve
Albu
with
the
Air
Board.

19
With
the
optimized
system,
we
ran
a
total
of
26
tests.

20
MR.
CALHOUN:
When
you
say
the
optimized
21
system,
how
many
did
you
run
altogether?

22
STEVE
ALBU:
That's
a
difficult
question
to
23
answer.
I
think
something
in
the
area
of
180
tests,

24
developmental
tests.

25
MR.
CALHOUN:
And
you
selected
7
tests
out
46
1
of
that
180?

2
STEVE
ALBU:
No,
not
at
all.
What
we
had
to
3
do
­­

4
MR.
CALHOUN:
Out
of
the
optimized
vehicles,

5
you
select
7
tests;
is
that
correct?

6
STEVE
ALBU:
Out
of
the
26
tests,
we
7
selected
7
that
represented
the
best
fuel
targeting
that
we
8
could
achieve
since
we
did
not
have
the
ability
to
modify
9
the
fuel
control
to
match
the
new
catalyst.
And
I
can
10
explain
that
later
maybe
as
testimony
goes
forth.

11
MR.
CALHOUN:
And
the
average
results
as
12
presented
in
the
chart
­­
now,
did
you
take
into
13
consideration
the
fact
that
the
manufacturers
will
need
a
14
design
level
so
that
as
call
for
­­
I'm
not
sure
what
you
15
call
it.
But
a
lot
of
the
factors
that
were
taken
into
16
consideration
­­
drivability,
fuel
economy
­­
were
those
17
things
taken
into
consideration?
How
did
you
consider
that
18
during
the
course
of
the
testing?

19
STEVE
ALBU:
We
definitely
did.
We
targeted
20
about
.035
NOx
level
which
is
what
industry
agreed
was
the
21
appropriate
level
to
provide
headroom
to
meet
a
.05
NOx
22
standard.
And
what
we
did
was
we
performed
the
best
tests
23
we
could
achieve
in
the
about
six­
month
time
period
we
had
24
to
develop
this
vehicle,
and
then
we
provided
the
air
25
injection
system.
We
provided
preconditioning
procedures
47
1
that
achieved
the
lowest
emissions
possible
without
better
2
fuel
control.
And
then
we
also
listed,
on
the
slides
you
3
saw
in
the
presentation,
another
12
or
so
technologies
that
4
can
still
be
used
in
the
industry
in
the
eight
years
5
remaining
for
the
toughest
vehicles
to
actually
meet
the
6
standards.

7
In
fact,
this
is
the
first
time
really
that
8
staff
has
ever
taken
a
component
like
a
catalyst
system
and
9
aged
it.
Back
in
LEV
I,
for
example,
we
used
unaged
10
components
that
had
no
real
durability
development
on
11
them.
We
projected
much
further
as
to
what
could
be
done.

12
In
this
instance,
we
have
actually
used
aged
13
components,
although
we
did
not
have
a
proper
fuel
system.

14
It
was
just
somehow
available
to
us.
We
still
demonstrated
15
emissions
at
the
standard,
and
we
also
provided
additional
16
explanations
of
how
industry
could
improve
upon
those
17
results.
One
of
the
most
effective
things
they
can
do
is
18
just
simply
have
fuel
control
that
we
would
have
liked
to
19
have
had.

20
MR.
CALHOUN:
How
soon
after
the
21
introduction
will
manufacturers
have
to
meet
the
ULEV
22
standard,
the
vehicle
we
are
talking
about?
In
the
next
23
year?

24
STEVE
ALBU:
The
standards
begin
phasing
in
25
2004,
and
we
expect
the
industry
will
typically
certify
the
48
1
passenger
cars
in
the
"
T2"
category
which
are
the
trucks,

2
primarily,
will
do
the
minivans,
compact
pickups
first.

3
And
we
would
expect
vehicles
like
the
Ford
Expedition,
the
4
F150
pickups,
they're
probably
done
in
2007.

5
MR.
CALHOUN:
We
will
hear
from
the
6
manufacturers
later
on.

7
STEVE
ALBU:
Sure.

8
CHAIRMAN
DUNLAP:
Matter
of
fact,
Joe,
they
9
are
in
the
first
five
witnesses
or
so.

10
STEVE
ALBU:
We
will
be
happy
to
respond
to
11
those
comments
when
they
come
up.

12
CHAIRMAN
DUNLAP:
One
of
the
things
that
the
13
Board
is
going
to
be
looking
for
is
for
you
to
explain
some
14
main
arguments
that
we
may
have
some
selective
test
data,

15
and
we
want
to
clear
that
up
and
talk
about
what
we've
done
16
to
make
it
so
the
people
can
see
clearly
the
depth
and
17
breadth
of
what
you've
tried
to
do
relative
to
what
you've
18
proposed
today.

19
Any
other
Board
member
questions?

20
MS.
EDGERTON:
Yes,
I'd
like
to
ask
21
questions.

22
CHAIRMAN
DUNLAP:
Sure,
Ms.
Edgerton.

23
MS.
EDGERTON:
I'd
like
to
confirm
that
my
24
understanding
of
some
key
points
is
correct
because
we
have
25
a
lot
of
letters
here
from
Californians
who
are
concerned
49
1
that
they
may
not
be
able
to
have
the
kind
of
vehicles
they
2
want
starting
in
2004.
It's
my
understanding
from
your
3
report
that
the
staff
feels
confident
that
there
will
be
no
4
reduction
in
the
variety
and
performance
of
sports
utility
5
vehicles
and
light­
duty
trucks
being
offered
in
California
6
as
a
result
of
this
proposal.

7
The
only
change
will
be
that
there
will
be
8
somewhere
in
the
nature
of
$
200
added
to
the
cost
of
9
producing
the
vehicle
to
pay
for
the
catalyst,
and
that
may
10
well
be
less
because
it
doesn't
happen
until
2004;
is
that
11
correct?

12
STEVE
ALBU:
Well
actually,
you're
correct.

13
There
is
virtually
no
reason
­­
there
is
absolutely
no
14
reason
why
there
should
be
any
loss
of
vehicle
types.

15
Every
vehicle
model
currently
being
sold
now
should
still
16
be
available.
All
we
did,
as
I
say
again,
was
replace
the
17
catalyst
with
one
that
was
the
same
size,
same
18
configuration
as
currently
on
the
Expedition.
We
improved
19
the
air
injection
system.
We
added
an
air­
injection
20
system,
and
then
we
outlined
a
number
of
other
technologies
21
that
could
be
added
to
the
vehicle.

22
The
catalyst
increase
in
cost
is
around
$
50.

23
The
rest
of
the
components
could
go
up
to
$
200
when
you
24
talk
about
adding
in
the
cost
of
development,
the
25
facilities
and
so
forth,
dealership
costs.
So
no,
there
50
1
should
be
no
loss
in
vehicles.
Ownership
should
be
just
2
the
same
as
it
is
today.

3
MS.
EDGERTON:
When
you
put
it
on
the
test
4
vehicles,
the
Ford
Expedition,
there
is
no
loss
in
5
performance?

6
STEVE
ALBU:
None
at
all.

7
MS.
EDGERTON:
Thank
you.

8
MR.
CACKETTE:
I
want
to
point
out
that
that
9
car
is
sort
of
a
worst­
case
vehicle.
So
if
the
potential
10
is
shown
on
that
vehicle,
then
it
should
be
even
easier
on
11
the
other
ones.
And
I
think
you
can
see
that.
We
have
a
12
mid­
size
car
out
there,
the
Mitsubishi
Galante,
which
meets
13
the
2004
standards
right
now
in
production.

14
CHAIRMAN
DUNLAP:
When
you
say
worst­
case,

15
you
mean
generally
category
because
of
weight
and
that
kind
16
of
thing,
not
that
it's
a
bad
vehicle
or
anything?

17
MR.
CACKETTE:
Right.
It's
actually
the
18
best
technology,
but
it's
in
the
most
difficult
19
compliance­
type
vehicle.

20
CHAIRMAN
DUNLAP:
We
just
­­

21
MR.
CACKETTE:
Thank
you
for
correcting
me.

22
I
want
to
get
out
of
here
alive.

23
MS.
EDGERTON:
It
is
important
to
reassure
24
the
public,
particularly
since
we
have
so
many
people
25
relying
on
these
vehicles,
that
they
will
still
be
51
1
available
and
fully
performing.
Thank
you.

2
CHAIRMAN
DUNLAP:
And
I
don't
want
to
have
3
anymore
back
and
forth
on
that
right
now
because
we
are
4
going
to
hear
from
Ford
themselves,
and
I
don't
want
to
5
preempt
their
discussion.

6
If
there
is
nothing
else,
I
offer
up
that
we
7
get
another
witness
list.
So
what
I'll
do
is
­­
where
are
8
we
having
people
cue
up,
Shelby?
Over
on
this
side?

9
Okay.
We
have
45
witnesses,
and
I'll
ask
them
­­
I'll
call
10
off
ten
names
or
so.
If
you'll
take
your
seat
in
the
box
11
over
there
with
Mr.
Weiser.

12
Vic,
raise
your
hand
so
they
can
see
where
13
you
are.
There
is
Vic.
Kelly
Jensen,
California
Chamber
14
of
Commerce.
Vic
Weiser,
second
up,
from
CCEEB.
Mr.
Till
15
Stoeckenius
from
Environ
Corp.
Kelly
Brown
from
Ford.

16
Matt
Kevnick
from
Toyota.
Charlie
Kitz
from
Chrysler.

17
Kevin
Cullen
from
General
Motors.
Sam
Leonard
from
General
18
Motors.

19
Sam,
I'll
let
the
two
of
you
kind
of
tag
20
team
together.
I'll
call
you
up
at
the
same
time.

21
Barbara
Kiss
from
the
American
Automobile
22
Manufacturers
Association.
Greg
Dana
from
the
Association
23
of
International
Auto
Manufacturers.
Wolfgang
Groth
from
24
Volkswagen.
Dick
Shaw,
Ram
Products.
Andy
Frank,

25
Professor
Frank
from
UC
Davis.
And
Bruce
Bertelsen.
And
52
1
the
last
one
will
be
Roland
Hwang,
Janet
Hathaway,
et
2
cetera.

3
So
if
I
could
get
you
all
to
move
your
way
4
towards
that
end
of
the
room.
Kelly,
we
will
ask
you
to
5
come
forward.
Give
me
just
a
second
for
people
to
settle
6
down.
The
other
witnesses,
as
seats
open
up,
if
you
could
7
gravitate
towards
that
side
of
the
room,
I
would
be
8
grateful.

9
I
have
a
timer
here
that
I
used
it,
I
think,

10
once
in
the
four
years
I've
been
chairman.
I
prefer
not
to
11
use
it
today,
but
I'm
going
to
ask
witnesses
to
limit
their
12
comments
under
five
minutes.
And
if
we
get
some
people
13
droning
on
and
if
you're
repetitive,
I'm
going
to
clip
your
14
wings.
So
I
don't
want
to
hear
the
same
argument
over
and
15
over.
Suffice
it
to
say,
you
can
say,
"
As
the
previous
18
16
witnesses
said,
we
feel
this
way,"
and
leave
it
brief.

17
Kelly,
you're
up
first.
Welcome.

18
KELLY
JENSEN:
Thank
you,
Mr.
Chairman
and
19
Members.
Kelly
Jensen,
representing
the
California
Chamber
20
of
Commerce
and
a
new
coalition
called
the
Californians
for
21
Realistic
Vehicle
Standards,
a
coalition
with
over
60
22
individuals
who
have
engageed
to
write
letters
to
the
Board
23
and
express
their
opposition
to
the
LEV
II
staff
proposal.

24
We
believe
that
the
staff
proposal
is
25
arbitrary
and
illogical
and
could
have
lasting
impacts
on
53
1
the
economy.
It's
arbitrary
because
it
requires
standards
2
that
go
far
beyond
the
Federal
Clean
Air
Act.
It's
3
illogical
because
it
requires
a
full­
size
truck
hauling
4
heavy
equipment
to
meet
the
same
standards
as
a
passenger
5
car
half
its
size.
Because
it
is
not
possible
to
achieve
6
the
standards
proposed
by
the
staff
proposal
without
7
reducing
weight,
pay
load,
and
towing
capacity,
there
will
8
be
a
reduction
in
full­
size
vehicles
available
to
9
consumers.

10
Fewer
full­
size
vehicles
mean
consumers
will
11
lose
the
ability
to
haul
loads
and
tow
boats
or
they
could
12
be
forced
to
purchase
more
expensive,
larger
vehicles
that
13
are
not
subject
to
the
new
emission
standards.
The
only
14
way
for
industry
to
meet
the
new
standards
would
require
15
25
percent
of
vehicles
sold
in
California
to
run
on
16
alternative
fuels
at
an
increased
cost
of
$
7,000
per
17
vehicle.
This
would
affect
all
consumers,
not
just
18
light­
truck
users.

19
In
fact,
the
California
Trade
and
Commerce
20
Agency
estimates
the
cost
of
the
staff
proposal
on
21
California
business
and
individuals
would
equal
22
$
1.87
billion
over
a
five­
year
period.
That's
over
23
$
350
million
a
year.
The
California
Chamber
and
the
24
coalition
support
an
industry
alternative
that
preserves
25
the
functionality
of
full­
size
vehicles
and
provides
54
1
90
percent
of
the
desired
emission
reductions
without
the
2
cost
to
consumers.

3
Full­
size
utility
vehicles
are
the
4
commercial
workhorses
of
California
economy.
This
5
statement
is
illustrated
by
members
of
our
coalition
who
6
have
opposed
the
staff
proposal.
They
include
the
Heating
7
and
Air
Conditioning
Contractors'
Association,
the
8
California
Building
Industries
Association,
the
San
Joaquin
9
Farm
Bureau,
auto
makers,
and
many
individual
businesses.

10
One
letter
of
opposition
sent
to
the
Board
by
the
Berry
11
Petroleum
Company
speaks
directly
about
the
impact
of
the
12
staff
proposal
on
their
company.

13
Berry
Petroleum
has
over
45
pickup
trucks
in
14
its
operation.
They
state
that
any
added
cost
to
new
15
vehicles
would
require
the
company
to
keep
their
vehicles
16
longer
because
it
would
be
more
cost­
effective
to
repair
17
rather
than
replace
older
vehicles.
The
letter
concludes
18
with
this
comment,
"
The
pickup
is
the
lifeblood
of
19
thousands
of
businesses,
large
and
small,
in
California.

20
Boosting
the
price
and
forcing
owners
to
keep
their
pickups
21
longer
would
only
increase
air
emissions
in
California."

22
California
is
at
an
economic
crossroads.

23
Taxpayers
and
businesses
will
be
asked
by
the
next
24
administration
to
invest
in
our
schools
and
rebuild
our
25
infrastructure.
We
welcome
that
challenge.
But
at
the
55
1
same
time,
we
are
in
an
uncertain
economic
time.
The
2
chamber
believes
that
this
staff
proposal
is
the
type
of
3
rigid
policy
that
will
stifle
economic
growth
and
jobs.

4
Unless
the
economy
continues
to
grow,
there
will
be
little
5
money
to
improve
our
schools
and
rebuild
our
6
infrastructure.

7
Please
keep
that
in
mind
as
you
thoughtfully
8
consider
all
the
recommendations
that
you'll
hear
today.

9
And
on
a
personal
note,
we
just
want
to,
from
myself,
I
10
want
to
congratulate
the
Chairman
on
his
leadership
11
throughout
the
many
years
and
look
forward
to
working
with
12
you
in
the
future.

13
CHAIRMAN
DUNLAP:
If
I
could
maybe
ask
a
14
question.
One
of
the
things
­­
and
I
think
you
know
15
this
­­
that
we
are
concerned
about
is
that
you're
16
concerned.
I
mean,
you're
generally
known
throughout
17
before
this
Board
unless
their
issue
has
really
got
our
18
attention.
Having
said
that,
I
have
a
couple
issues
19
relative
to
the
statistics
you
cited.
I
just
want
to
20
understand
their
origin,
and
I've
had
a
chance
to
read
some
21
of
the
offhand
pieces
and
other
materials
that
you
guys
22
have
been
putting
out.

23
You
talk
about
this
25­
percent
factor
of
the
24
larger
sports
utility
vehicles
being
produced
having
to
be
25
alternative
fueled
and
the
cost
associated
with
that.
I'm
56
1
a
bit
confused
about
that,
and
I
kind
of
want
to
2
understand.
And
I'm
asking
more
for
a
dialect
for
you,

3
Tom,
with
Kelly
on
this
point.

4
Kelly,
where
do
those
statistics
come
from?

5
What
are
your
beliefs
surrounding
that?

6
KELLY
JENSEN:
I
guess
it
comes
from
two
7
sources
and
sort
of
an
overview
of
consumer
choice.
You
8
know,
it's
estimated
and
industry
tells
us
that
to
produce
9
these
vehicles
is
going
to
cost
$
7,000
more.
It's
clearly
10
not
the
consumer
choice
in
California
to
drive
an
11
alternative
fuel
vehicle.
So
we
believe
that
anytime
when
12
you
take
25
percent
of
a
product
out
of
the
supply
or
out
13
of
the
demand,
you
impact
consumer
choice
which
leads
to
14
higher
prices
across
the
board.
You
have
25
percent
of
15
your
product
sitting
on
the
shelf
that
nobody
wants
to
buy.

16
Clearly,
there
is
going
to
be
less
supply
which
leads
to
17
higher
cost.

18
CHAIRMAN
DUNLAP:
I
was
in
a
very
low
19
chair.
Not
that
I
needed
to
be
towering
above,
I
just
was
20
lower.
So
excuse
me.
This
is
my
last
meeting.
Indulge
21
me.

22
Tom,
what
is
your
feeling?
Would
we
be,
in
23
effect,
voting
for
going
off
the
fuel
neutral
position
we
24
have
and
pushing
people
somewhere
in
the
fleet
that
is
25
intentional?
Is
that
where
this
is
taking
us?

57
1
MR.
CACKETTE:
No.
We
are
absolutely
2
convinced
there
will
be
no
model
unavailability
out
of
3
this.
If
the
statistic
Mr.
Jensen
provides,
that
a
quarter
4
of
the
vehicles
or
models
would
be
unavailable,
I
guess
I
5
would
be
the
61st
member
of
his
coalition.
We
don't
see
6
it.
We
believe
that
the
feasibility
of
the
standards
has
7
been
proven
on
these
larger
trucks
with
gasoline,
not
with
8
alternative
fuels.
And
I
think
it's
important
that,
to
my
9
knowledge,
the
issue
of
we
can
only
do
it
with
alternative
10
fuels,
it
would
cost
$
7,000,
has
never
come
up
in
any
of
11
the
many
workshops
and
interactions
that
Mr.
Schoning
12
outlined
for
you.

13
CHAIRMAN
DUNLAP:
Is
there
something
hidden
14
in
the
averaging
scheme
for
the
fleet
and
the
breakdown
15
between
what
they
do
and
what
category
that
maybe
we
are
16
missing?

17
MR.
CACKETTE:
Well,
I
think
the
point
would
18
be
made
if
in
fact
one
believed
­­
and
I
think
some
of
the
19
testimony
will
lead
to
that,
that
it
is
infeasible
to
meet
20
these
standards
for
certain
kinds
of
vehicles.
And
if
it
21
is
infeasible,
then
I
guess
it
wouldn't
be
available.
We
22
just
soundly
disagree
with
that
because
we
think
we
have
23
demonstrated
that
the
standards
can
be
met,
especially
24
given
there
are
eight
years
of
compliance
time
left
for
the
25
hardest
to
control
vehicles.

58
1
But
we
do
have
other
provisions,

2
flexibilities
in
the
rule,
which
allow
­­
you've
got
these
3
four
categories
of
standards.
And
if
you've
got
a
tough
to
4
control
vehicle,
then
you
tend
to
certify
it
in
one
of
the
5
more
lax
categories
and
make
one
of
the
easier
to
control
6
ones
in
super­
type
categories.
That
kind
of
averaging
7
helps.
The
slow
phase
in
we
have
helps,
which
means
you
8
get
the
full
eight
years
versus
five
years
to
make
those
9
vehicles
comply.

10
And
I
just
point
out
in
1990,
when
this
11
Board
heard
the
LEV
I
Program,
that
the
manufacturers
got
12
up
and
testified
a
little
bit
differently
than
I
think
they
13
are
going
to
testify
today,
and
that
was
basically
they
14
could
do
the
TLEVs.
But
they
had
no
idea
how
they
were
15
going
to
do
a
LEV
or
ULEV
car,
but
they
would
give
their
16
best
effort
at
it.
And
what
you
see
today
is
for
$
100
17
incremental
price,
we
have
LEVs
and
now
some
ULEVs
being
18
sold
commercially
exactly
eight
years
later
after
the
Board
19
adopted
that
standard.

20
I
think
the
burden
of
proof
here
there
has
21
been
more
evidence
presented
as
the
feasibility
than
there
22
was
eight
years
ago,
and
I
would
expect
the
manufacturers
23
will
end
up
responding
exactly
the
same
way.

24
CHAIRMAN
DUNLAP:
Kelly,
not
to
quibble
with
25
you
about
statistics
and
areas
of
concern
because
I
too
59
1
would
share
if
we
were
pushing
people
to
that
high
of
a
2
price
jump
and
we
are
going
to
limit
choices.
I
would
be
3
worried
about
that
as
well.
So
we
will
let
you
off
the
4
hook
as
well.

5
KELLY
JENSEN:
Clearly,
there
is
a
6
disconnect
between
what
the
staff
is
recommending
on
cost
7
and
what
the
industry
is
telling
me.
I
think
it's
your
8
responsibility
to
sort
of
remedy
that.
And
whether
or
not
9
the
technology
is
out
there,
it
may
or
may
not
be
10
responsible
to,
you
know,
leap
forward
on
something
that
11
just
isn't
there.
And
it
would
impact
the
economy
in
such
12
a
devastating
way.

13
CHAIRMAN
DUNLAP:
We
will
take
that
cue
and
14
get
to
that
as
we
go
through.
Thank
you.
Any
other
15
questions?

16
We
will
go
to
Vic.
Vic,
we
want
to
17
acknowledge
your
compliant
behavior,
being
over
there
in
18
the
box
before
anybody
else.

19
VIC
WEISSER:
There
were
no
other
seats.

20
You're
so
popular,
John.

21
CHAIRMAN
DUNLAP:
Welcome.
Glad
to
have
you
22
with
us.

23
VIC
WEISSER:
Thank
you,
Mr.
Chairman
and
24
Members
of
the
Board.
This
is
an
honor
for
me
to
be
before
25
you,
and
this
is
an
incredibly
important
issue
and
one
that
60
1
will
surely
set
the
legacy
of
this
Board
and
the
state
of
2
California
in
years
to
come.
I'm
Vic
Weisser.
I'm
the
3
president
of
the
California
Council
for
Environmental
and
4
Economic
Balance,
CCEEB.

5
CCEEB
is
a
coalition
of
organized
labor
and
6
family
owned
businesses
like
Chevron,
Disney,
Lockheed.
We
7
cover
most
of
the
major
players
in
California.
And
I
think
8
it's
really
important
that
we
make
a
special
9
acknowledgement
to
the
incredible
advances
that
we
have
10
seen
in
the
emission
reduction
technology
over
the
last
two
11
decades.
It's
astounding
what
the
auto
manufacturers
and
12
the
petroleum
providers
have
enabled
us
to
do
in
terms
of
13
attacking
the
emission
control
problem.

14
So
you
might
ask
well,
why
do
you
need
to
go
15
further?
And
the
answer
is
what
Willy
Sutton
said
when
16
asked
why
he
robs
banks.
And
the
answer
is
because
that's
17
where
they
keep
the
money.
Well,
the
answer
­­
the
reason
18
why
you
have
to
go
after
these
cars
is
that
that's
where
19
the
emissions
are.
50,
60,
in
some
areas
over
70
percent
20
of
the
emission
pie
is
made
up
from
mobile
sources.

21
If
we
have
any
hope
to
achieve
our
emission
22
goals,
we
need
to
aggressively
and
smartly
go
after
23
reducing
those
sources.
We
still
face
an
enormous
problem,

24
particularly
in
the
south
coast
area,
in
meeting
existing
25
standards.
And
a
vast
majority
of
the
state
will
face
61
1
enormous
hurdles
in
meeting
the
new
standards
recently
2
established
by
the
US
EPA.

3
The
truth
is
is
that
we
have
done
as
a
4
society
virtually
all
the
easy
and
less­
expensive
things,

5
and
that
the
things
that
we
pick
now
we
really
need
to
be
6
smart.
We
can't
go
after
these
things
with
a
shotgun.
We
7
really
have
to
do
rifle
shots.
We
have
to
work
and
think
8
smarter.
We
also
need
to
go
after
every
ton
because
every
9
ton
counts.
We
can't
just
say
oh,
it's
a
couple
tons
here
10
or
a
couple
tons
there
because
somewhere
in
society
we
need
11
to
make
up
those
tons.

12
And
it's
been
CCEEB's
perspective
that
each
13
source,
each
sector
of
industry
and
society
including
the
14
public,
needs
to
bear
a
proportionate
responsibility
to
15
reduce
their
emissions.
We
think
that
you
ought
to
be
16
going
after
those
reductions
in
the
most
cost­
effective
17
manner
possible
and,
whenever
possible,
rely
on
market
18
forces
to
get
there.
But
every
part
of
California,
every
19
part
of
this
nation
and
ultimately
the
world
is
going
to
20
have
to
take
responsibility
for
those
emissions
that
they
21
produce.

22
I
presented
you
a
letter
from
CCEEB
that
23
outlines
our
position,
which
is
supportive
of
the
staff
24
proposal.
We
recognize
and
concur
with
the
need
of
the
25
magnitude
of
reductions
that
the
staff
is
proposing
in
this
62
1
rule
making.
We
support
reducing
emissions
from
future
2
light­
duty
trucks
and
SUVs.
It's
been
the
phenomenal
3
success
of
the
SUVs
that
has
thrown
our
movement
toward
4
achieving
our
goals
in
somewhat
danger.

5
We
need
something
to
do
to
reduce
emissions
6
from
that
very
popular
class
of
vehicles.
We
agree
that
7
vehicles
designed
for
personal
transportation
should
meet
8
the
same
emission
standards.
We
support
your
efforts
to
9
improve
the
durability
of
vehicle
emission
systems
by
10
extending
the
useful
life
definition
for
cars
and
trucks.

11
Frankly,
many,
many
people
think
you
should
have
gone
12
further
than
that
which
the
staff
has
proposed,
but
we
are
13
glad
you're
moving
in
the
right
direction.

14
We
believe
that
the
proposed
super
ULEV
15
standard
will
encourage
and
assist
manufacturers
to
16
introduce
cleaner
vehicles,
and
we
support
your
efforts
to
17
ensure
that
there
is
no
net
increase
in
particulate
18
emissions
from
vehicles
put
into
the
California
fleet.

19
Lastly,
we
believe
that
it's
important
that
20
consumers
be
aware
of
the
differences
in
emission
21
performance
of
all
the
new
cars,
and
we
urge
you
to
try
to
22
improve
the
sticker
that
now
appears
on
cars
in
a
variety
23
of
mostly
unintelligible
fashions.

24
Lastly,
I
want
to
wave
in
front
of
you
a
25
letter
which
you've
also
received
in
testimony,
a
letter
63
1
signed
by
well
over
20
members
of
the
California
2
Environmental
Dialogue,
a
group
Jim
Schoning
made
reference
3
to.
This
is
a
group
of
business
leaders
and
4
environmentalists
and
government
leaders
that
we
got
5
started
about
two
or
three
years
ago
in
the
silly
belief
6
that
environmentalists
and
businesses
could
actually
sit
7
down
and
talk
about
something
and
agree
on
something.
And
8
I
think
it's
noteworthy
that
one
of
the
two
major
issues
9
that
this
group
decided
was
important
enough
to
engage
10
their
efforts
are
mobile
source
emission
reductions.

11
And
this
group
has
come
together
with
a
12
series
of
principles
that
we
think
might
be
helpful
for
you
13
in
terms
of,
A,
showing
you
our
support
of
what
you're
14
doing
and,
B,
guiding
the
efforts.
I'm
going
to
conclude
15
by
recognizing
the
heavy
burden
that
the
Chairman
and
16
Members
have
in
facing
this.
This
is
not
an
easy
issue.

17
You're
going
to
hear
a
lot
of
people
with
a
lot
of
18
different
opinions,
and
I
suspect
some
of
the
words
that
19
you're
going
to
hear
will
approach,
if
not
exceed,
what
I
20
understand
as
rhetoric.

21
I
would
urge
the
Board
to
have
their
antenna
22
out
when
they
hear
buzz
words.
Buzz
words
like
arbitrary,

23
unnecessary,
negligible,
costly.
Arbitrary
in
terms
of
24
staff
proposal
is
a
word
that,
to
me,
makes
little
sense.

25
Arbitrary
means
without
standard,
without
reference
point.

64
1
Hundreds
of
hours,
thousands
of
hours,
hundreds
of
pages,

2
thousands
of
pages
­­
this
is
not
arbitrary.
This
is
a
3
reasoned
approach.
You
might
not
agree
with
it,
but
it's
4
certainly
not
an
arbitrary
approach.

5
Unnecessary?
As
I
said,
we
need
every
pound
6
of
cost­
effective
emission
reductions
that
we
can
get.

7
Negligible?
No.
Six
tons
is
not
8
negligible.
Eight
tons
is
not
negligible.

9
And
costly?
Yes,
it
is
costly.
There
is
no
10
free
lunch
in
reducing
emissions,
and
every
Californian
and
11
every
business
doing
business
in
California
is
going
to
12
have
to
pay
more
to
ensure
that
this
golden
state
goes
13
forward
with
a
future
that
we
can
actually
see.

14
And
with
that,
thank
you
very
much.

15
CHAIRMAN
DUNLAP:
Thank
you,
Vic.
Any
16
questions?
All
right.

17
Till
Stoeckenius.

18
TILL
STOECKENIUS:
Thank
you
very
much,

19
Mr.
Chairman,
for
struggling
with
that.
I'm
a
senior
20
meteorologist
from
Environ
Corporation,
and
I
came
here
21
today
at
the
request
of
the
American
Automobile
22
Manufacturers'
Association
to
present
to
you
the
results
of
23
some
research
we
have
recently
completed
for
them,
and
I
24
have
some
overheads.
What
I
want
to
talk
to
you
today
25
about
is
­­
I'm
going
to
do
this
much
more
quickly
than
I
65
1
had
intended
­­
some
research
we
did
examining
comparison
2
of
ozone
concentrations
in
Southern
California
on
weekends
3
versus
weekdays.

4
And
why
this
is
important
is
that
we
have
5
different
patterns
of
emissions
on
weekends
and
weekdays.

6
And
in
particular,
we
have
lower
morning
NOx
emissions
on
7
weekends.
So
it's
interesting
to
see
what
happens
to
ozone
8
on
weekends.

9
Before
I
get
into
those
results,
let
me
just
10
give
you
a
very
quick
background
on
the
ozone
formation
11
process.
As
you
all
know,
it's
combination
of
hydrocarbons
12
and
NOx
in
the
presence
of
sunlight
which
produces
ozone.

13
This
is
not
a
simple
first­
order
process.
It's
rather
14
complicated,
and
strange
things
can
happen.
In
particular,

15
what's
most
important
here
is
the
hydrocarbon­
to­
NOx
ratio.

16
At
low
ratios,
reducing
hydrocarbons
will
17
reduce
ozone,
but
reducing
NOx
will
actually
increase
18
ozone.
This
is
well
known
from
modeling
theoretical
19
studies.
On
the
other
end
at
high
ratios
of
hydrocarbons
20
to
NOx,
you
see
NOx
will
reduce
ozone.
This
is
illustrated
21
on
the
next
slide
where
we
have
what
is
commonly
referred
22
to
as
an
ECMA
diagram.

23
The
curved
lines
here
look
like
boomerangs,

24
represent
lines
of
constant
ozone
concentrations,
and
they
25
are
plotted
against
NO
concentration
on
the
left
at
the
"
Y"

66
1
axis
on
the
left
and
hydrocarbon
concentrations
on
the
"
X"

2
axis
on
the
bottom.
Ozone
increases
as
you
go
up
the
plot
3
from
the
lower­
left
corner
to
the
upper
right.
And
what
4
you're
seeing
here
is
that
at
high
hydrocarbon­
to­
NOx
5
ratios,
such
as
in
the
Bay
area
and
other
locations
in
6
California,
when
you
decrease
ozone
­­
I
don't
think
we
7
have
a
pointer
­­
as
you
decrease
the
NOx
concentration,

8
you
can
actually
go
to
higher
ozone
concentrations.
It's
9
not
until
you've
gone
over
this
line
of
maximum
ozone
10
formation
that
the
decreases
in
NOx
will
actually
result
in
11
decreases
in
ozone.

12
We
go
to
the
next
slide
now.
What
we
have
13
done
here
is
taken
advantage
of
sort
of
an
experiment
of
14
opportunity.
We
are
looking
at
the
change
in
ozone
in
15
response
to
the
changes
in
emissions
between
weekdays
and
16
weekends.
And
what
characterizes
weekends,
on
the
next
17
slide,
is
the
significantly
lower
morning
NOx
18
concentrations.
This
is
the
result,
of
course,
of
the
lack
19
of
a
commute
on
weekend
mornings.
So
we
see
large
NOx
20
reductions
in
the
mornings
on
the
order
of
30
to
50
percent
21
in
the
ambient
data.
At
the
same
time,
we're
seeing
22
hydrocarbon
reductions
but
not
as
large,
only
on
the
order
23
of
about
20
percent.

24
And
what
happens
then
is
that
the
25
hydrocarbon­
to­
NOx
ratio
increases
significantly
on
67
1
weekends
as
compared
to
weekdays.
At
the
same
time,
we
2
find
that
the
ozone
concentrations,
the
peek
concentrations
3
in
the
afternoon,
actually
increase
on
the
weekends.
And
4
this
leads
us
to
some
speculation
about
where
we
are
on
5
that
ECMA
diagram
that
I
showed
previously.

6
On
the
next
slide,
here
is
what
is
going
on
7
by
day
of
week
­­
Monday
on
the
left,
Sunday
on
the
right.

8
The
NOx
concentrations
­­
that's
the
top
line
­­
they
build
9
up
gradually
but
not
significantly
over
the
course
of
the
10
week.
Then
on
Saturday,
and
especially
so
on
Sunday,
the
11
NOx
decreases
dramatically.

12
We
go
to
the
next
slide.
The
result
of
this
13
reduction
in
NOx
on
weekend
mornings
is
an
increase
in
14
weekend
ozone
concentrations.
We've
reduced
NOx
a
lot
on
15
weekend
mornings.
The
hydrocarbons
have
come
down
only
a
16
little
bit.
Ratio
goes
way
up.

17
And
on
the
next
slide,
you
can
see
what
18
happens
with
ozone.
Here
we
are
in
Azusa,
a
site
with
very
19
high
ozone
concentrations
in
the
basin.
This
is
1986
on
20
the
left;
1996
on
the
right.
The
top
two
lines
are
the
21
Saturday
and
Sunday
concentrations
of
ozone,
daily
maximum
22
one­
hour
concentrations.
Bottom
two
lines
are
Tuesdays
and
23
Wednesdays.
You
see
that,
after
1989
at
this
site
the
24
concentrations
of
ozone
on
average
have
been
significantly
25
higher
on
weekends.
We
can
go
to
the
next
slide.

68
1
CHAIRMAN
DUNLAP:
Sir,
I
want
you
to
relate
2
this
back
to
what
we
are
considering.
Do
you
like
the
3
regulatory
proposal
staff
has,
or
it's
going
to
hurt
your
4
scenario?
What
do
you
want?
You
want
us
to
be
smarter.
I
5
respect
that.
What
is
the
bottom
line?

6
TILL
STOECKENIUS:
The
bottom
line
here
is
7
to
show
you
what
is
happening
in
a
real­
world
experiment
8
where
you
are
reducing
NOx.
We
know
the
LEV
II
standards
9
are
very
NOx
heavy
in
terms
of
amount
of
emission
10
reductions
that
are
occurring.
Here
is
a
case
that
we
11
experience
every
week,
where
we
are
reducing
NOx
12
significantly,
and
look
what
is
happening
to
ozone.
This
13
is
a
correlation.
It's
not
a
cause­
and­
effect
14
relationship,
but
it
is
rather
compelling.
And
that's
why
15
I
came
here
today
to
present
it.

16
CHAIRMAN
DUNLAP:
What
would
you
have
us
do
17
relative
to
this
proposal?

18
TILL
STOECKENIUS:
I'm
not
here
to
suggest
19
one
way
or
the
other,
sir,
on
what
you
would
do
here
today.

20
CHAIRMAN
DUNLAP:
Just
be
aware
of
what
is
21
happening,
what
we
are
pushing
to
the
weekends,
and
perhaps
22
our
regulatory
actions
are
taking
us
somewhere
that
is
23
inadvertent.

24
TILL
STOECKENIUS:
That's
correct.

25
CHAIRMAN
DUNLAP:
In
conclusion,
you
wanted
69
1
us
­­
is
that
it?

2
TILL
STOECKENIUS:
That
is
my
conclusion.
I
3
think
you
made
it
very
well.

4
CHAIRMAN
DUNLAP:
I
appreciate
your
taking
5
the
time.
If
you
can
leave
this,
I'll
ask
staff
get
copies
6
of
this.
If
you
don't
mind,
leave
it
with
us
and
we
will
7
have
a
chance
to
peruse
it.
Okay.

8
I
guess
this
gentleman
has
come
some
9
distance
to
be
with
us.
Mr.
Kenny,
any
message?
Any
10
interpretive
message
relative
to
the
regulatory
proposal?

11
MR.
KENNY:
Well,
I
think
what
he's
12
basically
trying
to
propose
to
the
Board
is
that
the
13
Board's
present
proposal
is
before
the
Board
today
from
the
14
staff,
which
does
have
a
fair
amount
of
NOx
reductions
in
15
it
is,
in
their
view,
inappropriate,
and
we
would
disagree.

16
Actually,
if
you'd
like
to
have
some
discussion
about
the
17
science,
we
do
have
technical
experts
here
who
can
provide
18
responses
to
that.

19
CHAIRMAN
DUNLAP:
We
will
come
back.
Tom,

20
I'll
just
ask
you
guys
to
facilitate
on
this
presentation
21
toward
the
end
of
the
witnesses.
Mr.
Calhoun?

22
MR.
CALHOUN:
Mr.
Chairman,
I've
discussed
23
this
extensively
with
Dr.
Holmes
and
a
few
others,
and
24
there
are
other
reports
out
which
intended
to
show
the
same
25
things.
So
what
I've
encouraged
our
staff
to
do
­­
I'm
not
70
1
sure
who
is
right
or
who
is
wrong
here.
There
is
a
lot
of
2
uncertainty,
at
least
some
questions.
Let
me
put
it
that
3
way.
So
what
I've
encouraged
our
staff
to
do
is
get
4
together
with
the
other
interested
stakeholders
­­
like
5
EPA,
the
environmentalists,
and
the
auto
people
­­
and
take
6
a
real
good
look
at
this.

7
NOx
control
is
needed
for
other
purposes.

8
What
impact
does
the
NOx
control
have
on?
If
it
adversely
9
effects
ozone
and
you
still
need
it
for
NOx,
what
is
the
10
end
game
like?
And
I
think
this
is
something
we
need
to
11
take
a
look
at,
and
that's
what
I've
encouraged
our
staff
12
to
do.

13
CHAIRMAN
DUNLAP:
Joe,
I
think
that
the
14
Board
certainly
sat
through
­­
I
can
remember
three
or
four
15
times
in
the
last
four
years
we
have
had
presentations
16
about
transport,
time
of
day,
emissions,
inventories,
work
17
that's
been
going
on
that
Supervisor
Patrick
worked
on
in
18
the
San
Joaquin
Valley.
So
there
is
a
lot
of
action
here,

19
and
it's
positive.

20
We
are
learning
more
all
the
time.
But
21
having
said
that,
I
mean,
we
have
a
regulatory
proposal
22
before
us
that
is
reducing
emissions,
and
it's
going
to
do
23
that,
we
believe.
That's
why
we
are
talking
about
it.
At
24
the
same
time,
if
there
are
inadvertent
or
consequences
25
that
we
are
not
sure
of,
we
need
to
get
those
on
the
table
71
1
and
deal
with
them.
So
that's
why
I'm
going
to
ask
staff
2
at
the
end
to
talk
about
this
a
bit.
But
this
should
not
3
drive
­­
I
don't
want
this
kind
of
technical
discussion
to
4
drive
deliberation
today
on
the
merits
of
this
regulatory
5
proposal.
Good
point,
Joe.
We'll
come
back.

6
Kelly
Brown
from
Ford,
Matt
Kevnick
from
7
Toyota,
and
Charlie
Kitz
from
Chrysler,
and
Sam
Leonard
and
8
his
colleague
Kevin
Cullen
I'll
ask
to
come
up.
Kelly?

9
KELLY
BROWN:
You
don't
want
us
all
up
here
10
at
once,
I
assume.
It
would
be
a
cozy
scene.

11
CHAIRMAN
DUNLAP:
By
the
way,
I'll
12
acknowledge
I've
appreciated
­­
and
I'll
say
the
same
to
13
Sam
­­
how
seriously
you
all
are
taking
this.
I
know
this
14
is
a
big
market
for
you,
and
I
certainly
will
subscribe
to
15
the
best
motives
relative
to
your
advocacy.
I
know
you're
16
worried
about
this,
and
you've
devoted
a
lot
of
time
and
17
attention
to
that,
and
we
respect
that.

18
KELLY
BROWN:
Thank
you.
If
somebody
could
19
dim
the
lights,
whoever
the
chief
engineer
of
lighting
is.

20
Mr.
Chairman
and
Members
of
the
Board,
my
21
name
is
Kelly
Brown.
I'm
director
of
vehicle
environmental
22
engineering
for
Ford
Motor
Company.
Ford
is
committed
to
a
23
role
of
providing
continued
reductions
in
emissions.
And
24
before
we
go
on
to
the
rest
of
the
discussions
here
this
25
afternoon,
one
of
the
unfortunate
things
that
always
72
1
happens
at
a
hearing
is,
when
you
still
have
problems
with
2
the
rule
even
though
they
may
be
minor
compared
to
the
3
large
number
of
areas
you
agree
with
the
staff,
you
spend
4
all
your
time
focusing
on
the
negative.
And
I
thought
5
before
we
do
that,
I'd
spend
a
little
time
focusing
on
the
6
positive.

7
Ford
was
the
first
company
to
produce
8
vehicles
that
met
California's
super­
ultra­
low
emission
9
vehicle
standards.
Shown
here
is
a
1997
natural
gas
F250
10
pickup
truck
and
also
the
Econolines,
many
of
which
are
in
11
service
in
the
state
of
California.
Ford
has
been
a
leader
12
in
sales
of
vehicles
that
operate
on
cleaner
fuels,
such
as
13
CNG
and
also
on
ethanol.

14
Beginning
with
the
1999
model
year,
Ford
15
voluntarily
made
all
of
its
sport
utilities
comply
with
the
16
low­
emission
vehicle
standards,
not
only
in
the
state
of
17
California
and
the
states
that
have
adopted
them,
but
18
across
the
US
and
Canada.
So
trucks,
like
shown
here
the
19
Explorer,
the
Expedition
the
much
touted
Expedition
­­
the
20
staff
did
a
really
nice
job
on
the
tires
on
the
ones
out
21
there.
I
wish
they
would
have
gotten
the
ding
out
of
the
22
bumper
­­
and
the
Navigator,
all
are
low­
emission
vehicles
23
across
the
country.
And
as
you've
heard
and
you'll
24
probably
continue
to
hear
throughout
the
day,
we
have
all
25
been
flattered
and
have
the
dubious
honor
of
the
staff
73
1
picking
our
vehicles,
because
they
are
so
much
cleaner,
as
2
their
test
bed
for
this
rule
making.
And
in
fact,
if
I
3
didn't
fear
for
my
life,
I'd
probably
say
we
are
probably
4
the
biggest
cause
of
why
we're
here
today.

5
Further,
the
1999
Ford
Windstar
is
certified
6
as
a
ULEV
in
California
and
also
will
be
sold
that
way
7
across
the
US
and
Canada.
Even
though
we
produce
some
of
8
the
cleanest
vehicles
available
today,
Ford
continues
to
9
look
towards
the
challenges
of
doing
even
more
in
10
California.
And
as
I
mentioned,
we
agree
with
the
11
overwhelming
portion
of
what
the
staff
has
put
forth
and,

12
in
some
cases,
we
have
even
suggested
going
further
from
13
the
staff's
suggestion.

14
However,
since
California
vehicles
have
the
15
highest
or
the
toughest
emission
standards
in
the
world,

16
it's
important,
before
setting
those
standards,
that
ARB
17
realizes
what
these
technology
levels
are
and
evaluate
the
18
amount
of
incremental
benefits
and
risks
where
we
are
in
an
19
unknown
area.
And
you've
also
heard
today
we
are
going
to
20
be
dealing,
and
we
are
dealing,
a
lot
in
the
area
of
21
unknowns.
Yes,
the
Ford
Expedition
is
very
clean.
A
few
22
years
back,
I
don't
think
anybody,
even
the
staff,
would
23
have
predicted
that
we
would
have
gotten
it
down
to
those
24
low
levels.
We
did
so,
by
the
way,
without
regulation.

25
Those
are
well
­­
they
are
certified
at
about
a
quarter
of
74
1
the
level
required
by
the
standards
they're
certified
to.

2
To
take
on
some
of
the
concerns
that
we
had,

3
we
worked
with
some
of
our
competitors
to
try
and
develop
a
4
proposal.
It
was
addressed
by
the
staff
in
their
staff
5
report
and
briefly
here
this
morning.
I'm
not
going
to
go
6
through
all
of
these
numbers,
but
this
is
a
cleaned­
up
copy
7
of
several
literations.
We
have
gone
back
and
forth
with
8
the
staff
as
an
industry
to
try
and
come
to
an
area
where
9
we
felt
comfortable
that
we
wouldn't
have
product
10
disruptions
and
we
wouldn't
have
severe
consequences
if
we
11
failed
to
develop
the
needed
technology
to
make
up
the
12
shortfalls
from
where
we
are
today
to
where
the
staff
would
13
like
us
to
be.
And
I
won't
go
through
that.
We
can
go
14
through
it
again
if
you
want,
but
I
think
the
staff
15
outlined
their
comments.

16
All
I
can
say
is
we
tried
to
make
in
this
17
latest
document
the
fewest
number
of
changes
we
could
to
18
the
staff
proposal
and
still
felt
comfortable
that,
even
19
though
there
is
a
considerable
unknown
in
some
of
these
20
numbers,
that
it
was
something
we
could
go
forward
with.

21
CHAIRMAN
DUNLAP:
Kelly,
could
I
offer
a
22
suggestion?

23
KELLY
BROWN:
Sure.

24
CHAIRMAN
DUNLAP:
And
I
know
you
want
to
25
paint
a
picture
here,
I'm
sure,
and
talk
about
your
75
1
position.
But
I
would
be
grateful
if
you
would
focus
on
2
the
three
or
four
key
issues
that
remain
as
you
see
it
so
3
we
can
have
a
robust
discussion
about
that.

4
But
again,
I
don't
want
to
shortchange
you
5
relative
to
talking
about
a
bigger
vision.
So
if
you
can
6
focus
on
those
key
things,
we
will
have
a
back
and
forth
on
7
that,
and
I
think
it
will
be
productive.

8
KELLY
BROWN:
I'll
skip
through
these
then
9
and
highlight
that
we,
even
with
the
industry
proposal,
we
10
would
achieve
all
of
the
requirements
of
the
M2
box
and
11
also
59
tons
per
day
or
a
majority
of
what
is
required
out
12
of
the
black
box,
and
that
was
not
just
assigned
to
us
but
13
assigned
to
everybody.

14
Also
­­
and
I
think
this
is
a
key
point,

15
Mr.
Chairman,
that
we
agree
that
all
of
the
passenger
cars
16
in
the
white
part
of
the
pie,
all
of
the
trucks
in
the
blue
17
part
of
the
pie
­­
including
our
Expedition
or,
excuse
me,

18
our
Explorer,
Mountaineer,
our
Villager,
our
Windstar,

19
minivans,
Ranger
pickup
trucks
­­
agree
with
the
staff
and,

20
in
fact,
have
suggested
further
tightening.

21
The
area
of
concern
I
think
with
all
the
22
manufacturers
that
operate
is
in
the
yellow
area,
and
it
23
comprises
about
15
percent
of
the
total
vehicles.
And
even
24
there,
we
are
not
saying
do
nothing.
We
are
saying
we
25
can't
go
quite
as
far
quite
as
fast
as
what
the
staff
has
76
1
said.

2
CHAIRMAN
DUNLAP:
Can
I
ask,
Kelly,
on
that
3
point
­­

4
KELLY
BROWN:
This
isn't
coming
off
my
time,

5
is
it?

6
CHAIRMAN
DUNLAP:
No.
Talk
to
us
about
­­

7
and
I
think
the
staff,
I
would
hope
they
are
perceived
as
8
fair
on
this
­­
the
15­
percent
number.
Why
do
you
think
­­

9
obviously,
I
know
that's
the
toughest
nut
to
crack
for
you
10
guys,
but
why
do
you
think
it
can't
be
done?
Talk
a
bit
11
about
some
of
the
barriers
that
you're
having
in
seeing
12
your
way
there.

13
KELLY
BROWN:
First
of
all,
I've
learned
in
14
the
years
I've
done
this
­­
the
first
time
I
testified
15
before
this
Board,
Barry
Nichols
had
your
job
­­
I've
16
learned
to
stop
saying
never.
It's
not
in
my
vocabulary,

17
at
least
for
the
day.
What
I
can
tell
you
is
today
we
have
18
very
serious
concerns
about
being
able
to
meet
the
LEV,

19
ULEV,
and
certainly
the
super­
ULEV,
especially
for
the
20
larger
trucks
to
the
right
that
have
the
biggest
trailing
21
tow
capability
which
usually
means
you
put
a
taller
axle
22
and
bigger
engine
and
everything
on
it,
more
weight,
plus
23
the
engine
operates
at
higher
speeds
through
the
catalyst.

24
Those
are
our
biggest
concerns,
and
it's
25
those
features
that
cause
us
to
drive
that.
Typically,
the
77
1
debate
between
us
and
the
staff
is
they
say,
"
We
understand
2
that,
but
people
don't
use
them
that
way
all
the
time."

3
And
our
response
is,
"
But
if
we
sell
them
the
vehicle
that
4
has
that
capability,
when
they
do
want
to
use
it,
it
has
to
5
perform
to
that
capability."
And
I
think
that
is
where
the
6
debate
really
focuses.

7
CHAIRMAN
DUNLAP:
So
the
argument
they
may
8
not
tow
the
boat
every
day,
but
once
a
month
when
they
do,

9
they
need
to
be
able
to
do
it
is
your
argument.

10
KELLY
BROWN:
Correct.
Skip
through
that.

11
We
really
did
it.
This
chart
here
talks
­­
the
boxes
in
12
the
corner
show
where
we
would
have
to
get
for
NOx
and
13
hydrocarbons
in
order
to
comply.
I'm
trying
to
find
the
14
arrow.
For
example,
this
is
the
LEV
II
hydrocarbon.
This
15
is
the
LEV
II
NOx.
In
order
to
comply
with
that
standard,

16
you
have
to
get
inside
the
box.
In
order
to
avoid
a
recall
17
or
actually
have
them
perform
in
use,
that
is
what
we
have
18
to
sign
up
to.

19
We
have
internal
targets
which
are
generally
20
about
up
on
these
kinds
of
numbers,
roughly
half
of
the
21
standard.
So
for
development
purposes
for
a
Ford
22
calibrator
to
have
to
sign
off,
if
you're
signing
off
to
23
this
standard,
you
wouldn't
sign
off
if
the
test
data
were
24
right
there.
The
test
data
has
to
be
down
in
the
small
box
25
that
I'll
show
you.

78
1
This
is
some
of
the
data
the
CARB
has.
This
2
is
the
first
CARB
data.
Then
later
data
on
one
of
our
3
Expeditions,
we
tried
some
using
a
similar
catalyst.

4
Again,
we
are
all
around
the
outside
of
the
box.

5
Eventually,
the
latest
data
that
Mr.
Calhoun
and
Steve
Albu
6
were
discussing,
they
got
some.
They
got
a
few
data
points
7
down
in
the
corner
of
the
box
here,
which
would
give
you
8
some
comfort.
But
for
a
Ford
calibrator,
it's
still
not
in
9
the
area
to
have
what
we
call
sign­
off
level
data,
and
it's
10
nowhere
near
the
ULEV
and
SULEV.

11
So
what
would
you
say
about
that?
You'd
say
12
with
some
time,
we
probably
have
a
chance
on
the
Ford
13
vehicles
of
getting
the
data
down
into
this
part
of
the
14
box,
but
it's
going
to
take
some
work
and
some
effort
and
15
there
is
risk,
based
on
the
timetable,
that
we
may
not
make
16
that.

17
CHAIRMAN
DUNLAP:
On
that
point,
one
of
the
18
things
that
I've
been
proud
of
the
staff
for
recommending
19
the
Board
­­
and
we've
embraced
it
­­
are
these
technology
20
review
processes,
you
know,
that
we
go
through
­­
we've
21
done
it
with
ZEVs
and
other
things
­­
where
every
couple
22
years
we
will
take
a
hard
look
with
you,
you
know,

23
arm­
in­
arm
looking
at
the
data,
figuring
out
where
we
are.

24
How
does
that
set
with
you,
us
adopting
the
25
proposal
like
it
is,
agreeing
to
this
technology
review,

79
1
looking
at
the
data
with
you,
assessing
where
we
are
at.

2
And
if
things
need
to
be
changed,
changing
it
down
the
3
road,
but
setting
a
tough
standard,
which
you
yourself
said
4
you
don't
say
never.
But
you
know
what
I'm
saying,
Kelly?

5
Is
there
a
way
for
us
­­

6
KELLY
BROWN:
It's
a
risk,
Mr.
Chairman.
If
7
it
was
SULEV
that's
out
a
few
years,
I'd
say
yes.
Put
that
8
down
as
a
research
objective
if
that's
what
you
want
us
to
9
shoot
for.
That
gets
us
working
in­
house.
This
one
here,

10
we
are
a
little
closer
to
being
in
the
box
at
Ford
now.

11
But
the
timetable,
these
are
the
ones
you
have
to
do
12
first.
So
it's
a
trade­
off
between
how
much
work
do
you
13
have
to
do
and
how
much
time
do
you
have
to
do
it,
and
14
that's
what
we
tried
to
reflect
in
our
proposal.

15
The
balance
between
us
and
the
staff,
we
try
16
to
push
it
out
a
little
further
and
give
ourselves
in
the
17
early
part
a
bigger
margin,
and
we
accepted
in
return
a
18
tougher
ultimate
standard.

19
CHAIRMAN
DUNLAP:
Okay.

20
KELLY
BROWN:
Again,
here
is
the
example.

21
That
is
the
CARB
data
where
it
is
now.
In
the
blue
box
in
22
the
corner
is
where
a
Ford
engineer
has
to
get
that
in
23
order
to
get
sign­
off
and
release
the
calibration.

24
CHAIRMAN
DUNLAP:
On
that
sign­
off,
that's
25
typical
practice
within
Ford.
I
mean,
you
guys
want
that
80
1
below
the
standard
sufficiently
so
you're
protected
from
2
recall.

3
KELLY
BROWN:
We
used
to
have
a
very
bad
4
in­
use
track
record,
and
I
think
the
staff
will
admit
we've
5
cleaned
it
up
a
lot,
and
that
is
how
you
do
it.

6
CHAIRMAN
DUNLAP:
So
the
bottom
line
for
you
7
there,
just
so
I
get
it,
is
that
you're
concerned
about
8
going
along
with
this
new
standard
because
you
can't
9
guarantee
you
can
get
there
and
you're
going
to
put
your
10
company
at
risk
if
you
fail.
That's
the
bottom
line;

11
right?

12
KELLY
BROWN:
Yes.
I
can't
come
up
here
and
13
you'd
never
have
enough
data
to
prove
you
can't
do
14
something.
What
you
can
say
is
we
have
got
the
best
15
technology
available
today
sitting
right
out
there
with
16
those
dirty
jet
skis
behind
it.

17
With
that
I
think
I'd
stop
before
I
get
the
18
hook,
and
I'd
like
the
opportunity
to
answer
your
19
questions.

20
CHAIRMAN
DUNLAP:
Okay.
All
right.
I
have
21
a
handle
on
what
is
at
issue
with
your
company,
a
big
22
ticket
issue.

23
Ron,
do
you
have
a
question?

24
SUPERVISOR
ROBERTS:
Just
a
quick
question.

25
The
problem
with
the
largest
trucks
that
you
referred
to,

81
1
you
went
through
that
quickly,
and
I'm
unsure
what
will
2
those
­­
what
are
some
examples
of
largest
trucks
you're
3
having
problems
with?

4
KELLY
BROWN:
The
larger
vehicles,
not
just
5
because
they're
large,
because
of
the
capabilities
they
6
have
like
trailer
tow.
When
people
order
trailer
tow,
they
7
get
a
heavier
suspension.
It
adds
weight
to
the
vehicle.

8
They
get
a
different
rear­
axle
ratio
so
that
you
can
tow
9
heavy
loads
so
you
can
get
the
big
trailer
moving
from
a
10
dead
stop.
That
causes
the
engine
to
operate
at
a
higher
11
speed
and
put
more
exhaust
flow
through
the
catalyst.
So
12
it's
tougher
to
get
the
efficiency
under
that
operation.

13
We
also
have
to
protect
the
catalyst
from
14
temperature,
and
that's
why
we
worry
a
little
bit
about
15
using
the
air
strategy,
the
air
injection
strategy,
that
16
the
staff
would
use.
I
wouldn't
say
we'd
rule
it
out,
but
17
that
would
be
our
last
resort
because,
when
you
put
that
in
18
too,
you
run
the
risk
of
aging
the
catalyst
faster.
In
19
order
to
achieve
any
of
these
standards,
you
have
to
keep
20
the
catalyst
at
almost
brand­
new
condition.
When
we
age
21
it,
we
have
to
make
sure
that,
when
it's
out
at
120,000
22
miles,
it's
still
almost
as
efficient
as
when
it
was
new.

23
When
we
first
put
catalysts
on
vehicles,
we
24
were
happy
if
it
was
80
percent
at
50,000
miles.
Now
we
25
have
to
be
in
the
high
90'
s
or
else
we
fail.
So
not
82
1
insulting
the
catalyst
is
the
biggest
risk
we
have.

2
CHAIRMAN
DUNLAP:
Mr.
Parnell?

3
MR.
PARNELL:
Kelly,
about
the
argument
that
4
in
the
event
you
meet
the
standards
that
staff
has
proposed
5
on
some
vehicles,
that
will
push
the
marketing
into
heavier
6
vehicles
so
that
the
job
can
actually
be
done
­­
do
you
7
have
any
comment
about
that,
whether
it
changes
the
dynamic
8
of
what
actually
happens
in
the
market
and
how
that
might
9
affect
air
quality?

10
KELLY
BROWN:
You
mean
if
we
don't
offer
the
11
types
of
vehicles
like
an
Expedition,
how
many
people
would
12
go
to
a
bigger
vehicle?
Is
that
the
question?

13
MR.
PARNELL:
I'm
not
talking
about
not
14
offering,
but
I
think
it
was
suggested
by
Kelly
earlier,
or
15
who
testified?
I
think
it
was
the
Chamber's
testimony
16
that,
in
the
event
these
cars
had
to
meet
the
standard,
it
17
could
affect
the
performance
and,
therefore,
you
may
push
18
people
who
might
otherwise
buy
these
cars
into
bigger
19
heavier
vehicles
and
thus
affect
overpowering.

20
Do
you
have
a
sense
of
that?

21
KELLY
BROWN:
To
me,
we
learned
a
lesson
22
about
drivability.
If
it
doesn't
drive
right,
we
just
23
won't
release
it.
The
bigger
risk
would
be
that
you'd
24
limit
trailer
tow.
If
the
full
trailer
tow
package
caused
25
you
to
put
in,
I
think
we
put
on
373
axle.
If
you
couldn't
83
1
calibrate
that
and
you
drop
the
axle
ratio
down
to
do
that,

2
you'd
restrict
the
amount
of
trailer
tow.
And
one
of
the
3
things
that
has
happened
through
the
years
as
we
did
that
4
on
cars,
people
went
to
light
trucks,
as
we
called
light
5
trucks
used
to
be
up
to
6,000
pounds.
Then
it
got
moved
to
6
8,500.

7
Some
people,
if
you
do
take
away
an
axle
or
8
something
that
it's
what
they
need
to
get
their
trailer
9
tow,
you
might
move
somebody
out
of
an
F150
or
250
into
a
10
F350
or
something
like
that,
a
much
bigger
truck.
They
11
keep
chasing
it.
That
has
happened.

12
CHAIRMAN
DUNLAP:
Dr.
Friedman?

13
DR.
FRIEDMAN:
Mr.
Brown,
you
showed
us
by
14
your
overlays
the
progressive
improvement
that
you're
15
achieving.
I
need
to
know
about
the
time
course
between
16
what
currently
exists,
a
couple
of
points
in
the
lower
17
optimal
box,
and
the
one
before
that?
What
is
the
duration
18
between
those?

19
KELLY
BROWN:
Of
the
data
set,
most
of
these
20
were
run
pretty
quickly.
Probably
in
the
last
six
to
eight
21
months,
Steve?

22
STEVE
ALBU:
About
six
to
eight
months.

23
DR.
FRIEDMAN:
So
in
the
last
six
months,

24
improvement
between
the
next
to
the
last
and
the
last?

25
KELLY
BROWN:
We
didn't
go
through
our
full
84
1
development
and
all
that
and
make
sure
it
was
okay
and
the
2
catalyst
temperatures
were
all
right.
We
were
trying
to
3
work
with
the
staff.

4
CHAIRMAN
DUNLAP:
Supervisor
Roberts?

5
SUPERVISOR
ROBERTS:
Kelly,
one
more
6
question.
The
Chamber
made
a
statement
that
the
vehicle
7
costs
could
increase
by
as
much
as
$
7,000
per
year.
Is
8
that
something
you
would
strongly
associate
yourself
with?

9
That
number,
is
that
something
that
you're
wondering
where
10
they
got
it?

11
KELLY
BROWN:
I
think
and
it's
always
risky
12
to
guess
what
somebody
elses
number
is
­­

13
SUPERVISOR
ROBERTS:
I'm
wondering
if
14
somehow
you
would
have
made
that
same
projection?

15
KELLY
BROWN:
I
would
hope
if
we
got
up
to
16
$
7,000
on
gasoline­
powered
products,
and
I
realize
there
17
may
be
a
different
board
when
we
have
to
come
back
and
ask
18
them
to
fix
some
things
that
you
might
do
today
­­
it
19
wasn't
a
shot.
It's
a
risk.
It's
a
fear
in
my
mind.

20
CHAIRMAN
DUNLAP:
So
how
are
we
looking,

21
Kelly?

22
KELLY
BROWN:
I'll
call
you
in
a
couple
of
23
years.
I
lost
my
train
of
thought
now.

24
SUPERVISOR
ROBERTS:
The
question
is
how,

25
representing
your
company,
do
you
associate
yourself
85
1
strongly
with
that
$
7,000?

2
KELLY
BROWN:
The
$
7,000
would
be
a
good
3
cost,
not
necessarily
price,
but
a
good
cost
for
the
4
natural
gas
vehicles
that
I
showed
in
there.
It's
mainly
5
tank
cost.
We
are
trying
to
promote
those
sales;
so
we
6
don't
charge
all
that.
We
take
some
of
that
out
of
our
7
profit,
but
the
natural
gas
SULEV
pickup
trucks,
$
6,000
to
8
$
8,000
is
probably
a
good
tank
price.

9
SUPERVISOR
ROBERTS:
I
guess
maybe
as
I
10
understand
this,
this
was
a
suggestion
as
to
what
it
might
11
cost
us
to
not
necessarily
go
to
natural
gas
but
to
use
a
12
regular
gas.
Would
you
expect
that
it's
going
to
cost
13
$
7,000
a
unit?

14
KELLY
BROWN:
On
gasoline?
I
don't
know
15
what
­­
if
I
was
going
to
spend
$
7,000
on
gasoline,
I
think
16
I'd
put
it
into
something
else.

17
SUPERVISOR
ROBERTS:
Okay.

18
CHAIRMAN
DUNLAP:
Okay.
Kelly,
I
think
19
that's
it.
Thank
you.
I
appreciate
it.
Sorry
to
make
you
20
readjust
there,
but
it
helped
us
focus.

21
KELLY
BROWN:
Thank
you
and
good
luck
on
22
your
last
hearing.

23
CHAIRMAN
DUNLAP:
Thank
you.
Matt
Kevnick
24
from
Toyota,
and
then
I'm
going
to
­­
not
that
we
are
25
dragging
or
anything,
but
we
need
to
pick
it
up
a
little
86
1
bit.
I've
got
a
few
witnesses
that
have
got
some
time
2
pressure.
I'm
going
to
ask
for
some
of
the
others
to
yield
3
to
them.
So
I'm
going
to
ask
Manuel
Cunha
and
I
think
4
Peter
Welch
if
they
are
around
close
to
come
up
here.
I'll
5
let
them
get
up
there
because
of
time
pressure.

6
MATT
KEVNICK:
Understood.
I'll
be
brief,

7
Mr.
Chairman.

8
CHAIRMAN
DUNLAP:
Okay.

9
MATT
KEVNICK:
My
name
is
Matt
Kevnick.
I
10
am
a
certification
regulatory
manager
for
Toyota
out
of
11
Ann
Arbor
office,
but
I'm
speaking
on
behalf
of
AMA
and
12
AIM.
And
I'd
like
to
address
a
few
comments
regarding
the
13
LEV
II
evaporative
emission
proposal.

14
We
appreciate
the
opportunity
to
continue
to
15
work
with
staff
through
the
development
of
this
evap
16
proposal
and
would
very
much
appreciate
the
opportunity
to
17
continue
to
do
that.
And
I'd
also
like
to
publicly
thank
18
CARB
with
tongue­
and­
cheek
also
for
giving
Toyota
the
19
recognition
of
having
outstanding
systems.

20
They
have
used,
as
we
heard
this
morning,

21
the
Camry
and
vehicles
as
part
of
their
benchmarking
study
22
for
determining
evap
standards.
But
the
message
I'd
like
23
to
bring
today,
which
is
analogous
to
this
picture,
is
that
24
while
today's
evap
proposal
affects
more
than
just
two
or
25
three
star
performers,
it
affects
our
full
product
lineup
87
1
as
well
as
the
rest
of
the
class,
our
competitors
as
well.

2
First
a
little
background.
And
don't
panic,

3
I'm
not
going
to
go
through
this
chart.
What
I
really
4
liked
to
point
out
is
that
Toyota
approves
their
evap
5
system
design
from
a
systems
approach,
and
fundamentally
6
all
our
systems
are
alike
across
our
lineup.
The
main
7
thing
I
want
to
say
here
is
that,
from
technology
8
standpoint,
we
employ
what
we
feel
is
probably
the
best
9
technology
capable
for
these
systems.

10
So
how
good
are
our
systems?
This
chart
11
here
is
a
representation
of
the
Toyota
certification
data
12
for
1998
model
year.
And
if
you
could
kind
of
focus
on
the
13
left
side
of
the
chart,
for
this
is
data
for
the
current
14
2
gram
enhanced
evap
system
standard.
And
as
is
typical,

15
we
employ
a
50­
percent
compliance
margin
or
headroom
margin
16
and
come
up
with
a
design
target
of
the
1
gram.
The
17
clustered
dots
you
see
below
that
is
our
actual
data
from
18
our
certification
vehicles,
and
a
couple
models
are
pointed
19
out
­­
the
SC300
being
the
bad
guy,
I
guess;
and
the
star
20
performers
shown
below,
the
Camry
and
the
Corolla.

21
If
you
then
direct
yourself
to
the
right
22
side
of
the
chart,
the
dark
line
is
the
.5
gram
standard
23
that
CARB
is
currently
proposing.
While
if
we
approach
it
24
as
we
do
today,
the
design
target
is
shown
by
the
dotted
25
line.
And
what
you're
basically
asking
us
to
do
is
take
88
1
our
range
of
product
line
of
data
and
compress
it
into
that
2
small
area
shown
below
the
dotted
line
in
the
shaded
bar
3
shown
as
background.
And
I
might
point
out
that
the
range
4
where
if
you
took
an
electric
vehicle
and
tested
it,
that's
5
where
those
vehicles
would
fall
as
well.

6
Some
question
is
why
do
we
have
such
a
7
difference
among
our
product
lineup?
Well,
the
first
row
8
identifies
several
vehicles
that
we
had
seen
on
the
9
previous
chart,
and
second
row
is
the
actual
numbers.
The
10
Corolla
and
Camry,
the
star
performers;
and
the
bad
guy
in
11
the
far
right,
the
SC300.

12
You
begin
to
look
at
parameters
that
might
13
affect
evap
performance.
You
start
looking
at
what
is
14
different.
Well
gee,
there
are
some
subtle
differences,

15
but
nothing
really
strikes
us
as
being
significant
in
terms
16
of
things
we
might
want
to
figure
in
order
to
get
the
bad
17
guys
to
perform
like
the
star
performers.
What
I
really
18
want
to
say
here
is,
at
this
point,
we
are
really
not
sure
19
how
to
get
the
rest
of
our
lineup
to
look
at
the
star
20
performers.

21
But
without
ignoring
the
current
work
that
22
staff
had
done
and
throughout
discussions,
we
admit
that
23
their
data
we
agree
with.
There
are
some
potential
24
opportunities
for
improvement.
And
this
chart
kind
of
goes
25
through
some
of
the
things
in
terms
of
our
systems,
where
89
1
we
think
there
may
be
some
opportunity
for
improving
our
2
system.
Maybe
the
big
ticket
item
at
the
moment
that
comes
3
out
is
a
carbon
impregnated
air
filter,
something
that
ARB
4
staff
had
used
in
their
studies.
Some
of
the
things
we
5
have
already
adopted
into
our
system,
and
quite
frankly,

6
some
of
them
we
just
don't
see
as
production
feasible.

7
So
kind
of
in
summary
what
I'd
like
to
say
8
is
we
see
ARB
staff's
work
on
evap
as
a
good
starting
9
point.
We
don't
disagree
with
the
results
that
have
been
10
made
public,
but
we
don't
think
they
present
all
the
11
answers,
just
as
I'm
here
to
say
that
we
don't
think
we
12
have
the
answers
yet.
We
don't
feel,
frankly,
that
picking
13
one
or
two
star
performers
is
a
prudent
way
to
develop
14
standards
that
will
affect
the
rest
of
the
industry.
We
15
will
learn
more
as
we
gain
more
experience
with
developing
16
our
systems,
and
we
recognize
there
are
needs
to
continue
17
to
improve
our
systems.

18
However,
today
we
can't
say
how
we
are
going
19
to
get
there.
And
if
I
had
to
venture
a
guess,
trying
to
20
fit
our
product
lineup
into
that
small
region,
as
you
saw
21
in
the
other
chart,
might
even
suggest
we
may
be
forced
to
22
limit
our
vehicle
model
lineup
to
the
California
market.

23
Thank
you
very
much.

24
BARBARA
RIORDAN:
Let
me
thank
the
speaker
25
particularly
now
of
his
mindfulness
of
the
time.
Are
there
90
1
any
questions
by
the
Board
of
this
particular
speaker?

2
Seeing
none
­­

3
MR.
CALHOUN:
Are
you
aware
of
what
the
4
staff
did
in
order
to
meet
and
develop
their
evap
standard?

5
MATT
KEVNICK:
You
mean
the
work
they
had
6
done?

7
MR.
CALHOUN:
Yes.

8
MATT
KEVNICK:
We
worked
kind
of
closely
9
with
them
and
exchanged
information,
trying
to
explain
our
10
systems
and
technology.
So
we
have
had
a
pretty
good
11
understanding.

12
MR.
CALHOUN:
And
you
agree
with
the
numbers
13
they
came
up
with?

14
MATT
KEVNICK:
We
can
accept
the
numbers.

15
It's
a
matter
of
integration,
how
to
apply
them
to
our
16
future
product
line.

17
MR.
CALHOUN:
But
you're
not
sure
whether
or
18
not
you
can,
in
fact,
meet
that
number
that
they
propose?

19
MATT
KEVNICK:
Right.
Some
of
the
20
technologies
on
the
chart
that
we
showed
previously
21
suggested.
Those
bad
actor
is
the
kind
of
thing
that
staff
22
have
employed
in
some
other
studies.

23
BARBARA
RIORDAN:
Mrs.
Rakaw?

24
MS.
RAKAW:
Yes.
Your
statement
regarding
25
the
California
market,
can
you
tell
me
approximately
what
91
1
percentage
of
the
California
market
you
have?
Do
you
have
2
any
idea?

3
MATT
KEVNICK:
18
percent.

4
BARBARA
RIORDAN:
Mr.
Roberts?

5
SUPERVISOR
ROBERTS:
Mr.
Kevnick,
did
you
6
suggest
a
figure
of
$
7,000
additional
cost
per
each
vehicle
7
for
your
company?

8
MATT
KEVNICK:
No.

9
SUPERVISOR
ROBERTS:
Did
you
come
up
with
10
anything
like
that?

11
MATT
KEVNICK:
Quite
honestly,
no.

12
SUPERVISOR
ROBERTS:
We
will
find
who
did
13
it.

14
BARBARA
RIORDAN:
Thank
you
very
much.

15
MR.
CACKETTE:
Can
the
staff
make
one
16
comment
on
this?

17
BARBARA
RIORDAN:
Yes.

18
MR.
CACKETTE:
With
that
chart
up
there,

19
this
data
sort
of
bothered
us
when
we
first
saw
it,
and
we
20
have
gone
out
and
done
this
additional
vehicle
modification
21
and
testing
since
the
report
came
out.
The
two
things
I
22
want
to
point
out
is,
where
you
see
the
arrow
that
says
23
Camry
at
roughly
.4
and
the
one
we
tested
was
at
.5,
we
24
took
the
absolute
best
hosing
systems
and
seals
we
could
25
find
and
put
it
on
that
Camry.
It
was
at
.5.
And
when
we
92
1
were
done
testing,
it
was
at
.2.

2
Second
thing
is
we
went
out
and
got
­­
just
3
recently
last
week,
we
went
out
and
got
a
Lexus
and
brought
4
it
in.
And
we
were
trying
to
figure
out
why
did
the
5
Lexus
­­
it's
the
same
family
as
the
one
up
there
almost
at
6
1
­­
and
we
tested
and
it
came
at
.3
without
any
7
modifications.
It
looks
like
it's
got
a
good
system.
So
8
why
they
have
certification
data
which
I
think
is
what
is
9
shown
there
that
was
the
kind
of
high
flyer
did
not
agree
10
when
we
got
a
production
model,
a
rental
vehicle
and
11
tested.
It
was
much
lower,
much
nearer
the
standard.

12
So
I
don't
think
­­
there
is
still
some
13
mystery
as
to
why
that
specific
data
points
so
high,
but
I
14
don't
think
it
is
quite
as
mysterious
as
we
had
thought.

15
BARBARA
RIORDAN:
I
appreciate
that.
Thank
16
you
very
much.
We
are
going
to
go
on
to
Mr.
Charlie
Kitz
17
from
Chrysler.
And
in
recognition
of
time
issue,

18
Mr.
Welch,
you'll
be
next.

19
Would
you
like
the
lights
on?

20
CHARLIE
KITZ:
No,
that's
fine.
I
want
to
21
thank
the
Board
for
the
opportunity
to
represent
this
very
22
critical
issue,
and
can
we
have
very
comprehensive
23
testimony
that
has
been
prepared
and
provided
to
the
24
staff.
I'm
not
going
to
go
through
that
in
the
interest
of
25
time
today.
It's
here
on
the
disk.
We
are
going
to
have
93
1
to
flip
through
quick,
but
I
understand.

2
What
is
your
team,
first
of
all.
Let
me
3
just
state
broadly
that
Chrysler
is
supportive
of
the
4
California's
air
quality,
as
we
understand
that.
We
5
further
recognize
the
fact
that
the
industry
­­
of
Chrysler
6
in
particular
­­
is
going
to
have
to
be
a
major
player
in
7
terms
of
substantial
part
of
clearing
that
path,
and
we
8
accept
that
responsibility
willingly.

9
We
do
indicate,
however,
as
it's
been
said,

10
that
trucks
should
provide
some
greater
emission
reduction
11
and
also
that
trucks
should
provide
greater
reduction
in
12
the
how
soon
to
do
that
and
how
it's
done.
But
in
13
principle,
we
support
all
of
that.
In
addition,
I
just
­­

14
I
guess
we
are
not
there.

15
Let
me
just
continue
in
the
interest
of
time
16
that
there
are
three
things
that
Chrysler
would
like
to
17
talk
about
specifically
and
not
comments
that
are
redundant
18
that
were
said
before.
First
of
all
and
most
importantly
19
is
that
fuel
quality
must
be
improved
concurrent
with
the
20
emission
reductions.
We
are
saying
that
for
us
to
be
21
capable
of
achieving
these
low­
emission
standards,
we
have
22
to
have
the
fuels
at
the
same
time.
That's
absolutely
23
critical.

24
We
also
recognize
some
flexibility
has
been
25
provided
by
the
staff,
but
we
believe
more
is
required
­­

94
1
specifically,
that
we
be
allowed
plus
NOx
averaging
as
a
2
sum
and
also
that
the
optional
emission
standard
be
3
applicable
at
only
150,000
miles
only,
not
the
50
and
120
4
categories
and
also
to
receive
supplemental
fleet
average
5
and
credits
for
those
vehicles.

6
So
let
me
just
flip
right
on
through
to
the
7
end
of
the
fuel
quality.
I'll
just
do
a
very
quick
8
summary.
California
has
been
the
leader
in
the
advance
9
fuels,
and
we
recognize
that.
As
we
said,
further
10
improvements
in
fuel
quality
are
necessary
to
enable
11
compliance
with
either
the
ARB's
proposal
or
the
12
manufacturers'
alternative.
Whatever
proposal
is
adopted,

13
we
believe
fuels
are
necessary
so
that
we
request
the
Board
14
to
fuel
equality
in
aiding
manufacturers
to
comply
with
the
15
LEV
II
standards.
And
also,
as
we
said
earlier,
that
these
16
standards
precede
or
be
concurrent
with
the
availability
of
17
the
timeliness
of
new
standards.

18
I'm
going
to
pass
through
the
rest
of
the
19
fuel
comments.
You
only
want
what
is
very
critical.
What
20
I
wanted
to
talk
about
is
that
cars
themselves,
that
the
21
fuel
requirements
are
the
single
most
important
thing
in
22
terms
of
air
quality
that
they've
ever
achieved.

23
3.5
million
vehicles
off
the
road,
and
we
think
further
24
improvements,
therefore,
are
very,
very
critical.

25
They
said
there
is
no
single
measure
in
our
95
1
history
reduced
application,
but
a
larger
amount
in
such
a
2
brief
period
of
time
going
on
now
to
a
second
item.
That
3
is
partial
ZEF
credits.
As
you
know,
the
Air
Resources
4
Board
has
proposed
the
credits
for
very
low
emission
5
technologies
to
provide
flexibility
for
this
ZEV
mandate.

6
The
proposal
allows
manufacturers
to
produce
and
sell
7
electric
vehicle
substitutes.

8
Now,
we
think
these
are
laudable
goals
and
9
we
appreciate
the
flexibility
that
they
provide
but,

10
nonetheless,
we
should
have
serious
concerns.
First
of
11
all,
the
proposal
continues
sales
mandates
which
requires
12
manufacturers
to
sell
but
does
not
require
customers
to
buy
13
those
vehicles.
This
is
a
fundamental
principle
on
our
14
part.
We
cannot
pose
mandates
in
any
form
as
this
15
interferes
with
the
free
market.

16
The
second,
none
of
the
proposed
vehicle
17
substitutes
have
any
volume
sales
potential
by
the
2003
18
timetable
that
has
been
established.
Specifically,
here
is
19
a
chart
that
just
summarizes
will
these
things
have
sales
20
potential
of
a
technically
feasible
and
also
do
they
have,

21
more
importantly,
buyer
acceptance.
Will
people
buy
these
22
vehicles
in
the
volumes
that
are
projected,
and
I'm
not
23
going
to
go
through
all
the
details.

24
Some
people
will
put
yes
or
no
or
maybe,
but
25
fundamentally
none
of
these
are
ready
across
the
board
that
96
1
are
feasible
and
meet
all
customer
requirements.
That's
2
not
saying
that
we
don't
strongly
support
encouraging
3
advanced
technologies,
but
we
are
concerned
about
the
4
practicality
or
the
required
volumes
in
the
proposed
5
timetable.

6
Let
me
show
you
what
I
mean.
The
proposal
7
will
continue
to
have
at
least
4
percent
real
ZEVs
which
is
8
about
31,000
vehicles
a
year.
All
you
notice
on
the
9
footnote,
in
the
last
three
years
nationwide
there
has
only
10
been
less
than
23,000
vehicles
sold.
The
other
6
percent
11
of
the
10
percent
can
be
made
up
in
partial
credits.
They
12
can
do
the
division
for
what
the
partial
credits
are
for
13
that
6
percent.
This
says
that
we
will
need
fuel
cells
at
14
9
percent
of
California
volumes
or
around
68,000
units.

15
The
hybrids
would
have
to
be
available
to
16
be
sold
to
about
10
percent
of
the
public
at
almost
80,000
17
units.
And
the
SULEVS
at
15
and
30
percent
get
up
to
18
almost
250,000
units.
And
this
is
what
our
real
concern
19
is,
not
that
there
is
flexibility
provided,
but
is
it
20
realistic
to
expect
people
to
buy
these
vehicles
in
that
21
time
period.

22
And
the
most
important
thing,
of
course,
if
23
these
vehicle
sales
are
not
achieved,
you
do
not
receive
24
the
air
quality
benefit.
And
regarding
benefits,
I'd
like
25
to
make
one
last
point,
and
that
is
this
graph
shows
the
97
1
increased
benefit
from
the
ZEF
program
as
initially
2
conceived
under
LEV
I.
And
over
time,
the
reduction
3
becomes
more
and
more,
and
that
is
why
it
was
done.
It's
a
4
very
laudable
goal.

5
The
interesting
thing
is,
when
you
6
superimpose
the
LEV
II
standards,
the
benefit
from
the
ZEF
7
program
comes
down
to
1.6
tons
per
day
by
2010.
The
main
8
reason
is
you're
substituting
ZEVs
with
very,
very
low
9
SULEVS
and
other
vehicles.
In
fact,
SULEV
vehicle,
if
it's
10
driven
100,000
miles,
will
emit
one
pound
of
hydrocarbons
11
which
is
equivalent
to
spilling
a
pint
of
gasoline.

12
Now,
100,000
miles,
that's
over
eight
years
13
of
use,
and
you're
only
talking
about
one
pound
of
14
hydrocarbon.
And
that's
why,
if
we
get
to
those
kinds
of
15
levels
that
are
proposed
by
staff,
it
gets
very
problematic
16
as
to
whether
you
need
the
ZEF
program.
So
we
are
saying
17
we
would
remove
the
partial
­­
suggest
they
remove
the
18
partial
ZEF
credits
from
LEV
II
and
study
this
more
19
thoroughly.
I
don't
think
it's
necessary
to
be
part
of
the
20
LEV
II.
And
if
the
Board
should
address
air
quality
21
standards,
not
sales
mandates,
we
would
suggest
do
it
in
22
simple
terms,
is
intensify
some
of
these
advanced
vehicle
23
technologies
underneath
the
end
market
by
giving
multiple
24
credits
so
you
can
have
a
fuel
cell
hybrid
at
five
times
a
25
SULEV,
and
it
should
go
like
two
times
and
concentrate
on
98
1
just
the
air
quality
and
not
the
sales
mandate.

2
CHAIRMAN
DUNLAP:
We
will
talk
to
staff
and
3
wrap
up
about
their
idea
of
including
that
in
the
review.

4
CHARLIE
KITZ:
Very
quickly
passing,
there
5
is
something
in
the
report
about
vehicles
equipped
with
6
ozone
technology.
We
don't
think
this
makes
a
lot
of
sense
7
on
mobile.
You
make
more
sense
on
a
stationary
application
8
such
as
an
air
conditioner
that
is
operating
a
fan
all
day
9
long
on
top
of
a
building
or
something.
But
that
concludes
10
my
remarks.

11
CHAIRMAN
DUNLAP:
All
right.
Thank
you.

12
Any
questions
of
the
witness?
All
right.
Very
good.

13
Thanks.
I
understand.

14
Peter
Welch?
Peter
Welch
with
the
15
California
Motor
Car
Dealers'
Association.
He's
come
all
16
the
way
from
Sacramento
to
be
with
us
today.

17
PETER
WELCH:
Thank
you,
Mr.
Chairman,

18
Members.
Peter
Welch
with
the
California
Motor
Car
19
Dealers'
Association.
It's
a
statewide
trade
association
20
that
has
all
of
1,400
members.
We
collectively
employ
21
about
125,000
Californians.
Our
members
are
the
people
22
that
stock,
sell,
and
service
new
cars
of
all
line
makes.

23
There
are
currently
over
30,000
franchisers
that
franchise
24
our
members.

25
I'm
going
to
keep
my
comments
short.
I'd
99
1
like
to
answer
any
questions.
I'm
here
to
talk
about
2
market
concerns.
Nothing
more,
nothing
less.
We
do
not
3
obviously
design,
manufacture,
or
warrant
these
vehicles.

4
We
put
on
our
lots
what
people
want,
what
Californians
want
5
to
buy,
what
they
want
to
drive.

6
It's
interesting
to
note,
because
a
lot
of
7
people
don't
understand
the
distribution
chain,
but
we
are
8
actually
the
sole
purchasers
of
vehicles
from
the
auto
9
manufacturers.
We
buy
them.
We
put
them
on
our
lot.
And
10
we
only
buy
them
and
put
them
on
our
lots
in
number
and
11
variations
of
what
people
want
to
buy.
And
last
year,
we
12
sold
bumper
our
best
year
in
the
last
ten.
We
sold
over
13
1,582,000­
something
vehicles
and
yes,
43
percent
of
those
14
would
fall
under
the
category
of
trucks,
light­
duty
sport
15
utility,
and
so
on.

16
I
think
the
Board
has
done
a
pretty
17
remarkable
job
over
the
years
in
creeping
the
technology
18
into
the
cars
in
kind
of
a
seemless
kind
of
really
19
non­
transparent
method
for
consumers
have
been
able
to
go
20
out
there.
They
haven't
seen
any
noticeable
change
in
what
21
a
car
looks
like,
what
it
performs
like.
And
yes,
the
22
price
has
creeped
up
20,
30,
40,
50
bucks
here.
Consumers
23
have
been
able
to.

24
Where
we
have
hit
the
wall
with
the
25
consumers
are,
quite
frankly,
the
alternative
fuel
and
100
1
alternative
powered
vehicles.
Those
who
range
natural
gas
2
vehicles.
Again,
we
talked
about
cost,
and
the
3
differential
in
those
cars
are
in
the
$
5,000
to
$
10,000
4
range.
Electric
vehicles
haven't
caught
appeal
primarily,

5
again,
because
of
performance/
utility
and
the
consumers
6
perception
price
value.
They
have
not
counted
out
in
7
numbers.

8
We
would
like
to
see
them
buy
this
9
technology.
The
fact
of
the
matter
is
that
internal
10
combustion
engine
seems
to
be
the
most
price
valued
11
personal
transportation
unit
that
is
out
there,
and
that
is
12
what
people
go
for.
That
is
what
they
want
and
yes,
they
13
are
going
for
trucks
these
days.
The
bigger,
the
better.

14
I
know
that
in
many
circumstances
it's
kind
15
of
something
that
ought
to
be
banned.
They're
polluters.

16
They
are
killing
people
in
accidents.
But
that's
what
17
consumers
want.
They
want
big,
high­
riding
cars,
heavy
18
mass,
et
cetera.
We
can
point
our
fingers
to
fuel
cost
and
19
so
on.
I'm
not
here
to
do
that.
I'm
telling
you
what
20
they're
buying,
what
they
want,
and
when
they
hit
the
wall
21
with
respect
to
price.

22
Our
biggest
problem
right
now
on
the
market
23
is,
in
fact,
price
sensitivity.
The
average
price
of
the
24
car,
average
price
of
the
car
is
just
under
$
20,000
this
25
last
year.
We
are
hitting
the
price
wall.
Our
biggest
101
1
problem
in
getting
people
into
cars
is
qualifying
them
for
2
financing
and
keeping
them
in
the
car.

3
What
we
have
seen
in
the
last
three
or
four
4
years
is
a
phenomenon
that
I
haven't
seen
in
my
5
20­
something
years
­­
that
is,
manufacturers
are
starting
6
what
we
refer
to
as
decontent
the
car.
They're
starting
to
7
take
equipment
options
to
keep
the
car
under
$
20,000.
We
8
have
seen
some
major
vehicles
with
price
reductions
in
the
9
last
two
or
three
years.

10
So
we
get
very
sensitive
when
it
comes
to
11
the
price
increase.
I
don't
know
what
the
price
ultimately
12
is
going
to
be.
Your
staff,
over
the
years,
have
been
13
pretty
good
with
their
projections.
You're
in
the
$
215
14
range
average.
I
don't
think
it
takes
a
rocket
scientist
15
to
figure
out
that
a
car
that
weighs
7,000
or
8,000
pounds
16
and
has
heavier
engines
and
rear
ratios,
et
cetera,
et
17
cetera,
is,
using
my
math,
going
to
cost
twice
as
much
to
18
certify
as
a
car
that
only
weighs
3,000
or
4,000
pounds.

19
It's
a
matter
of
physics
with
regard
to
it.

20
When
we
take
a
look
at
price
sensitivity,

21
1­
percent
increase
in
price
usually
means
a
1
percent
22
decrease
in
the
volume
of
vehicles
that
are
sold.

23
Likewise,
if
you
reduce
the
price
1
percent,
general
rule
24
of
thumb,
there
are
a
lot
of
other
things
that
come
to
25
play.
We
can
see
increases
in
them.
$
215
increase
is
102
1
about
1­
percent
price
increase.
To
put
this
into
2
proportion,
I'm
sure
all
of
you
read
the
newspaper
about
3
our
big
stalemate
budget
fight
this
year
where
the
big
4
budget
issue
this
year
was
tax
reduction,
vehicle
license
5
fee
25­
percent
reduction.

6
The
whole
battle
this
whole
summer
is
46
7
bucks
a
person
is
the
average
reduction
we
have
seen
there.

8
That's
only
25
percent
of
what
we
are
looking
at
just
to
9
staff
average
here.
This
is
a
significant
price
increase
10
for
consumers,
and
it's
going
to
have
some
significant
11
ramifications
in
the
marketplace.
It
is
not
a
$
15
or
$
20
12
bump.

13
CHAIRMAN
DUNLAP:
What
year
are
these
14
numbers
going
to
play,
Tom?

15
MR.
CACKETTE:
Well,
the
standard
goes
into
16
play
in
2004.
I
just
want
to
point
out
a
couple
things.

17
Our
economic
analysis
uses
$
215
number
which
is
more
of
a
18
worse­
case
number,
as
the
staff
showed
the
number
as
$
107
19
as
the
range.
It
gets
into
$
200
for
the
bigger
one.

20
You're
right
in
terms
of
bigger
ones
will
be
­­

21
CHAIRMAN
DUNLAP:
It
sound
reasonable.

22
MR.
CACKETTE:
I'd
also
point
out
that
23
percentagewise,
that
percentages
will
be
about
the
same;
so
24
it
will
be
1
percent
on
that.

25
PETER
WELCH:
We
think
those
are
absorbable.

103
1
We
think
most
of
the
cars
are
in
the
$
90
range,
and
we
2
don't
pay
it
every
year.
Let's
be
honest.
But
it's
going
3
to
be
a
pop.
Our
concern
is
the
same
as
the
4
manufacturers'.
That's
the
6,000­
to
8,000­
pound
range.

5
We
think
that,
just
intuitively,
that
it's
going
to
be
500
6
bucks
or
something
in
that
range.
I
don't
know
what
it's
7
going
to
cost
out
in
2004
when
you
get
it
there,
but
it's
8
going
to
be
more
than
a
1­
percent
increase.

9
What
is
that
going
to
do?
It's
going
to
10
drive
people,
we
think,
into
bigger
cars.
If
you
own
a
11
$
30,000
boat
and
you
need
towing
capacity
to
take
it
over
12
to
the
lake
or
ocean
or
wherever
you
put
it
in
to
go
for
a
13
ride,
you're
going
to
buy
it.
You're
going
to
buy
an
older
14
car,
an
older
truck.
You're
going
to
go
out
of
the
state
15
and
get
a
car
with
over
7,500
miles
and
import
it
in.

16
These
are
going
to
have
negative
ramifications
necessarily,

17
but
we
want
you
to
be
cognizant
of
those.

18
I
think
I
know
where
the
$
7,000
figure
comes
19
from,
Mr.
Roberts.
When
we
look
at
the
end­
market
average
20
and
when
you
look
at
your
own
staff's
chart
which
is,
like,

21
on
page
Roman
numeral
II
and
if
you
look
at
the
schedule
22
and
they're
flexible,
you
get
out
into
the
later
years
like
23
2010,
you're
going
to
see
in
those
truck
range
24
64
percent
­­
10,
15
percent
or
64
percent
ULEV,
15
percent
25
SULEV.

104
1
Now
on
a
fleet
average,
sure,
that
is
going
2
to
affect
Suburbans.
They
are
going
to
put
natural
gas
in
3
those.
Probably
people
aren't
going
to
buy
them.
But
in
4
order
to
buy
SULEVS,
some
vehicles
are
going
to
be
5
certified.
We
can't
sell
them
in
any
category
right
now,

6
and
it
does
cost
$
7,000
difference
in
an
electric
vehicle
7
now.
So
if
that
is
way
out
there
­­
and
I'm
not
crying
8
wolf
today
­­
but
there
are
market
concerns
out
there.
And
9
that
is
the
one
that
is
most
impacted
and
those
are
15
10
percent
of
the
cars
or
trucks,
I
should
say,
as
a
result
11
today.

12
Any
questions?
That
is
my
point.

13
CHAIRMAN
DUNLAP:
Thank
you,
Mr.
Welch.
I
14
appreciate
that.
Any
further
questions.

15
Manuel
Cunha?

16
MANUEL
CUNHA:
Thank
you
very
much.
Manuel
17
Cunha,
president
of
the
Nisei
Farmers
League.
Also,

18
Mr.
Chairman,
I
have
Mr.
Mike
Wade
here
from
Merced
Farm
19
Bureau
and
if
he
could
be
a
part,
we
could
split
our
time
20
up.

21
CHAIRMAN
DUNLAP:
Is
he
signed
up
as
well?

22
MANUEL
CUNHA:
Yes,
he's
signed
up.
He's
23
right
here
behind
me
on
the
chair.

24
CHAIRMAN
DUNLAP:
Come
on
up.
We
will
do
a
25
two­
for­
one.

105
1
MANUEL
CUNHA:
First,
before
I
start,
I
do
2
want
to
thank
Mr.
Dunlap
for
your
staff
and
this
Board
for
3
the
tremendous
amount
of
work
that
you've
done
in
working
4
with
agriculture
in
California
and
especially
the
staff
­­

5
Mr.
Mike
Kenny,
Mr.
Jim
Schoning
of
course,
and
Tom
6
Cackette,
Peter
and
Bob
Cross,
and
those
folks.
You
have
7
definitely
been
and
have
made
agriculture
a
part
of
your
8
program
in
working
with
us
to
better
our
industry
in
9
cleaning
up
the
air
that
we
are
involved
with
as
well
from
10
AMTAM
as
well
as
other
operations
that
we
have.
So
again,

11
Mr.
Dunlap,
I'd
like
to
thank
you
personally,
and
we
12
appreciate
that
very
much.

13
Okay.
Let's
get
right
to
the
details.

14
Right
now
before
you,
you
should
have
several
testimonies
15
that
were
being
brought
today
for
you.
Those
individuals
16
were
not
able
to
attend;
so
I'm
representing
them
here,
and
17
I'll
just
read
the
names
off,
and
then
I'll
get
right
to
my
18
three
or
four
bullet
points
and
let
Mr.
Wade
come
on
board.

19
First,
Nisei
Farmers
League,
which
is
in
the
20
San
Joaquin
Valley,
Salinas
Valley,
and
in
the
Santa
Maria
21
Valley
as
well
as
down
in
the
Imperial
Valley.
The
second
22
is
the
California
Growers
and
Processors
throughout
the
23
state.
Third
group
is
Fresno
County
Farmers.
After
24
Wednesday
or
after
Tuesday,
I
don't
know
what
is
going
to
25
happen
with
it
or
if
it's
going
to
be
there
or
not.

106
1
But
Fresno
County
Farm
Bureau
which
is
the
2
largest
farm
bureau
west
of
the
Mississippi
in
the
3
San
Joaquin
Valley,
Western
United
Dairy
across
California,

4
California
Grape
and
Tree
Fruit
League
which
represents
5
growers
across
the
state,
the
Raisin
Bargaining
Association
6
referred
to
as
the
RBA
which
is
the
largest
single
entity
7
for
raisin
production
and,
of
course,
99.9
percent
of
the
8
raisins
are
in
the
San
Joaquin
Valley.

9
The
other
group
that
hasn't
brought
10
testimony
forward
is
Dennis
Tristo
with
Boswell
Corporation
11
out
of
corporate.
The
other
group
that
doesn't
have
a
12
written
testimony
due
to
scheduling
or
whatever
is
that
13
California
Growers
Association.
Their
specific
comments
14
for
me
to
raise
was
that
they
are
not
opposed
to
the
15
staff's
proposal
by
ARB.

16
The
other
groups
I
mentioned
for
you,
we
17
look
forward
to
the
staff's
proposal
and
look
forward
to
it
18
moving
forward
because
we
saw
some
statistics
that
were
out
19
there
that
we
could
not
find
$
7,000.
I
asked
every
motor
20
company
as
well
as
the
chamber
where
that
information
was,

21
and
we
couldn't
find
it.
By
contacting
the
staff,
Steve
22
Albu,
he
presented
to
me
actual
information
that
showed
23
what
their
cost
would
be
estimated.
In
fact,
I
mean
in
the
24
actual
calculations.

25
I'm
not
an
engineer.
I
wouldn't
even
be
107
1
able
to
understand
this,
any
of
those
numbers,
but
I
took
2
it
to
somebody
that
understands
those
things
and
explained
3
that
cost
is
around
that
$
200.
I
couldn't
find
$
7,000
at
4
all.
I
even
went
to
the
web
cite.
I'm
not
a
computer
5
individual,
but
maybe
it
was
underneath
the
web
system
6
somewhere.

7
But
our
agriculture
industry
does
support
8
this
because
it
deals
with
it
across
the
board.
Now,
we
9
deal
with
vehicles,
of
all
vehicles
on
road,
vehicles
10
making
the
public,
all
of
us,
responsible
for
doing
a
11
better
job
of
cleaning
up
the
air
because,
as
Mr.
Wade
will
12
talk
about
in
a
few
seconds,
some
of
the
things
of
why
that
13
is
important.
This
will
not
have
an
impact
on
agricultural
14
farmers.

15
The
way
our
economy
is
going,
if
we
have
16
another
El
Nino,
I
do
know
that
many
of
you
will
be
seeing
17
farmers
back
to
the
1800'
s
with
horses
and
plows.
We
will
18
have
a
catch
bag
though
for
the
material
that
was
dropped
19
along
the
street
with
our
buggies
or
whatever.
So
we
don't
20
have
a
BM10
problem.
But
the
economics
or
our
industry
21
though
is
that
farmers
today
keep
their
vehicles
for
a
long
22
time
because
of
the
cost
of
our
tractors.

23
Many
of
my
farmers
are
small
farmers,

24
anywhere
from
2
acres
up
to
80
acres.
I
have
a
farmer
that
25
has
a
tractor
that
is
35
years
old
and
only
has
4,000
hours
108
1
on
it.
That
is
not
many
hours.
8,000,
hours
you
go
to
an
2
overhaul
on
a
tractor.
They
keep
their
vehicles.
And
the
3
economics
of
this
for
me
and
my
agriculture
industry
is
we
4
are
a
part
of
what
we
need
to
do
to
clean
up
the
air.
We
5
are
doing
a
lot
of
voluntary
programs.
They're
positive
6
with
the
San
Joaquin.

7
So
that
issue
alone
is
that
we
are
giving
­­

8
and
I
look
at
it
this
way,
when
I
say
we,
the
state
of
9
California
is
allowing
the
industry
to
come
up
with
giving
10
flexibility
of
4
percent
so
giving
them
some
latitude.

11
Also,
there
is
a
federal
thing
coming
down
the
line
in
the
12
future
that
what
California
does,
we
hope
the
federal
13
government
follows.
I
understand
they
are.
They
want
to
14
copy
what
California
is
doing
with
their
fuels
and
their
15
vehicle
costs,
and
I
think
that
gives
those
manufacturers
a
16
fair
opportunity
across
the
board.

17
So
at
this
time,
I
would
close
and
have
18
Mike
Wade
please
come
forward.
We
choose
to
support
this.

19
The
agriculture
industry
will
not
have
an
economic
impact
20
at
all.
I
want
to
make
that
clear.
We
saw
some
literature
21
out
about
the
farmers
were
going
to
go
into
severe
22
bankruptcy
problems,
et
cetera.
Again,
we
couldn't
find
23
where
that
came
from,
but
it
will
not,
that
we
can
see
at
24
this
time
at
all.
And
$
200
to
me
is
a
reasonable
thing
to
25
clean
up
vehicle
emissions
across
this
state,
and
it
has
to
109
1
be
done.

2
Thank
you.

3
CHAIRMAN
DUNLAP:
Thank
you.
Mr.
Wade,
from
4
Merced
County
Farm
Bureau.

5
MIKE
WADE:
Thank
you
for
your
time
6
consideration.
It's
never
easy
to
follow
Manuel,
but
I'll
7
be
brief.
Merced
County
Farm
Bureau
represents
the
8
collective
interests
of
over
1,800
San
Joaquin
Valley
farm
9
families
and
individuals.
We
are
part
of
California's
10
immense
agriculture
industry.
Our
farm
bureau,
as
does
11
Manuel's,
supports
the
ARB
LEV
II
proposal
because
we
feel
12
it's
a
reasonable
approach
to
the
ongoing
problem
of
poor
13
air
quality
in
the
San
Joaquin
Valley
and
other
parts
of
14
California.

15
Much
has
been
accomplished
in
the
Valley
to
16
improve
air
quality
through
regulations
that
affect
many
17
agricultural
and
non­
agricultural
businesses.
The
food
18
processing
plants
which
are
a
vital
part
of
our
industry
as
19
well
as
other
businesses
have
made
great
strides
over
the
20
past
10
or
20
years
in
reducing
stationary
source
21
emissions.
But
we
think
more
can
be
done,
perhaps
not
with
22
that
class
of
polluter,
but
with
mobile
sources.

23
Based
on
the
influx
of
an
estimated
24
9
million
people
coming
in
the
next
20
years
to
the
state,

25
we
need
to
act
now
to
further
reduce
tailpipe
emissions
110
1
which
are
a
major
problem
in
the
San
Joaquin
Valley
and
a
2
major
source
according
to
the
San
Joaquin
Valley
Unified
3
Air
Pollution
District.

4
LEV
II
is
a
fair
and
balanced
approach,
we
5
feel,
in
reducing
the
air
pollution
problem.
It's
going
to
6
be
effective,
and
we
feel
it's
going
to
be
affordable.

7
LEV
II,
as
written,
will
begin
implementation,
as
you
know,

8
in
2004.
And
it
will
affect
certain
pickup
trucks,
sport
9
utility
vehicles,
and
medium­
duty
trucks.

10
The
improvement
in
tailpipe
emissions
can
be
11
accomplished
among
these
vehicles,
again,
for
approximately
12
$
200
or
less,
which
we
have
heard
testified
to
a
number
of
13
times
already
today.
We
feel
that
this
can
be
accomplished
14
hopefully
without
compromising
performance
or
fuel
economy.

15
From
the
technology
that
has
been
derived
from
the
16
passenger
automobile
industry
can
be
applied
to,
we
hope
17
and
believe,
into
this
other
class
of
vehicles
and
provide
18
an
incremental
common­
sense
approach
to
the
further
air
19
quality
problems.

20
CHAIRMAN
DUNLAP:
So
you
like
it
and
support
21
it?

22
MICHAEL
WADE:
We
do
like
it,
and
we
support
23
it.
We
don't
feel
it's
going
to
be
an
economic
burden,
and
24
we
think
it's
the
one
way
that
we
can
have
a
unified
25
approach
statewide
to
improving
air
quality.

111
1
CHAIRMAN
DUNLAP:
That's
great.
Thank
you
2
guys
very
much.
I
appreciate
your
coming.

3
SUPERVISOR
PATRICK:
I
would
just
like
to
4
ask
either
Manuel
or
Mike
to
talk
a
little
bit
about
5
performance
because
we've
heard
from
the
San
Joaquin
Farm
6
Bureau,
Take
Home
Ranch
and
others,
saying
that
they're
7
afraid
this
is
going
to
affect
the
performance
of
their
8
work
vehicles.
Your
comments
have
primarily
addressed
9
economics.
But
could
you
talk
a
little
bit
about
10
agricultural's
concern,
if
there
is
any,
about
performance
11
of
the
vehicles
under
the
new
standards?

12
MANUEL
CUNHA:
I
think
just
a
real
quick
13
thing
on
that
is
that
many
of
our
farmers
today,
as
I
14
mentioned,
buy
a
larger
vehicle
because
they
use
it
for
15
more
than
just
the
one
purpose;
so
they're
going
to
buy
a
16
bigger
vehicle
anyway.
They're
not
going
to
go
to
a
17
vehicle
that
is
going
to
be
at
the
minimal
to
get
you
over
18
the
hill.
They're
going
to
a
bigger
pickup
truck
because
19
they
know
farmers
do
something
most
of
the
time
that,
if
it
20
says
you
only
load
it
with
two
pounds,
they
will
go
six
21
pounds.
That's
the
way
we
work.
We
have
to
get
the
22
maximum
across.

23
Today,
my
farmers
especially,
they
don't
get
24
into
the
smaller
vehicles.
They're
going
for
a
bigger
25
vehicle
because
their
potential
is
they're
going
to
do
more
112
1
with
it
than
just
use
it
for
towing
the
boat.
They
have
2
always
gone
for
the
larger
system
of
saying
they
are
going
3
to
tow
a
trailer
that
is
a
12,000­
pound
trailer.
They're
4
going
to
put
11
ton
on
it,
and
it's
that
type
of
thing
that
5
the
farmers
do.
And
anymore,
many
of
my
farmers
are
going
6
to
diesel.

7
They
want
that
ability
of
that
torque
and
8
that
low­
end
drive
and
conserving
on
how
many
fuel
tanks
9
they
have
in
your
facility
because
of
the
regulations
that
10
they're
going
to
diesel
­­
one
fuel
tank,
one
issue
to
deal
11
with
versus
having
to
deal
with
gas
and
diesel.
So
that's
12
my
comment
from
our
side.
I've
talked
to
farmers
across
on
13
many
issues.

14
CHAIRMAN
DUNLAP:
Thank
you,
gentlemen.

15
Sam
Leonard?
You're
against
clustering,
Sam?

16
KEVIN
CULLEN:
I'm
going
to
try
to
make
this
17
quick.
I'll
skip
the
opening
commercial
that
some
of
my
18
friends
have
done
as
long
as
you
don't
take
that
time
away
19
from
me.

20
Supervisor
Roberts,
I
don't
know
anything
21
about
$
7,000.
I'm
going
to
try
to
explain
to
you
why
there
22
has
been
a
lot
of
talk
about
tech
feasibility.
That's
23
certainly
a
concern
and
issue.
I
want
to
talk
about
a
24
completely
different
aspect
of
this,
which
is
the
nature
of
25
the
proposal,
the
workload
it
presents
us,
and
why
if
we
113
1
assume
tech
feasibility,
we
still
have
problems.

2
LEV
II
staff
proposes
the
tailpipe
rollout
3
from
'
04
to
'
07,
produced
for
the
industry
an
unprecedented
4
level
of
workload
in
design
and
release,
development
and
5
validation
and
search.
And
that
impact
is
disproportionate
6
on
us
full­
line
manufacturers
who
have
to
deal
with
the
7
shift
of
medium­
duty
trucks
and
light­
duty,
and
that
is
8
really
the
core
message
I
would
like
to
get
to
here.

9
Many
of
the
people
in
the
room
here,
when
10
they
go
home
today,
will
move
on
to
other
things.
Those
of
11
us
from
Detroit
and
other
automotive
centers
will
spend
12
time
trying
to
make
this
happen,
and
the
workload
we're
13
presented
with
is
really
crushing.

14
CHAIRMAN
DUNLAP:
Will
that
be
around
the
15
clock
you're
working
on
this?

16
KEVIN
CULLEN:
Personally,
no,
sir.
I
do
go
17
home
in
the
evening.
But
yes,
we
have
emission
testing
24
18
hours
a
day
for
development.
Key
issues
are
what
I
call
19
the
triple
whammy
of
the
shift
from
medium­
duty
vehicle
to
20
light­
duty
trucks.
And
that's
part
of
the
trucks­
to­
car
21
initiative
2004
to
2007.
Additionally,
the
severity
of
the
22
reduction,
the
ongoing
shift
from
LEV
to
ULEV
and
beyond,

23
superimposed
evap
rollout
and
then
the
other
shoes
to
24
follow.

25
Just
so
we
are
clear
on
the
categories,
this
114
1
isn't
a
commercial.
Current
LEV
II
are
the
guys
on
top
­­

2
the
small
sport
utility,
small
pickups,
and
minivans.
The
3
current
MDVs
under
8,500
are
the
full­
size
trucks,

4
full­
size
pickup,
van,
sport
utilities.
The
MDVs
over
5
8,500
are
the
heavy
work
trucks.

6
When
we
talk
about
the
triple
whammy,
what
7
does
that
really
mean?
When
you
look
at
shifting
vehicles
8
from
the
current
MDV
category
that
is
6,000
to
8,500
into
9
the
new
broader
LDT
II
category,
the
obvious
candidates
to
10
do
that
are
trucks
that
are
going
to
be
ULEVs
as
MDVs
11
because
they
are
the
most
emissions
capable.
When
you
12
remove
those
from
MDV
and
send
them
to
LDT
II,
you
have
to
13
re­
balance
your
MDVs
to
get
back
to
the
proper
split
of
14
LEVs
to
ULEVs,
and
that
means
there
is
work
to
do
on
the
15
MDVs
left
behind
to
get
more
ULEVs
back
in
to
cover
the
16
ones
you
removed.
As
well,
the
MDVs
you
send
to
LDT
II
are
17
the
least
capable
in
that
population.

18
As
data
has
shown
­­
our
data,
certainly
the
19
staff's
data
­­
the
vehicles
6,000
to
8,500
are
primarily
20
LEV
II
candidates.
There
is
no
data
on
the
table
I've
seen
21
yet
that
says
they're
ULEV
candidates.
So
that
means
the
22
balance
of
the
LDT
II
population
has
to
shift
more
23
aggressively
to
ULEV
in
order
to
offset
those
entering
24
MDVs.

25
And
maybe
most
importantly,
when
you
look
at
115
1
the
total
MDV
population,
the
6,000
to
8,500
are
the
2
dominant
volumes.
Those
are
the
configurations
that
are
3
sold
in
high
volume.
When
you
take
one
high
volume
MDV
4
between
6,000
to
8,500
away,
it
no
longer
offsets
many
5
smaller
volume
configurations.
And
this
speaks
to
6
Ms.
Edgerton's
questions
about
availability
­­
will
there
7
be
a
narrowing
of
features
or
a
narrowing
of
offerings.

8
So
we
have
a
multiplied
workload
because
we
9
now
have
to
take
many
small­
volume
configurations
to
10
replace
a
few
large­
volume
configurations.

11
Tried
to
illustrate
that
with
this
plot.

12
This
is
GM's
current
mix
of
sub­
configurations.
A
13
sub­
configuration
is
an
engine,
a
transmission
in
a
body
14
between
6,000
and
10,000
pounds.
Each
of
the
colored
15
sub­
bars
is
one
configuration.
What
you
see
when
you
look
16
at
the
6,000
to
8,500
pound
bar
is
there
are
four
or
five
17
large
configurations
that
dominate
the
volume
in
these
18
categories
and
then
lots
of
cats
and
dogs
that
are
produced
19
in
hundreds
to
thousands
of
vehicles
per.

20
Those
large
volume
configurations
are
the
21
ones
that
will
be
ULEVs
in
2003.
They
will
be
the
first
22
ones
to
move
out
to
go
to
LDT
II,
and
they
will
leave
23
behind
that
large
pull
of
cats
and
dogs.
Making
each
of
24
these
into
a
LEV
II
is
an
equivalent
amount
of
workload,

25
whether
it's
a
500­
vehicle
configuration
or
50,000­
vehicle
116
1
configuration.
So
you
can
see
how
the
workload
multiplies
2
as
you
lose
those
high­
volume
MDVs
that
currently
carry
3
most
of
the
higher
emission
performance
in
this
category
4
today.

5
The
60­
percent
ULEV,
we
are
showing
there
is
6
what
is
proposed
for
the
MDV
class
post
2003,
and
you
can
7
see
that
today
we
can
cover
that
with
about
four
8
configurations.
Once
those
high
volumes
go
away,
we
are
9
going
to
have
many
configurations
to
cover
that
same
10
requirement.

11
I'm
not
going
to
spend
much
time
on
this,

12
but
when
we
talk
about
the
reduction
staff
has
proposed,
as
13
you
step
up
into
those
larger
vehicles,
it
is
a
much
14
tougher
road
to
ho.
The
green
bars
are
LEV
I,
LEVs
to
15
ULEVs
in
each
cagegory.
The
blue
and
red
bars
are
the
16
comparable
reductions
in
HC
plus
NOx
to
get
to
LEV
II
or
17
ULEV
II.
We
are
talking
about
very
dramatic
reductions
in
18
emissions.

19
We
are
also
going
to
more
aggressive
nexus.

20
What
does
that
mean?
More
ULEVs,
and
they
are
ULEV
IIs
not
21
ULEV
Is.

22
Next
slide,
Barbara.
Superimposed
on
all
23
this
is
an
aggressive
evap
rollout.
In
only
three
years,

24
we
are
going
to
change
over
to
the
new
lower
evap
standard
25
on
top
of
the
tailpipe
rollout.
The
last
time
we
did
this
117
1
enhanced
evap
one
rollout
in
four
years,
'
95
to
'
98,
that
2
preceded
the
toughest
years
of
the
LEV
I
Program,
which
are
3
'
99
and
2000.
So
those
workloads
were
decoupled.
We
4
weren't
trying
to
do
them
at
the
same
time.

5
That
enhanced
evap
change
will
require
us
to
6
essentially
recertify
all
of
our
vehicles
for
durability.

7
And
as
staff
knows,
the
test
is
tough.
It's
tough
to
run.

8
It
takes
lots
of
time
so
that
that
recertification
process
9
will
be
very
labor
intensive.

10
And
there
are
other
shoes
to
follow.
What
11
does
that
mean?
There
are
going
to
OBD
impacts
from
the
12
LEV
II
proposal.
Thresholds
that
are
set
relative
to
our
13
measuring
standard
will
change,
will
have
to
be
14
recalibrated
to
the
new
tighter
standard.
I
think
staff
is
15
already
talking
about
the
possibility
of
meeting
a
NOx
16
focus
catalyst
monitoring
diagnostic
as
we
move
the
NOx
17
levels
down
much
further.
The
evap
proposal
may
have
OBD
18
impacts.
And
by
the
way,
at
the
same
time
frame
we
are
19
phasing
in
the
supplemental
FTC
requirements
already
20
adopted
by
the
Board,
2003
to
'
5
on
the
same
MDVs,
6,000
to
21
8,500;
and
the
6,000
to
8,500
ORBR
phase
in
at
the
same
22
time.

23
Last
slide.
So
when
we
look
at
­­
I'm
24
sorry.
How
does
our
proposal
improve
workload?
The
25
biggest
impact
is
by
leaving
the
6,000
to
8,500
as
MDVs,

118
1
we
avoid
that
triple
hit
that
happens
when
migrating
them
2
to
LDT
II.
It
moderates
the
impact
on
the
PC
and
LDT
II
3
under
6,000
LEVs
by
having
a
slightly
higher
LEV
NOx
level.

4
And
what
that
says
is
these
are
vehicles
that
are
going
to
5
go
away
soon
because
of
the
planning
and
NMOG
averages.

6
Why
rework
them
for
a
short
remaining
life.
It
improves
7
our
confidence
that
the
standards
are
achievable,
and
it
8
extends
the
evap
phase
in
by
one
year.

9
Next
slide.
While
we
have
asked
for
some
10
moderate
relief
on
standards,
our
stringency
proposal
is
11
still
very
aggressive.
We
are
still
asking
for
big
12
reductions
at
proportionately
larger
reductions
on
the
13
truck.

14
Next
slide.
Conclusion.
The
staff
15
proposals
really
comprise
a
functioning
workload
task
for
16
all
manufacturers.
I'm
not
trying
to
whine.
I'm
just
17
telling
you
straight
up.
This
is
a
lot
of
work,
and
it's
a
18
particularly
severe
impact
on
the
full­
line
manufacturers
19
who
have
to
do
the
truck
category
shift.
Our
post­
2004
20
product
claims
that
volumes
are
still
very
fluid.
I
can't
21
come
up
and
tell
you
precisely
what
the
workload
ratio
is,

22
but
a
good
estimate
would
be
it's
at
least
twice
the
worst
23
years
'
99
and
2000
for
the
LEV
I
proposal,
and
maybe
as
24
large
as
three
times
the
workload
that
we
are
doing
right
25
now
to
get
through
2000­
2001.

119
1
One
more
comment
I'd
like
to
make.
Staff
2
talked
about
five
years
of
lead
time
on
the
LEV
II
3
proposal.
We
are
currently
certifying
2000
model
year
4
vehicles.
We
are
nearing
calibration
freeze
for
2001'
s.

5
The
most
charitable
number
I
can
come
up
for
the
real
lead
6
time
on
the
LEV
II
proposal
is
three,
maybe
a
little
under
7
three
years.
It
isn't
five
years.
We
are
in
calendar
year
8
1998,
but
we
are
in
product
2000
to
2001.
That's
the
end
9
of
my
story.

10
Questions?

11
CHAIRMAN
DUNLAP:
Any
questions?

12
MR.
CALHOUN:
Kevin,
you
focused
on
13
workload.

14
KEVIN
CULLEN:
Yes,
sir.

15
MR.
CALHOUN:
What
about
the
technology
16
itself?

17
KEVIN
CULLEN:
I
tried
to
approach
this,

18
Joe,
with
the
technology
as
a
given
and
saying
technology
19
isn't
the
only
problem.
The
problem
is
the
resources
to
do
20
this.
In
terms
of
technology,
is
the
technology
there
to
21
do
either
our
reductions
or
the
staff's?
Certainly
there
22
is
technology
to
do
much
lower
levels.
I
think
the
23
question
that
I
have
is
how
do
you
do
an
MDV
over
6,000
24
pounds
to
the
proposed
ULEV
II
level.

25
Nobody's
data
suggests
that
can
be
done,

120
1
particularly
on
NMOG,
and
the
plan
would
require
us
to
2
start
doing
those
as
we
get
to
the
out
years.

3
MR.
CALHOUN:
Do
you
see
that
as
being
a
4
major
hurdle?

5
KEVIN
CULLEN:
Sure.
Absolutely
do.

6
CHAIRMAN
DUNLAP:
Okay.
Thank
you.

7
Sam,
you're
up.

8
SAM
LEONARD:
Sam
Leonard
with
General
9
Motors
Corporation.

10
As
many
of
you
know,
I've
been
before
this
11
Board
many
times
before,
including
1990
when
historic
12
LEV
I
Program
was
passed.
And
at
that
time,
GM
supported
13
the
LEV
I
Program,
including
the
ZEF
mandate
for
which
I
14
have
since
had
some
discussions
with
my
management
about.

15
But
the
auto
industry
is
contributing
to
16
improved
air
quality
through
reduced
emission
reductions.

17
Barbara,
just
quick
slides.
And
this
is
just
a
18
continuation
of
progress
we
have
seen
over
the
last
20
19
years.
This
is
the
share
of
the
auto
statewide
in
1996.

20
This
is
what
it's
going
to
be
under
the
ARB
proposal.
This
21
is
what
it's
going
to
be
under
the
industry
proposal.
You
22
can
see
the
dramatic
reductions
we
are
continuing
to
get
in
23
the
auto.
You
can
also
compare
that
to
the
other
areas.

24
In
fact,
the
auto
proposal
gets
about
25
90
percent
of
the
staff's
proposal,
and
it
covers
all
of
121
1
the
M2
Program,
as
you
know.
All
of
the
M2
commitment
­­

2
and
I
still
can't
get
the
numbers
straight
whether
M2
3
commitment
is
25
or
16
and
whether
the
black
box
is
75
or
4
64.

5
MR.
KENNY:
M2
commitment
is
25,
and
black
6
box
is
55.

7
SAM
LEONARD:
Then
we
cover
about
40
percent
8
of
the
black
box
on
the
M2.

9
CHAIRMAN
DUNLAP:
Is
that
black
box
made
of
10
rubber
material,
or
is
it
really
a
box?

11
SAM
LEONARD:
Depends
on
which
model
you
use
12
for
it,
I
think.
That's
what's
been
the
confusion.
Can
I
13
go
back
to
the
next
slide
for
a
minute
because
I
want
to
14
focus
on
something
­­
I'm
sorry
this
is
not
as
pretty
as
15
Kelly's,
but
this
is
the
one
that
Kelly's
was
taken
from
­­

16
and
focus
on
the
two
things
in
the
tailpipe
area
that
the
17
industry
is
really
looking
for.
This
is
the
original
staff
18
proposal
on
this
side.

19
What
we
are
looking
at
here
in
this
chart
is
20
just
at
the
0
to
6,000
pounds.
The
industry
is
willing
to
21
bring
less
than
6,000­
pound
vehicles
down
to
passenger
car
22
standards.
That
covers
for
GM
all
our
S­
10
pickups,
all
of
23
our
sub­
compact
sport
utilities,
the
Blazers,
the
Jimmy's,

24
Bravados,
covers
all
of
the
minivans
such
as
the
25
Silhouette,
the
Lumina,
the
Montana,
and
most
of
the
Astros
122
1
and
Safaris.
We
are
more
than
willing
to
bring
those
down.

2
What
we
are
looking
for
in
that
category
is
3
some
relief
on
the
NOx
standard
for
LEV.
We
are
willing
to
4
pay
for
that
relief
with
a
more
stringent
NOx
standard
for
5
ULEV.
That
gets
us
through
some
of
the
transition
6
problems,
some
of
the
transition
problems
that
Kevin
is
7
talking
about.
That
particular
change
is
essentially
8
neutral
on
the
emission
tonage.

9
Second
is
that
is
a
big
issue
to
us
because
10
of
trying
to
do
the
transition,
and
it
is
a
relatively
11
minor
issue
in
air
quality
because
LEVs
are
generally
12
phased
out
in
that
category
by
2008
and
just
about
gone
13
because
you
have
to
meet
a
ULEV
average.

14
Second
big
area
is
the
light­
duty
truck
over
15
6,000.
Next
slide,
please.

16
CHAIRMAN
DUNLAP:
What
are
the
names
of
17
those?

18
THE
WITNESS:
The
GM
names
are
the
Silverado
19
pickup
truck,
and
the
GMC
version;
the
Yukon,
the
Tahoe,

20
the
Surburban;
the
Savanah
van,
which
is
the
21
eight­
passenger
van,
full­
size
vans.
These
are
the
big
22
vehicles
that
people
use
to
tow.
If
you're
standing
on
a
23
Michigan
highway
on
Friday,
these
are
the
vehicles
you
see
24
towing
the
trailers.
Every
one
of
them
are
going
north
for
25
the
weekend,
and
you
can
see
them
coming
back
on
Sunday
on
123
1
the
overpass.

2
This
is
the
staff's
proposal.
We
are
not
3
opposed
to
making
significant
reductions
in
the
emissions
4
of
this
category
of
vehicles.
We
think
it
can
be
done.
We
5
just
don't
think
that
we
can
get
all
the
way
down.
This
is
6
a
current
MDV
3,
LEV
I
level
.6.
The
staff
is
asking
us
to
7
get
down
to
.05
on
that.
We
think
a
reasonable
end
point
8
for
a
ULEV
II
on
average
will
be
.1.
These
trucks
do
twice
9
as
much
work
when
they
run
the
test
site.

10
You
talk
about
whether
it's
emission
11
equivalent
control
or
not.
If
you
measure
it
in
grams
per
12
mile,
you
make
the
argument
it's
not.
If
you
measure
it
in
13
percentage
reduction
of
uncontrolled
emissions,
what
we
are
14
proposing
is
equivalent
control.
They
would
both
be
15
reduced
from
uncontrolled
levels
by
99
percent.

16
The
hardware
to
do
that
is
identical
with
a
17
passenger
car
and
light­
duty
truck.
They're
even
more
to
18
get
them
on
the
light­
duty
truck.
But
it
doesn't
get
them
19
down
to
the
same
gram
per
mile
because
they
put
out
more
20
work
over
the
cycle
and
in
use.
Nothing
that
I
have
seen
21
has
shown
any
potential
to
reach
the
ULEV
II
proposal
for
22
MD
3
and
MD
2,
the
CARB
staff
has
proposed.

23
GM
sat
here
in
LEV
I
Program
and
said,
"
Yes,

24
we
are
willing
to
take
on
the
challenge.
We
don't
know
25
exactly
how
we
are
going
to
do
it.
We
don't
know
if
it
can
124
1
be
done,
but
we
think
they're
reasonable
goals."

2
Can
I
back
up
one
slide,
please.
We
are
3
saying
the
same
thing
today
about
this
category
of
4
vehicles.
We
don't
know
how
to
do
it
all,
but
what
the
5
staff
has
proposed
for
the
under
6,000,
we
think
are
6
reasonable
goals;
and
the
over
6,000
pounds,
we
can't
stand
7
here
and
say
that,
and
we
cannot
support
it
because
we
8
don't
think
they're
reasonable
goals.

9
CHAIRMAN
DUNLAP:
Sam,
on
that
point,
you
10
just
think
it's
taking
you
too
far
too
fast
even
with
the
11
time
because
we
are
talking
about
some
significant
time
12
here.
Now,
I
know
I
heard
you
talk
about
the
lead
time
you
13
need
and
all
of
that,
but
does
it
give
you
any
warm
14
feelings,
Sam,
when
we
talk
about
technology
reviews
and
15
corroborating
with
you
all,
et
cetera?

16
SAM
LEONARD:
Part
of
the
problem
I've
got
17
going
now
is
I'm
trying
as
a
corporate
company
to
make
the
18
electric
vehicle
a
success.
We
are
pouring
millions
of
19
dollars
into
that,
probably
with
several
digits
beyond
20
millions.
Spending
hundreds
of
millions
on
fuel
cell
21
program.
I
am
very
leery
of
going
after
another
program
in
22
which
I
have
very
little
hope
of
success
when
I
can
go
23
after
a
program
that
I
think
that
I
can
succeed
at
and
24
provide
90
to
93
percent
of
the
benefit
of
the
staff's
25
proposal.

125
1
CHAIRMAN
DUNLAP:
Is
it
possible?
Let
me
2
ask
one
other
thing,
and
I
mean
no
disrepect
to
your
3
company
in
that
regard
because
I
have
­­
is
it
possible
in
4
that
area,
Sam,
GM
is
a
little
depositioned
or
behind?
Is
5
that
possible?

6
SAM
LEONARD:
Absolutely
not.

7
CHAIRMAN
DUNLAP:
Absolutely
not?
Okay.

8
Thanks.
The
reason
why
I
ask
that
and
again
is,
you
know,

9
you
guys
are
capable
to
catch
up
in
a
hurry
when
you
put
10
your
mind
to
it
if
you're
ever
behind
or
delayed
in
a
way.

11
I
mean,
looking
at
this,
we
deal
with
you
all
the
time,

12
Sam.

13
SAM
LEONARD:
We
are
capable
of
doing
14
what
­­
capable
we
are
doing
it
here
in
this
state.
But
if
15
you
look
at
the
technological
feasibility
data
that
has
16
been
presented,
what
has
been
presented
for
the
LEV
II
over
17
6,000
is
similar
to
what
has
been
presented
for
the
18
ULEV
II
for
the
passenger
car
and
up
to
6,000.
I
think
19
there
is
a
feasibility
potential
there
for
LEV
II
on
those
20
vehicles
with
a
.1
NOx.
I
don't
think
there
is
any
21
feasibility
for
ULEV
II
that's
been
shown,
nor
do
I
have
22
any
hope
of
getting
there.

23
CHAIRMAN
DUNLAP:
One
last
question.
Staff
24
has
indicated
that
there
are
some
off­
the­
shelf
stuff
that
25
need
to
be
done,
different
kinds
of
catalysts
to
it,
et
126
1
cetera,
maybe
change
the
size
and
dimensions
or
whatever.

2
And
think
you
can
get
there
or
get
close?

3
SAM
LEONARD:
They
got
close
to
LEV
II
not
4
ULEV.

5
CHAIRMAN
DUNLAP:
The
question
is
to
me
­­

6
and
I
know
we
have
a
fine
staff
and
I'm
grateful
for
them
7
and
the
work
they
do,
but
you
guys
are,
if
not
the
biggest,

8
one
of
the
bigest
corporations
in
the
world.
And
I
know
9
when
you
put
your
mind
to
it,
you
can
accomplish
just
about
10
anything.
The
thing
that
disconnects
for
me
is
how
this
11
kind
of
David
and
Goliath
thing
is
going
on
here,
and
I'm
12
just
perplexed
by
it.

13
SAM
LEONARD:
The
disconnect
for
me
is
that
14
we
have
your
staff
saying
that
it
can
be
done,
and
every
15
automobile
manufacturer
in
the
world
that
produces
those
16
types
of
vehicles
saying
it
can't
be
done.

17
CHAIRMAN
DUNLAP:
Even
with
the
time?

18
SAM
LEONARD:
Even
with
the
time.
Just
to
19
summarize
the
three
major
issues
the
industry's
concerned
20
about
is
the
passenger
car
LEV
NOx.
We'd
like
the
relief
21
on
that
from
.05
to
.1
on
the
over
6,000
pound
trucks
and
22
the
evaporative
standard.
As
you
know,
we
have
offered
a
23
.95
in­
use
.8
cert.
The
staff
has
offered
a
.5
cert
with
a
24
.875
in­
use
or
three
years.

25
I
pushed
and
stretched
and
threatened
and
127
1
strangled
my
development
engineers
to
get
them
to
be
able
2
to
put
.8
cert
level
into
our
proposal.
They
have
­­

3
CHAIRMAN
DUNLAP:
Still
don't
see?

4
SAM
LEONARD:
Don't
see.
That's
all.

5
CHAIRMAN
DUNLAP:
Okay.

6
MS.
EDGERTON:
I
appreciate
that,
between
7
the
time
I
spent
with
you
and
your
colleagues
and
now,

8
there
has
been,
well,
there
have
been
other
meetings.
When
9
you
talk
about
your
proposal,
are
you
talking
about
the
one
10
that
you
had
several
weeks
ago,
or
are
you
still
sticking
11
with
that,
or
are
you
talking
about
a
smaller
one
that
just
12
has
the
items
there?
I'm
a
little
confused
with
what
we
13
are
talking.

14
SAM
LEONARD:
Put
it
this
way.
You
pick
it.

15
You
can
have
either
one
of
them.

16
MS.
EDGERTON:
Well,
thank
you
for
that,
and
17
I'll
ask
the
staff
to
respond.
Is
there
anything
you
think
18
you
can
clarify
with
respect
to
the
proposal
that,
you
19
know,
we
saw
several
weeks
ago
and
Mr.
Langer's
proposal
20
today
how
similar
they
are
or
dissimilar.

21
MR.
CACKETTE:
There
has
been
­­

22
CHAIRMAN
DUNLAP:
In
the
political
23
vernacular,
have
they
moved?

24
MR.
CACKETTE:
Very
small
amounts.
There
25
has
been
three
proposals,
one
from
months
ago,
I
guess;
one
128
1
from
early
this
week;
and
one
from
11:
00
last
night.
And
2
those
proposals
all
fall
roughly
in
the
range
of
doing
85
3
to
90
percent
of
the
reductions
that
the
staff
proposal
4
does.
They
all
fall
roughly
8
tons
per
day
short
in
South
5
Coast
compared
to
the
staff
proposal.

6
There
has
been
changes
that
have
moved
that
7
up
one,
down
one
a
ton
or
so
but
not
anything
that
8
substantially
shrunk
the
difference
between
the
two
9
proposals
in
terms
of
environmental.

10
MS.
EDGERTON:
I
appreciate
that,
and
all
I
11
can
say
is
is
that
these
are
very
complex
proposals,
as
you
12
know.
And
I
know
you
appreciate
it's
very
hard
to
try
to
13
shoot
from
the
hip.
I
mean
it's
impossible
sitting
up
14
here.
I
can't
even
really
respond
very
well
to
that
when
15
it's
something
that
is
changing.

16
SAM
LEONARD:
Basic
difference
is
the
17
assessment
of
the
feasibility
of
the
over
6,000­
pound
18
truck.
And
no
matter
how
you
squeeze
the
proposal,
you
19
can't
find
the
tonage
to
make
that
up
because
you've
got
20
passenger
cars
at
absolute
technology
forcing
levels.

21
Things
that
we
don't
know
how
to
do
but
we
think
are
22
reasonable
goals,
you
can't
sign
up
for
much
more
than
23
that.
We
tried
to
sign
up
for
a
little
more
of
that
on
24
ULEV
on
the
passenger
car
and
under
6,000.

25
But
as
long
as
we
are
convinced
that
what
129
1
the
staff
considers
feasible
for
the
over
6,000
pounds,
we
2
don't.
There
is
going
to
be
that
gap,
and
there
is
no
­­

3
with
everything
being
at
technology
forcing
levels,
there
4
is
no
place
to
make
it
up.
It's
just
a
difference
in
5
assessment
of
what
is
feasible
in
the
market.

6
CHAIRMAN
DUNLAP:
Mr.
Calhoun?

7
MR.
CALHOUN:
Mr.
Leonard,
correct
me
if
I
8
mischaracterize
your
proposal.
Essentially,
what
you
have
9
proposed
is
to
do
more
with
the
lighter
vehicle
passenger
10
cars
and
light
trucks
and
for
some
break
on
the
6,000
to
11
8,000
vehicle;
correct?

12
SAM
LEONARD:
Joe,
on
the
passenger
cars
to
13
light
trucks,
it's
basically
what
the
relief
we
are
14
requesting
on
the
LEV
NOx
is
basically
offset
by
the
added
15
stringency
we
are
offering
on
ULEV
NOx
in
that
range.
And
16
the
over
6,000,
it's
all
shortfall
because
we
have
nothing
17
to
give,
nothing
to
offer,
nothing
to
push
forward
on
that
18
because
of
technology.

19
MR.
CALHOUN:
The
staff
has
proposed
to
20
compensate
for
the
difficulties
the
vehicle
has
in
meeting
21
the
standards
by
allowing
4
percent
of
the
vehicles
to
meet
22
a
different
standard,
a
more
lenient
standard.
What
23
percentage
of
the
6,000
to
8,000
pound
vehicles
are
­­

24
what
percentage
of
your
product
in
that
range
are
ordered
25
with
the
heavy­
duty
trailing
package?

130
1
SAM
LEONARD:
Excuse
me
just
a
second.
Let
2
me
do
it
by
categorization.
If
I
look
at
the
three­
quarter
3
ton
SUVs
­­
Yukon,
Tahoe,
Suburbans
­­
over
90
percent
of
4
those
vehicles
are
ordered
with
a
trailering
package,
and
5
that's
not
a
cheap
package.
That's
a
$
150
to
$
350
package.

6
People
don't
buy
just
to
buy
it.
They
buy
it
because
7
they're
going
to
use
it.
On
the
three­
quarter
ton
pickups,

8
we
are
over
half
ordered
with
these
heavy­
duty
trailering
9
package.
The
one­
ton
pickups
are
a
little
bit
lower.
They
10
are
down
to
35
percent,
and
the
farmers
will
tell
you
why
11
that
is.
They
do
fifth­
wheel
trailering
packages
on
it
in
12
the
after
market.
We
don't
put
those
on
our
vehicles.

13
Concurrently,
if
you
look
at
our
passenger
14
cars
today
with
what
we
have
done
with
the
towing
15
capability
of
the
passenger
cars
by
reducing
emissions
and
16
improving
the
fuel
economy
and
removing
the
front­
wheel
17
drive,
we
have
virtually
0
percentage
of
our
passenger
cars
18
purchased
with
a
trailering
package.
I
can't
find
it
on
19
the
chart.
These
vehicles
are
6,000­
to
8,500­
pound
20
vehicles
are
purchased
with
tow
heavy
loads.

21
That's
what
they
have
to
be
designed
to
do.

22
When
you
run
them
over
a
test
cycle,
they
have
to
do
twice
23
the
work
as
our
passenger
cars.
And
that's
why
they
have
24
about
twice
the
emissions
on
a
gram­
per­
mile
basis.

25
DR.
FRIEDMAN:
I'm
just
a
little
confused.

131
1
Where
is
the
towing
package
installed?
Doesn't
it
come
to
2
the
dealer
with
the
towing
package
in
many,
many
instances?

3
SAM
LEONARD:
Many
instances,
it's
factory
4
installed.

5
DR.
FRIEDMAN:
So
when
it
gets
to
the
6
dealer,
you
buy
it
with
the
tow
package
because
it's
7
installed.
Are
you
telling
me
that
you
really
think
that
8
90
percent
of
those
vehicles
are
in
fact
towing
something?

9
SAM
LEONARD:
Yes,
I
do.

10
DR.
FRIEDMAN:
Not
in
my
neighborhood.

11
SAM
LEONARD:
They
are
in
mine.

12
CHAIRMAN
DUNLAP:
Sam,
we
may
want
you
guys
13
and
Kelly
as
well
later.
So
stick
around.
Okay.
Thanks,

14
gentlemen.

15
Mr.
Innes?
Mr.
Innes,
hello.
You're
a
16
citizen
from
the
909
area
code.
That
could
be
17
San
Bernardino,
Riverside
area;
is
that
right?

18
WILLIAM
INNES:
Well,
the
remark
is
now
the
19
regulators
have
solved
the
smog
problems.
Why
do
they
seem
20
to
want
to
unsolve
it?
My
name
is
Bill
Innes.
I'm
a
21
physical
scientist,
speaking
as
a
private
citizen
of
the
22
Los
Angeles
basin.
I'm
living
in
the
inland
area
where
we
23
have
the
highest
smog
level.
My
comments
are
directed
at
24
the
NOx
control
measures.

25
These
are
about
80
percent
of
the
132
1
incremental
emissions
benefits
claimed
in
the
staff
2
report.
Smog
chamber
in
modeling
seem
to
have
shown
that
3
controlling
NOx
is
counterproductive
with
respect
to
ozone
4
levels.
We
heard
a
little
bit
about
that
already
today.
I
5
don't
want
to
go
in
in
any
great
detail.
This
particularly
6
applies
to
the
South
Coast
Basin.
At
present,
it's
very
7
critical
what
the
ratio
is
below
one­
tenth
NOx
becomes
8
important
from
the
standpoint
of
being
necessary
for
smog.

9
Above
one
tenth,
it
acts
the
other
way
and
it
decreases
10
ozone
by
a
direct
reaction
of
ozone
with
nitric
oxide.

11
Right
now
the
ozone
is
about
.30,
which
is
12
three
times
higher
than
critical
ratio;
so
we
are
13
definitely
on
the
side
where
any
controls
on
NOx
are
14
counterproductive.
That's
why
I
say
it's
going
to
get
15
worse
with
these
measures
rather
than
better.
One
of
the
16
reasons
is
often
given
for
NOx
controls
is
a
matter
of
17
particulate.
However,
the
ARB
has
failed
to
come
up
with
18
any
proof
of
that,
to
my
knowledge.
I
think
it's
based
on
19
a
common
assumption
that
nitric
oxide
reacts
rapidly
in
air
20
to
become
an
NA2.

21
Well,
that's
a
false
idea.
Of
course
22
everybody
has
probably
seen
chemistry
experiments
if
they
23
took
chemistry
in
school.
When
you
release
NO
on
the
24
atmosphere,
you
see
a
ground
color,
and
NO's
converted
to
25
NO2
you
think.
Well,
that
does
happen.
That's
a
tailpipe,

133
1
but
it's
very
brief
and
never
only
about
10­
percent
2
conversion.
The
reason
it
happens
is
because
the
reaction
3
of
NO
air
and
oxygen.
Oxygen
and
air
requires
three
4
molecules.
It
requires
two
molecules
of
nitric
oxide
and
5
one
for
oxygen.
And
that
happens
very
rare
when
you
get
6
through
diluted
nano
condition
like
we
have
now.
Compared
7
to
the
reaction
of
NO
with
ozone,
it's
almost
negligible.

8
That's
where
the
conversion
occurs,
and
9
that's
where
actually
nitric
oxide
helps.
What
is
emitted
10
from
cars
essentially
is
about
90­
percent
nitric
oxide,
or
11
NO.

12
CHAIRMAN
DUNLAP:
Mr.
Innes,
what
would
you
13
have
us
do
relative
to
this
regulatory
proposal?
What
14
would
you
have
us
do?
What
do
you
want
us
to
know?
We
are
15
talking
about
the
regulatory
proposal.
Do
you
like
it?
Do
16
you
think
it's
misguided?

17
MR.
INNES:
You
want
me
to
get
to
the
18
recommendations
already?

19
CHAIRMAN
DUNLAP:
Yes,
I'd
like
you
to
do
20
that,
sir.

21
WILLIAM
INNES:
Recommend
that
you
delay
or
22
cancel
action
on
the
new
LEV
control,
the
current
proposal
23
resulting
from
the
EPA
standards.
And
these
are
24
scientifically
unjustified
and
probably
will
be
unchanged
25
because
probably
a
new
EPA
administrator
or
because
of
a
134
1
legal
challenge
because
they
don't
make
scientific
sense.

2
I
hope
the
state
of
California
will
not
be
a
party
to
such
3
a
challenge.

4
Secondly,
you
should
review
when
publishing
5
model
studies
involving
higher
NO
hydrocarbon
ratios
versus
6
the
proposed
LEV
controls.
Then
would
be
the
time
to
7
consider
emission
standard
changes.
The
staff
report
8
provides
no
assurance
the
new
air
standard
will
be
met
by
9
imposition
of
the
LEV
II
regulations.

10
CHAIRMAN
DUNLAP:
Okay.

11
WILLIAM
INNES:
Since
they
would
decrease
12
the
NOx
to
AC
ratio,
they
would
be
expected
to
increase
13
ozone
levels.

14
Thirdly,
we
are
not
with
hydrocarbon
than
15
any
future
regulations
that
are
in
this
because
their
16
effects
are
entirely
different.
That's
it.

17
CHAIRMAN
DUNLAP:
All
right.
Thank
you.

18
I'm
going
to
ask
staff
at
the
break,
Tom,
to
get
Mr.
Innes
19
and
share
with
him
some
modeling
data.
I
don't
know
if
we
20
can
turn
you
around
about
scrapping
this
thing,
but
we
want
21
you
to
know
some
of
the
assumptions
going
on.

22
Thank
you
for
coming
down
today.
I
23
appreciate
it.
We
will
take
one
more
witness
and
break
for
24
lunch.
Anybody
sitting
over
there
in
the
bull
pen
willing
25
to
be
particularly
brief?
Come
on
down.
Okay.
Very
135
1
good.
You
are?

2
BARBARA
KISS:
Barbara
Kiss.
I'm
the
staff
3
engineer
with
the
American
Automobile
Manufacturers
4
Association.
I've
got
just
a
few
very
brief
comments
on
5
CAP
2000
portion
of
today's
rule
making.
My
comments
today
6
on
behalf
of
both
AAMA
and
AIM.

7
Many
people
from
EPA,
CARB,
and
the
industry
8
have
worked
very
hard
for
several
years
on
this
initiative
9
to
achieve
effective
regulatory
streamlining
of
vehicle
10
compliance
programs.
In
1996,
the
automobile
11
manufacturers,
EPA,
and
CARB
agreed
to
work
under
the
12
auspices
of
the
statement
of
principles
with
the
goal
to
13
improve
future
in­
use
emission
controls
performance
of
14
light­
duty
vehicles
and
light­
duty
trucks
while
reducing
15
overall
compliance.

16
We
agree
with
the
statement
that,
given
the
17
mature
state
of
emission
control
technology
coupled
with
18
in­
use
program,
certification
requirements
may
now
be
19
streamlined
substantially
with
greater
emphasis
placed
on
20
in­
use
performance.
These
are
very
worthwhile
goals,
and
21
this
rule
making
is
a
definitive
step
in
that
direction.

22
However,
we
believe
that
EPA
and
ARB
missed
23
an
important
opportunity
to
accomplish
greater
reductions
24
in
workload,
testing
documentation,
and
related
staffing
on
25
the
certification
part
of
the
compliance
process.

136
1
Recognizing
that
the
proposed
increase
reliance
on
in­
use
2
testing,
a
process
more
approaching
self­
certification,

3
could
better
achieve
the
stated
goals
of
CAP
2000.

4
Overall,
today's
proposal
will
reduce
5
testing
of
certification
and
new
production
vehicles
6
significantly
in
some
cases
and
will
decrease
the
7
unnecessary
up­
front
paperwork.
However,
all
manufacturers
8
are
being
required
to
conduct
in­
use
testing
on
customer
9
vehicles
as
received
and
at
the
manufacturer's
expense,

10
resulting
in
a
new
level
of
burden
and
compliance
concerns.

11
On
the
whole,
we
agree
that
there
are
some
12
cost
savings.
The
cost
savings
are
not
uniform
throughout
13
the
industry.
In
the
aggregate,
many
manufacturers
may
14
incur
a
net
increase
in
costs.
Though
each
manufacturer
15
will
be
affected
differently
by
these
changes,
all
are
16
supportive
of
EPA
and
CARB
regulatory
harmonization.

17
Automobile
manufacturers
have
a
critical
need
for
common
18
certification
and
testing
procedures
between
the
agencies.

19
Today's
rule
making
takes
steps
in
that
direction.

20
However,
more
effort
in
this
direction
is
21
required.
Again,
we
will
continue
to
work
with
the
22
agencies
to
address
these
issues
and
to
reduce
unnecessary
23
regulatory
complexity.

24
CHAIRMAN
DUNLAP:
Okay.
I'm
going
to
ask
25
staff,
would
you
make
sure
staff
understands
the
testing
137
1
procedure
that
would
be
most
efficient
and
then
later
at
2
the
end
when
we
do
the
wrap
up,
we'll
have
you
talk
about
3
why
you
can't
do
it
their
way
or
what
the
issues
are
or
4
whatever
is
on
the
table;
so
we
will
address
that
at
the
5
right
time.

6
Is
Greg
Dana
here?
Are
you
going
to
go
next
7
because
she
said
she
was
representing
your
organization
as
8
well
as
­­

9
BARBARA
KISS:
Again,
my
comments
were
only
10
on
the
CAP
2000.

11
CHAIRMAN
DUNLAP:
Because
we
have
two
12
minutes,
I'll
let
you
go.
I'll
hold
you
until
after
13
lunch.
It's
your
call.
Last
witness,
and
we
will
break
14
for
lunch.

15
GREG
DANA:
My
name
is
Greg
Dana,
vice
16
president
and
technical
director
of
the
Association
of
17
International
Auto
Manuracturers.
Our
members
have
long
18
been
leaders
in
development
(
unintelligible).

19
To
name
a
few,
Toyota
has
introduced
the
20
first
production
hybrid
vehicle
in
Japan
which
are
soon
to
21
be
released
into
the
market
Honda
has
introduced
the
first
22
production
gasoline
ULEV.
Mercedes
Benz
is
the
leader
in
23
developing
the
fuel
cell
power
for
motor
vehicles.

24
Mitsubishi
has
been
developing
gasoline
(
unintelligible)

25
sold
in
Japan,
along
with
Toyota
and
Honda.
Volvo
has
138
1
introduced
a
system
on
(
unintelligible)
model
year.

2
In
light
of
this,
we
believe
the
proposed
3
LEV
provision
standards
present
a
significant
challenge
for
4
our
engineering
community,
given
the
significant
changes
to
5
the
tailpipe
evaporative
standards
as
well
as
changes
to
6
the
structure
of
passenger
cars
and
trucks
and
the
7
increased
use
of
the
light
truck
vehicles.

8
While
it's
impossible
at
this
point
to
know
9
whether
these
new
standards
will
be
achievable
across
the
10
entire
product
line
of
vehicles
produced
by
our
members,

11
they
are
committed
to
doing
their
best
to
achieving
12
emission
control
proposed
by
staff.
I
guess
this
is
Kelly
13
saying
never
say
never.

14
We've
already
talked
about
evaporative
15
emissions.
One
of
our
members
was
talking
about
that.
We
16
certainly
support
the
industry
(
unintelligible)
at
this
17
point.
One
small
item
though
regarding
evaporative
and
18
tailpipe
together
for
the
small
volume
manufacturers
that
19
we
represent,
depending
on
how
you
look
at
the
phase
ins,

20
if
in
fact
the
phase
ins
have
been
2006
and
tailpipe
2007,

21
for
the
small
volume
people
in
particular,
we'd
like
to
try
22
and
align
that
phase
in
so
it
will
all
happen
in
one
year.

23
Proposal
also
suggests
some
changes
to
the
24
smog
index
label.
While
we
continue
to
be
skeptical
of
the
25
benefits
of
such
labels,
we
support
the
changes
proposed
by
139
1
staff;
however,
we
again
ask
the
staff
to
remove
the
2
requirement
for
the
statutory
low­
emission
vehicle
label
3
required
by
the
state.
This
is
redundant
of
smog
index
4
label.
And
I
will
support
the
changes
of
the
phase
in
for
5
the
.020
in
leak
protection
as
part
of
the
OBD
II
6
requirements.

7
The
staff
proposal
is
to
go
from
50­
percent
8
phase
in
in
the
year
2000
to
20
percent
and
phasing
in
its
9
requirement
over
four
years
rather
than
three.
This
longer
10
and
less
front­
loaded
phase
in
will
permit
better
11
development
of
OBD
systems,
able
to
meet
the
stringent
12
requirement.
We
also
appreciate
the
addition
of
in­
use
13
compliance
standards
for
the
first
years
of
implementation
14
of
the
LEV
II
Program.
As
we
suggested
at
one
of
the
15
previous
workshops
(
unintelligible)
permit
more
time
to
16
develop
robust
calibration
while
keeping
the
focus
on
the
17
long­
term
goal
of
meeting
these
stringent
standards.

18
Another
issue
to
be
raised
at
the
previous
19
workshop
was
the
international
OBD
II
standards.
From
20
experimentation
or
data
we
have
been
trying
to
develop,
we
21
think
there
is
some
need
to
change
these
threshholds
that
22
we
have
on
the
OBD
II
system
as
we
move
into
the
SULEV
23
category.
We
don't
believe
that
a
(
unintelligible)

24
threshold
for
OBD
II
can
be
measured
in
SULEV.

25
Finally,
while
it
is
not
part
of
these
140
1
regulations,
AMA
would
like
to
state
for
the
record
that
2
cleaner
fuels
will
have
to
be
part
of
the
equation
as
new
3
standards
are
implemented.
This
includes
further
sulfur
4
reductions
in
both
gasoline
and
diesel
fuel.
Fuel
changes
5
to
control
combustion
chamber
deposits
as
well
as
other
6
fuels
that
may
be
needed
with
more
advanced
technologies.

7
And
we
look
forward
to
working
with
staff
on
these
issues.

8
Thank
you.

9
CHAIRMAN
DUNLAP:
Thank
you.
Any
questions
10
of
the
witness?
Very
good.
For
you
and
your
colleagues
at
11
AMA,
I
wish
you
guys
well
on
that.

12
GREG
DANA:
So
do
we.

13
CHAIRMAN
DUNLAP:
All
right.
Why
don't
we
14
take
a
break.
For
those,
again,
we
are
one­
third
done
with
15
the
witness
list.
We
will
reconvene,
40,
45
minutes.
1:
15.

16
(
Lunch
recess,
12:
40.
Return
at
1:
15.)

17
(
Back
on
the
record
at
1:
15.)

18
CHAIRMAN
DUNLAP:
Wolfgang,
would
you
mind
19
coming
forward.
Now
my
apologies
since
all
of
the
Board
20
members
are
not
back,
but
it
is
piped
into
the
back
so
they
21
can
hear
you.
Dick
Shaw.
Is
Dick
Shaw
here?

22
DICK
SHAW:
Right
here.

23
CHAIRMAN
DUNLAP:
Dick,
you're
up
next.
So
24
I'm
going
to
go
around.
Wolfgang,
you
get
going.
I
had
a
25
chance
to
meet
with
you.
So
I'm
going
to
let
Joe
keep
you
141
1
on
track.

2
WOLFGANG
GROTH:
My
name
is
Wolfgang
Groth,

3
and
I'm
director
of
engineering
environmental
staff
of
4
Volkswagen
of
America.
My
comments
here
are
presented
on
5
behalf
of
Volkswagen,
Audi,
and
Rolls­
Royce,
and
6
Automobili,
and
Lamborghini.

7
One
particular
concern
to
Volkswagen
is
the
8
impact
of
the
proposed
standards,
especially
NOx,
on
9
Volkswagen's
capability
to
market
lean
burn
technology
10
vehicles
such
as
gasoline
fuel
direct
injection
and
11
diesel­
power
vehicles.
There
are
definite
environmental
12
advantages
to
these
technologies.
In
the
case
of
diesel
13
technologies,
these
advantages
include
inherently
low
and
14
mark
admissions,
CO,
cold
start,
and
evaporative
emissions.

15
Another
important
feature
of
the
16
diesel­
power
vehicles
is
they
are
considerably
more
fuel
17
efficient
than
the
gasoline
counterpart.
As
such,
they
18
emit
much
lower
levels
of
CO2,
an
important
reduction
19
component
for
global
warming
control
strategy.
Volkswagen
20
is
the
world's
largest
producer
of
small
diesel
engines
and
21
the
leader
for
development
of
advanced
diesel
technology
22
for
small
cars.
We
are
actually
pursuing
the
goal
of
23
continuous
improvement
in
diesel
emission
performance.

24
ARB
proposed
.5
gram
per
mile
NOx
standard
25
at
150,000
miles.
Volkswagen
accepts
the
challenge
and
142
1
supports
the
standard.
To
achieve
an
even
lower
NOx
2
emission
lean
burn
NOx
emission
standard,
lean
burn
de­
NOx
3
catalysts
are
required.
However,
low
sulfur
diesel
fuel
is
4
necessary
to
enable
this
technology.

5
As
low
sulfur
diesel
fuel
and
new
diesel
6
emission
control
technology
becomes
available,
the
NOx
7
standard
can
be
reduced
to
.3
gram
per
mile
so
the
addition
8
of
a
new
vehicle
emission
category.
This
category
should
9
also
include
appropriate
reduction
in
NMOG
and
CO
10
emissions.
Since
low­
sulfur
diesel
fuel
is
not
available
11
in
California,
Volkswagen
recommends
that
ARB
mandates
the
12
sale
of
low­
sulfur
diesel
fuel.
I
would
like
to
add
that
13
gasoline
direct
injection
technology
would
also
benefit
14
from
the
availability
of
low­
sulfur
gasoline.

15
Another
point
I
have
here
says
on
partial
16
ZEF
allowance.
In
Volkswagen's
opinion,
the
proposed
17
partial
ZEF
allowance
provisions
do
not
represent
a
18
reasonable
alternative.
We
are
investigating
the
19
development
of
super
low
emission
vehicles
as
alternatives
20
to
the
pure
zero­
emission
vehicles
to
satisfy
our
2003
21
model
year
ZEV
sales
requirement
using
SULEVS.
We
want
to
22
have
­­
50
percent
of
our
California
sales
have
to
be
23
SULEV's,
in
that
case,
by
the
2003
model
year.
First,
this
24
will
require
the
SULEV's
to
be
introduced
in
advance
of
the
25
LEV
II
phase­
in
vehicles.

143
1
Second,
the
flexibility
provided
by
the
2
phase­
in
of
the
LEV
requirements
would
be
eliminated
by
the
3
need
to
introduce
50
percent
more
SULEV's
than
2003.
This
4
clearly
represents
an
unreasonable
burden
when
considering
5
it
would
require
development
effort
and
cost.

6
Another
thing
of
concern,
Volkswagen
is
7
particularly
concerned
about
compliance
with
the
zero­
evap
8
requirement
for
this
partial
ZEF
allowance
and
SULEV's.

9
This
is
clearly
technologically
not
feasible
in
the
10
required
time
frame.
You
will
hear
later
why
not.

11
Volkswagen
recommends
that
ARB
establishes
the
same
12
evaporative
emission
standards
for
partial
ZEF
allowance
13
SULEVs
as
those
applicable
to
all
other
categories
of
14
LEV
II
vehicles.

15
The
proposed
evaporative
emission
standards
16
represent
a
level
of
non­
fuel
background
emission
from
17
vehicles.
Therefore,
we
question
the
feasibility
of
the
18
proposed
standards.
The
technology
suggested
by
ARB
to
19
reduce
evaporative
emissions,
in
many
instances,
already
20
been
adopted.
In
other
cases
may
not
be
feasible
from
mass
21
production
or
repairability
standpoint.

22
Modification
to
existing
fuel
system
23
necessary
to
comply
with
the
proposed
evaporative
emission
24
centers
would
require
a
major
redesign
of
the
vehicle
and
25
could
not
be
accomplished
under
required
time
frame.
For
144
1
example,
most
stringent
evaporative
emission
standard
may
2
require
the
use
of
steel
fuel
tanks.
Volkswagen
and
Audi
3
vehicles
exclusively
use
plastic
molded
fuel
tanks
that
4
allows
to
maximize
fuel
tank
volume
with
the
confined
space
5
available
on
today's
vehicles.

6
Volkswagen
recommends
that
ARB
considers
7
evaporative
emission
standards
that
are
reasonable
and
8
achievable
in
the
required
time
frame.
That
concludes
my
9
remarks.

10
Do
you
have
any
question?

11
BARBARA
RIORDAN:
Thank
you
very
much.
Are
12
there
any
questions
for
our
speaker?

13
MS.
EDGERTON:
Yes.
I
wonder
if
I
14
understood
your
last
point.
Are
you
saying
that
you
15
question
whether
plastic
fuel
tanks
such
as
you
use
can
16
meet
the
evap
standard
proposed?

17
WOLFGANG
GROTH:
We
know
that
they
don't.

18
In
our
country,
we
have
all
plastic
fuel
tank
because
it
is
19
technology
to
go
with
small
cars.
You
can
get
much
more
20
fuel
in
small
cars,
and
it
packages
better.

21
We
have
here
two
problems.
We
have
the
evap
22
standards
coming
up.
They
are
very
low
and
currently
not
23
achievable
with
plastic
fuel
tanks.
So
we
actively
have
to
24
see
do
we
have
to
change
over
our
cars
to
steel
fuel
25
tanks.
That
is
a
major
redesign
in
the
car.

145
1
The
other
thing
is
the
2003
evap
standard.

2
These
are
zero­
evap
standards,
and
they
certainly
are
not
3
achievable
using
steel
or
plastic
fuel
tanks,
I
think.
So
4
we
would,
for
these
cars,
we
would
have
the
same
emission
5
standards
like
for
the
others.
It's
a
little
complex.
The
6
whole
regulation
is
a
little
complex,
but
the
staff
knows.

7
MS.
EDGERTON:
Thank
you.
I
wanted
to
ask
8
if
anybody
on
the
staff
wanted
to
make
a
comment
in
9
response
to
this
conversation
about
the
evap
standards?

10
BOB
CROSS:
We
have
talked
to
a
number
of
11
folks
about
the
feasibility
of
using
plastic
tanks,
and
12
they
use
the
basic
technology
called
barrier
technology.

13
They
impregnate
another
kind
of
plastic,
like
a
Teflon
or
14
something
like
that,
in
the
layers
of
the
tank
to
prevent
15
the
tank
from
having
its
plastic
permeation
problems.

16
And
sort
of
the
current
state
of
the
art
of
17
that
technology
is
the
tanks
emit
oh,
maybe
at
the
most,

18
two­
tenths
of
a
gram.
So
that
does
make
their
challenge
19
harder
with
the
current
state­
of­
the­
art
plastic
tanks,
but
20
there
is
also
a
lot
of
work
being
done
on
barrier
21
technologies
which
are
better
which
will
hopefully
play
out
22
in
the
time
frame
that
we
are
talking
and
bring
plastic
23
tanks
down
to
where
they're
really
not
that
big
of
a
24
problem.

25
But
it's
rapidly
developing
technology
right
146
1
now,
and
I
guess
the
staff's
view
is
that
the
standards
may
2
well
be
feasible
with
plastic
tanks,
but
we
are
not
sure.

3
We
know
steel
works,
but
we
think
plastic
will
work,
but
4
they
have
some
work
to
do.

5
MS.
EDGERTON:
What
does
the
Toyota
Camry
6
have?

7
BOB
CROSS:
Steel.

8
BARBARA
RIORDAN:
Thank
you
very
much.

9
Mr.
Shaw
from
Ram
Products.

10
DICK
SHAW:
Good
afternoon.
My
name
is
11
Dick
Shaw.
I'm
a
registered
professional
engineer,
and
I'm
12
the
president
of
Ram
Products.
I
appreciate
the
chance
to
13
speak
in
front
of
the
Board.

14
I'll
get
on
to
one
of
the
items
I'd
like
to
15
touch
on
very
briefly.
Somebody
said
there
was
no
such
16
thing
as
a
free
lunch
this
morning.
I'm
touching
on
a
17
issue
where
I
think
there
might
be
a
free
lunch
available
18
if
we
just
bear
through
with
it.

19
I
got
into
a
situation
where
looking
at
20
evaporative
emissions
from
gas
caps
became
a
very
21
significant
issue.
The
Board
is
asking
for
an
80­
percent
22
reduction
in
gas
caps
the
way
it's
currently
used
and
23
fabricated,
and
I
support
that
specific
issue.

24
But
in
studies
that
I
had
gotten
involved
in
25
through
a
series
of
business
events,
we
ran
into
a
147
1
situation
where
the
misuse
of
gas
caps
represented
a
2
significantly
bigger
problem
in
emissions
than
the
3
emissions
from
gas
caps
themselves.
It
wasn't
just
the
4
very
fact
that
you
had
emissions,
but
it
got
deeper
into
5
the
fact
it
was
a
very
serious
safety
and
environmental
6
issue
of
great
degrees.

7
We
feel
that
the
design
of
the
gas
cap
can
8
be
handled,
and
we
also
feel
that
the
proper
use
in
9
tightening
the
gas
cap
can
be
regulated.
And
if
you
bear
10
with
us,
you'll
find
that
we
not
only
are
going
to
give
the
11
industry
a
chance
to
correct
a
problem
and
it's
going
to
12
have
a
pay
back,
but
we
also
complement
the
OBD
II
13
regulations
in
relegating
the
control
system
related
to
the
14
fuel
lines
to
actually
detecting
leaks
not
to
consumer
15
response
to
a
device
that
is
supposed
to
be
used
properly.

16
What
I'd
like
to
do
is
just
give
an
overview
17
of
a
study
or
an
assortment
of
studies
that
you
folks
have
18
got
a
copy
of
so
the
audience
knows
basically
what
I'm
19
addressing.
And
insofar
as
this
study
is
concerned,
one
of
20
the
items
I'd
really
like
to
do
is
thank
the
staff
for
21
their
Resources
Board
because
they
had
a
lot
of
data
and
22
statistics,
but
I
couldn't
extend
evaporative
numbers
or
23
some
of
the
other
critical
data
that
is
involved
in
this
24
study
without
their
contributions,
and
it
was
fantastic.

25
I
mean
that.
Hats
off
to
these
guys.

148
1
We
ran
into
a
situation
where
there
is
a
2
very
significant
community
out
there
who,
when
they
go
to
3
fuel
a
car,
cannot
close
a
gas
cap.
One
of
the
things
I
4
submitted
to
the
staff
at
the
Resources
Board
was
a
video
5
tape
that
was
aired
by
the
Arthritis
Foundation
where
they
6
had
identified
gas
caps
as
one
of
the
ten
worst
products
a
7
consumer
has
to
use.
And
then,
as
you
started
to
check
in
8
with
medical
clinics,
you
checked
in
with
the
VFW,
seniors
9
groups,
seniors
homes,
you
find
out
there
are
40
million
10
gas
caps
that
are
totally
loose
and
unused
because
people
11
can't
loosen
them
if
they
tighten
them.

12
It's
a
very
distinct
ergonomic
problem.
I
13
started
to
follow
up
on
the
issue
from
a
safety
standpoint,

14
and
I
contacted
the
NITSA.
I
talked
to
the
director
of
the
15
test
labs
out
there,
and
he
had
stated
that,
when
they
do
16
testing
on
a
vehicle,
the
most
critical
testing
done
on
a
17
vehicle
is
related
to
fuel
system
because,
if
it's
18
compromised,
it's
the
most
dangerous
part
of
the
car.

19
A
loose
gas
cap
is
a
compromised
fuel
20
system.
The
numbers
of
people
that
are
being
killed
and
21
injured
is
quite
bad.
We
won't
discuss
them
out
loud,
but
22
the
study,
if
you
want
to
read
them,
they're
not
good.

23
CHAIRMAN
DUNLAP:
So
the
bottom
line
is
24
what?

25
DICK
SHAW:
The
bottom
line
is
that
we'd
149
1
like
to
see
the
Resources
Board
consider
specifying
2
standardization
of
gas
caps,
a
standardization
of
the
3
materials
used
in
the
fabrication
of
gas
caps.

4
CHAIRMAN
DUNLAP:
Would
you
work
with
us
on
5
that?

6
DICK
SHAW:
If
I
had
gotten
the
information
7
related
to
this
meeting
about
six
weeks
earlier,
I
think
I
8
could
have
come
out
with
a
gas
cap
that
would
have
fit
the
9
bill
completely
from
the
standpoint
of
using
­­

10
CHAIRMAN
DUNLAP:
What
I'll
do,
if
my
11
colleagues
support
it,
I'll
direct
staff
to
meet
with
you
12
later
and
see
if
there
is
ways
for
us
to
plug
some
holes
13
and
work
with
you
and
take
your
ideas
if
you're
willing
to
14
part
with
them
and
see
if
we
can
tighten
this
thing
up
down
15
the
road.

16
DICK
SHAW:
Controlling
gas
cap
use
in
the
17
marketplace,
which
is
very
inclusive,
and
we
think
we
can
18
pretty
much
tie
the
loop.
If
you're
willing
to
give
19
consideration
to
it,
I
think
we'd
all
benefit.
Just
from
a
20
very
conservative
standpoint,
loose
gas
caps
­­
and
this
21
again
is
complemented
with
material
from
the
Resources
22
Board
­­
are
contributing
alone
in
the
US
alone
about
23
5
million
tons
of
gasoline
a
year
that
is
vaporized.
So
24
it's
a
nasty
issue.

25
CHAIRMAN
DUNLAP:
We
will
work
with
you
on
150
1
that.

2
Tom,
would
you
have
a
discussion
with
this
3
gentleman
and
maybe
get
back
to
us
in
a
written
memo
to
the
4
Board
in
30
days
what
you
learned
and
what
we
might
do
down
5
the
road.
Thank
you.
Thanks
for
your
patience.
Okay.

6
Andy
Frank
and
then
Bruce
Bertelsen.

7
Dr.
Frank,
good
to
see
you.

8
ANDY
FRANK:
Hello,
Board.
I'm
9
Professor
Frank
from
the
University
of
California,
Davis.

10
And
I'm
here
to
lend
support
to
the
LEV
II
proposal
and
11
especially
the
ZEF
and
the
partial
ZEF
credit
issues.

12
And
by
the
way,
this
whole
evap
problem
13
becomes
much
simpler
if
you
have
a
much
smaller
tank.

14
Instead
of
having
a
10­
gallon
or
15­
gallon
tank
if
you
only
15
have
a
6­
or
7­
gallon
tank,
steel
pressurized
tank,
the
16
sealed
tank
is
entirely
in
the
cards.
It
makes
17
manufacturing
simpler,
et
cetera,
et
cetera.

18
So
how
do
you
get
that
smaller
tank
and
19
still
have
the
range
and
still
be
able
to
tow
your
boat
and
20
so
on?
What
I've
been
working
on
is
hybrid
electric
21
vehicles,
but
hybrid
electric
vehicles
different
from
what
22
the
car
companies
are
doing,
different
than
what
Toyota
is
23
doing
in
Previas.
Our
goal
is
to
increase
fuel
economy
by
24
a
factor
of
three.
We
are
already
at
two
times.
Our
goal
25
is
to
create
a
vehicle
which
will
satisfy
both
the
EMGV
CO2
151
1
reductions
as
well
as
emissions
reductions
of
California.

2
But
of
course
want
to
do
this
in
the
same
car.

3
So
what
we
are
doing
is
­­
and
also,
we
want
4
to
satisfy
the
issue
of
an
alternative
fuel
vehicle.
All
5
our
alternative
fuel
in
this
case
will
be
electricity
from
6
the
grid,
and
this
is
the
distinct
difference
between
what
7
we
are
proposing
and
what
we
are
demonstrating
at
the
8
University
of
California
Davis
as
opposed
to
the
rest
of
9
the
world.
The
rest
of
the
world,
they're
talking
about
10
hybrids
which
are
gasoline
fed,
so
to
speak,
totally
11
gasoline
vehicles.

12
What
we
are
talking
about
is
hybrid
13
electrical
vehicles
in
which
you
plug
it
in
every
night
14
just
like
you
do
an
electric
car.
And
I'll
show
you
the
15
figures
here
in
a
few
minutes.
What
this
results
in
is
a
16
vehicle
which
is
essentially
electric.
It
will
result
in
a
17
vehicle
where
97
­­
for
fleet
of
users,
97
percent
of
the
18
energy
will
come
out
of
the
wall
plug,
but
you
won't
have
19
the
limitations
of
an
electric
vehicle.

20
The
vehicles
we
are
putting
together
now
on
21
one
charge,
because
we
don't
charge
our
batteries
with
22
gasoline,
on
one
charge,
however,
you
can
go
from
23
Sacramento
to
Los
Angeles
and
return
on
the
same
charge.

24
It's
over
a
thousand
miles.
So
that
will
make
the
electric
25
vehicle
practical.
This
has
been
the
problem.
The
152
1
electrical
vehicle,
as
envisioned
and
as
manufactured
by
2
manufacturers,
has
not
been
practical
because
the
range
is
3
not
good
enough
to
satisfy
customer
expectations,
and
this
4
is
a
way
to
answer
it.

5
So
next
slide.
What
is
a
hybrid
vehicle?

6
There
are
two
kinds
as
I
just
mentioned.
There
is
a
charge
7
sustaining.
This
is
the
Toyota
Previa.
This
is
the
PNG
8
cars
that
are
being
proposed
by
the
government
and
9
industry.
But
then
there
is
another
kind
that
we
are
10
talking
about
is
the
charge
depletion.
This
charge
11
depletion,
as
I
say,
does
not
charge
the
energy
source
with
12
liquid
fuel
on
board.
It
charges
only
off
the
wall
plug.

13
That
means
you
plug
it
in
every
night.
So
we
are
also
14
working
on
automated
charger
so
that
it
is
completely
15
seemless
to
the
user.
All
you
do
is
put
gasoline
in
it,

16
but
you
only
put
gasoline
once
every
three
months
and
then
17
you
only
use
six
or
seven
gallons.
Okay.

18
You've
also
heard
that
hybrid
vehicles
may
19
be
series
or
parallel.
We
can
forget
about
the
series
20
because
they
are
not
efficient.
We
are
building
21
mechanically
parallel,
mechanically
coupled
gasoline
and
22
electric
motors.
So
this
is
a
picture
of
the
diagram
of
23
the
power
train.
There
is
an
internal
combustion
engine.

24
There
is
the
electric
motor.
But
I
put
that
little
red
25
line
through
it
to
indicate
that
the
shaft
goes
right
153
1
through
the
electric
motor
so
we
get
electrical
energy
from
2
the
batteries
up
to
the
electric
motor.

3
We
also
can
have
gasoline
energy.
The
4
important
thing
about
this
particular
concept
is
this
5
engine
is
no
longer
that
three
liter
for
a
3,000
pound
car
6
or
the
five
liter
for
SUV.
But
rather,
this
is
a
.6
liter;

7
so
it's
been
downsized
by
a
factor
of
four.
What
this
8
means,
of
course,
is
that
the
emissions
flow
rate
is
much,

9
much
lower.
That
means
that
all
the
emissions
technology
10
that
car
guys
have
been
saying
is
going
to
be
so
hard
to
11
do,
it's
going
to
be
much
easier
to
do
because
it's
a
12
smaller
engine.
And
not
only
that,
on
the
average
this
13
engine
is
used
only
a
very
small
portion
of
the
time.

14
So
on
a
fleet
basis,
this
engine
is
only
15
used
about
3
percent
of
the
time,
which
means
you
don't
16
have
to
have
very
tight
emissions
control
and
still
meet
17
SULEV.

18
Next
one.
This
is
a
power
train
schematic
19
of
a
car
that
­­
well,
we
are
putting
two
cars
together
20
right
this
moment
with
this
power
train,
and
in
all
21
respects
this
power
train
feels
like
and
drives
just
like
22
an
electric
power
car.
There
is
a
little
gas
in
the
23
engine,
being
only
six­
tenths
of
a
liter.
It
comes
on
and
24
off,
and
you
don't
even
know
it.

25
The
key
to
it
all
is
how
do
you
control
it,

154
1
and
this
is
completely
automatic.
There
are
only
two
2
controls
in
this
car
­­
gas
pedal
and
brake
pedal.
And
3
there
is,
of
course,
a
park
and
neutral.

4
By
the
way,
with
this
kind
of
a
system,

5
there
is
no
reverse
gear.
Just
reversed
electric
motor
6
because,
if
you
notice
from
those
previous
slides,
the
7
motor,
it's
connected
directly
to
the
wheel.
So
you
can
go
8
forward
or
reverse
just
by
reversing
electric
motor.
Okay.

9
The
key
here
is
that,
until
the
batteries
10
are
half
discharged,
the
gasoline
engine
doesn't
come
on
11
until
above
60
miles
an
hour.
And
after
the
batteries
are
12
half
discharged,
then
you
start
to
bring
the
gasoline
13
engine
on
at
the
lower
speed.
But
at
50
percent
of
the
14
discharge
with
the
concept
we
are
talking
about,
we
have
a
15
fairly
large
battery
pack,
almost
two­
thirds
the
size
of
an
16
electric
car.
You
have
covered
60
miles
of
range.
And
17
that
means
80
percent
of
the
people
who
are
driving
this
18
car
have
done
their
commute
and
everything
all
19
electrically.

20
Of
course,
you're
always
going
to
get
some
21
guy
who
is
going
to
want
to
go
250
miles
a
day
of
city
22
driving
which,
by
the
way,
is
18
hours,
and
that
guy
will
23
use,
of
course,
more
gasoline.
But
he
will
have
also
24
depleted
his
batteries.
He's
used
as
much
battery
as
he
25
can.

155
1
CHAIRMAN
DUNLAP:
Professor
Frank?

2
ANDY
FRANK:
Why
don't
we
skip
to
the
next
3
slide
then.

4
CHAIRMAN
DUNLAP:
I'm
impressed
with
your
5
commitment.
I've
known
you
for
a
while.
I
know
how
6
committed
you
are
to
this,
and
I'm
grateful
to
you
for
7
coming
and
telling
us
your
support
where
we
are
trying
to
8
go
and
that's
meaningful.
Matter
of
fact,
I'm
so
9
impressed,
I
hope
to
send
my
son
to
study
under
you
one
10
day.
So
you've
got
me
with
you.

11
What
would
you
have
us
know
different
than
12
what
we
kind
of
already
know
about
your
feelings?
What
is
13
the
key
thing
you
want
us
to
know
today?

14
ANDY
FRANK:
I
think
this
is
the
key
here,

15
that
if
we
stick
with
our
partial
ZEV
credits
for
hybrid
16
vehicles
and
you
encourage
off­
wall,
I
mean,
off­
board
17
charging
out
of
the
wall
and
you
build
it
the
way
we
are
18
talking
about,
we
can
talk
about
reducing
the
use
of
19
gasoline
fuel
to
3
percent
of
a
conventional
car.
And
that
20
means
97
percent
of
the
energy
comes
out
of
the
wall
plug.

21
In
all
respects,
we
have
an
electric
car
except
we
don't
22
have
the
range
power.
So
this
is
really
the
bottom
line.

23
CHAIRMAN
DUNLAP:
Great.
And
you
like
where
24
we
are
going
with
this
package?
Is
that
what
I
gather?

25
ANDY
FRANK:
Right.
And
I
think
the
mandate
156
1
should
be
continued.
Some
people
say
mandates
are
just
2
from
car
guys,
but
mandate
is
important
because
this
is
3
what
spurs
this
kind
of
technology
to
advance.

4
CHAIRMAN
DUNLAP:
Thank
you
very
much.
And
5
I'm
pleased
that
you're
involved
with
this
process.
It's
6
important.
Any
questions?
Very
good.

7
Bruce,
you're
up
next.
We
are
going
to
8
change
the
court
reporter
here.
Can
you
go
with
one
more?

9
Go
ahead,
Bruce.
Welcome.
Bruce
Bertelsen,
MECA.

10
BRUCE
BERTELSEN:
Good
afternoon.
MECA
is
11
pleased
to
have
the
opportunity
to
testify
today
in
support
12
of
the
proposed
LEV
II
Program.
We
commend
the
Board
for
13
your
continuing
efforts
to
implementing
effective
programs
14
to
protect
public
health
of
the
people
who
live
in
15
California.
We
also
want
to
take
the
opportunity
to
16
compliment
the
staff
on
what
we
thought
was
an
extremely
17
thorough
analysis
and
evaluation
of
the
technological
18
issues
supporting
this
proposal.

19
Today
the
Board
faces
an
important
and
20
certainly
challenging
decision.
And
I
think
in
that
21
regard,
it's
instructive
to
look
back
briefly
to
1990
when
22
the
LEV
Program
was
first
proposed.
At
the
time,
that
23
proposal
was
viewed
by
most
as
revolutionary,
and
I
think
24
indeed
it
was.
And
from
many,
it
was
viewed
as
infeasible.

25
I
went
back
and
looked
at
our
testimony
that
157
1
we
gave
back
in
1990,
and
MECA
made
several
points.
First,

2
that
the
LEV
Program
was
technology
forcing;
but,
second,

3
it
would
stimulate
important
technological
advances;
third,

4
there
were
significant
challenges
facing
compliance
with
5
that
program,
but
we
did
express
our
optimism
that
those
6
challenges
could
be
met.

7
Eight
years
later,
that
program
is
on
or
8
ahead
of
schedule,
certainly
from
the
technological
point
9
of
view.
The
technologies
that
are
being
used
to
meet
the
10
standards
are
less
complex
than
I
think
anybody
thought.

11
And
the
cost
of
those
technologies
are
below
what
I
think
12
anyone
estimated.

13
Today,
with
this
proposal,
again,
there
are
14
significant
challenges.
But
we
think
in
this
case
actually
15
the
technological
pathway
to
meeting
those
challenges
is
16
actually
clearer
than
it
was
in
1990
where
it
looked
like
17
we
were
going
to
need
breakthrough
technologies.

18
The
state
to
which
catalyst
technology
has
19
advanced
and
will
continue
to
advance
is
extremely
20
promising
and
encouraging.
I
think
there
are
a
number
of
21
engine
and
fuel
control
strategies
that
are
beginning
to
be
22
introduced
that
can
be
applied
to
other
vehicles.
And
it
23
seems
clear
to
us
today,
just
as
clear
today
as
it
did
in
24
1990,
that
if
the
Board
implements
this
program,
you
will
25
stimulate
important
and
significant
technology
158
1
advancements.

2
With
regard
to
the
technological
3
feasibility,
I
think
the
staff
report
outlined
a
variety
of
4
technical
options
that
are
available
and
presented
some
5
test
data.
MECA
conducted
a
test
program
of
its
own,

6
reevaluated
three
vehicles
that
met
the
tier
one
7
standards
­­
not
the
LEV
standard,
not
the
ULEV
standards.

8
But
we
took
US
Federal
tier
one
vehicles,
equipped
them
9
with
advanced
catalyst
systems,
modified
some
of
the
10
controls,
aged
the
catalysts,
and
those
vehicles
­­
one
was
11
an
eight­
cylinder
passenger
car,
a
Ford
Crown
Vic;
we
had
a
12
six­
cylinder
light­
duty
truck,
a
Toyota
T100;
and
a
six
13
cylinder
passenger
car,
a
Buick
Le
Sabre.
And
those
14
vehicles
did
achieve
the
LEV
II
ULEV
120,000
mile
15
standards.
A
copy
of
that
report
is
included
in
the
16
testimony.

17
We
think
that
the
types
of
strategies
that
18
are
being
used
and
introduced
on
passenger
cars
can
be
19
applied
to
other
categories
of
vehicles,
the
heavier
weight
20
vehicles.
Looking
at
the
work
that
the
staff
did
on
the
21
Ford
vehicle,
I
guess
our
perspective
is
a
little
bit
22
different.
We
think
it's
remarkable
what
was
accomplished
23
by
the
staff
in
a
relatively
short
period
of
time
by
a
24
group
of
individuals
who
are
not
auto
manufacturers.

25
So
from
our
perspective,
the
glass
looks
159
1
half
full
or
maybe
even
three­
quarters
full
rather
than
2
half
empty.
The
types
that
we
were
pleased
to
provide
3
catalyst
technology
program.
That
catalyst
technology
is
4
reflective
of
what
is
available
today.
I'm
very
optimistic
5
that
the
catalyst
technology
of
tomorrow
is
going
to
be
6
even
better.
And
we
see
no
reason
why
these
types
of
7
strategies
cannot
be
applied
to
other
vehicles.

8
One
point
that
was
brought
up
earlier
9
regarding
temperature
and
that
is
an
issue
with
heavier
10
vehicles.
Heavier
vehicles,
particularly
those
who
are
11
operating
in
a
commercial
mode,
will
generate
higher
12
exhaust
temperatures.
I
think
it's
important
to
point
out,

13
however,
at
least
with
regard
to
the
catalyst
technology,

14
over
the
past
five
years
there
have
been
incredible
15
advances
in
the
thermal
durability
of
the
catalyst
16
technology.
So
we
don't
see
that
as
a
barrier
to
applying
17
advanced
catalyst
technology
to
heavier
vehicles.

18
I
did
just
want
to
say
a
quick
word
about
19
diesel
vehicles,
and
I'm
sure
you'll
have
some
other
20
discussion
later
this
afternoon.
Our
philosophy
has
always
21
been
fuel
neutral.
We
are
prepared
to
provide
technical
22
solutions
to
any
type
fuel,
and
that
includes
diesels.
We
23
believe
that
the
proposal
that
the
staff
has
developed
with
24
regard
to
diesel
will
provide
flexibility
to
permit
the
25
development
and
evolution
of
the
diesel
vehicle
to
a
point
160
1
where
it
is
extremely
clean,
and
we
support
that
proposal.

2
Our
companies
are
working
on
a
number
of
3
technologies,
exhaust
control
technologies
for
diesels.
I
4
should
point
out
though
that
some
of
these
technologies,

5
like
lean
NOx
catalysts,
NOx
absorbers,
some
types
of
6
particulate
filters
will
require
a
lower
sulfur
level
than
7
is
currently
available
and
therefore
we
encourage
the
8
Board,
at
a
subsequent
time,
to
begin
to
look
at
the
issue
9
of
lower
sulfur
fuel.
I
guess
I'll
wrap
­­

10
CHAIRMAN
DUNLAP:
I
think
we
are
willing
to
11
talk
about
and
contribute.
I
mean,
this
Board
has
been
12
willing
to
tackle
fuel
issues,
but
we
can't
go
there
alone,

13
as
you
know.

14
BRUCE
BERTELSEN:
In
closing,
again,
I
don't
15
want
to
understate
the
fact
that
there
are
technology
16
changes,
but
I
think
the
proposal,
as
it's
crafted,
offers
17
a
lot
of
the
flexibility
and
it
also
offers
some
safety
18
valves.
And
I
think
that,
if
the
program
is
implemented,

19
you
will
see
a
significant
stimulation
in
technical
20
effort.
We
think
the
end
result
will
be
vehicles,
a
wide
21
choice
of
vehicles
that
are
fuel
efficient,
high
22
performance
vehicles
that
are
extremely
clean,
and
I
want
23
to
state
on
behalf
of
our
all
members
that,
if
the
Board
24
adopts
this
program,
we
are
prepared
to
do
our
part
to
make
25
LEV
II
the
kind
of
success
story
that
LEV
I
has
been.

161
1
CHAIRMAN
DUNLAP:
Thank
you.
Any
questions
2
for
Mr.
Bertelsen?
All
right.
Good
deal.

3
Roland,
you're
up.
Now
you
want
to
be
a
4
floor
manager
here;
right?
You've
got
two
or
three
of
your
5
colleagues
you're
going
to.

6
ROLAND
HWANG:
That's
correct.
We
have
a
7
few
of
my
environmentalists
colleagues
that
also
wanted
to
8
emphasize
the
points,
which
I
will
provide
­­

9
CHAIRMAN
DUNLAP:
You
need
a
little
more
10
time
­­

11
ROLAND
HWANG:
Yes.
I
have
overheads.

12
Hopefully
we
can
move
through
this
­­

13
CHAIRMAN
DUNLAP:
Which
I'll
give
you.
Who
14
else
are
you
going
to
bring
up
with
you?

15
ROLAND
HWANG:
I
think
Janet
Hathaway
is
16
coming
up
after
me
and
then
Bonnie
Holmes.

17
CHAIRMAN
DUNLAP:
Okay.
Where
is
Janet?

18
I'll
give
you
the
time,
but
I
want
you
to
manage
it
as
19
efficiently
as
you
can.
So
Janet
Hathaway,
Bonnie
Holmes,

20
when
they
get
here
will
come
up
with
you.
After
that,

21
we'll
have
Aaron
Lowe,
Tim
Riley,
Lynn
Cardwell,
Johan
22
Gallo.
Well,
does
Joe
Caves
want
to
be
part
of
your
group?

23
Is
Joe
here?

24
ROLAND
HWANG:
Joe
is
going
to
go
a
little
25
bit
later.

162
1
CHAIRMAN
DUNLAP:
Okay.
Chris
Walker,
John
2
Valencia.
So
those
folks
can
come
over
here
and
sit.

3
Go
ahead,
Roland.

4
ROLAND
HWANG:
Thank
you,
Mr.
Dunlap.
Union
5
of
Concerned
Scientists
appreciates
this
opportunity
to
6
provide
comments
to
the
Board
and
the
Chairman
on
this
7
extremely
important
program
for
the
future
of
California's
8
air
quality.

9
I
know
that
you
folks
have
a
lot
of
paper
in
10
front
of
you;
so
I've
provided
my
written
comments
and
11
overheads
in
this
green
covered
report.
I
hope
it
stands
12
out
a
little
bit
from
all
the
other
piles
of
paper
you
have
13
in
front
of
you.

14
I
think
I
want
to
build
actually
on
what
15
Bruce
Bertelsen
just
said.
We
believe
this
program,
as
16
proposed,
we
admit
it's
a
very
aggressive
program,
but
we
17
do
believe
the
staff
has
done
an
incredible
amount
of
work,

18
very
thorough
work,
and
we
believe
the
program
is
19
technically
sound.
And
like
Bruce
said,
we
believe
the
20
program
is
not
a
whole
lot
different
than
what
ARB
21
traditionally
has
done,
especially
as
recently
as
1990
with
22
the
LEV
Program.

23
This
program
is
a
combination
of
24
off­
the­
shelf
technology,
which
I
hope
that
most
the
Board
25
members
did
get
a
chance
to
go
outside
and
see
those
163
1
Expeditions
and
see
the
catalysts.
Nothing
exotic.
I
2
didn't
see
anything
which
had
a
$
7,000
price
tag
on
it.

3
This
is
off­
the­
shelf
technology.
It
is
a
combination
of
4
that,
and
it's
a
combination
of
technology
forcing.

5
Traditionally,
this
is
what
the
Air
Board
has
done
and
has
6
done
very
well.
So
with
that
introduction,
let
me
go
to
my
7
first
slide.

8
And
as
an
overview,
we
have
delivered
a
9
letter
to
the
Board
Chairman
and
staff
with
our
number
of
10
recommendations,
and
I
wanted
to
go
through
the
top
three
11
recommendations
which
we
wanted
to
present
to
you
as
a
way
12
of
strengthening
the
ARB
proposal.
Again,
we
believe
the
13
ARB
proposal,
the
bulk
of
it,
is
extremely
sound.
We
do
14
have
some
concern
about
certain
issues.
And
again,
this
15
letter
was
signed
by
a
number
of
different
environmental
16
groups
as
listed
above.

17
The
first
issue
that
we
have
raised
is
this
18
issue
of
diesel
vehicles
in
our
light­
duty
fleet.
We
are
19
concerned
that
introduction
of
these
diesel
vehicles,
which
20
clearly
the
automobile
companies
have
plans
for
and
that's
21
exactly
why
AMA
has
proposed
more
relaxed
standards
for
22
PM10
in
their
counter
proposal
to
the
Board.
Auto
23
companies
clearly
have
plans
for
diesel
introduction.

24
We
are
obviously
concerned
about
25
implications
for
the
increase
in
the
diesel
exhaust
164
1
particulates,
especially
since
the
Board
just
two
months
2
ago,
I
believe,
identified
diesel
exhaust
as
a
toxic
air
3
contaminant.
I
don't
really
want
to
be
making
the
problem
4
worse
here.
We
need
to
be
trying
to
address
problem
with
5
heavy­
duty
vehicles
sector,
obviously.

6
Second
is
that
we
all
have
concerns.
We
7
have
had
long
discussions
with
staff
about
this.
We
have
8
concerns
about
this
ZEV
Program
being
watered
down
too
9
much.
We
do
believe
the
program
should
flex,
but
10
shouldn't
allow
in
some
of
the
gasoline
SULEVs
which
do
not
11
have
electric
drive
technology.
We
believe
the
hybrids
and
12
fuel
cell
vehicles
are
appropriate
to
get
partial
ZEF
13
credit
because
they
get
us
toward
the
true
ZEV
category.

14
Finally,
we
believe
all
8,500
pound
vehicles
15
staff
has
shown
as
demonstrated
that
technologically
16
feasible
during
all
8,500
pound,
even
the
work
trucks,
to
17
the
same
standards
as
passenger
cars.
So
we
believe
18
actually
that
4­
percent
work
truck
exemption,
we
question
19
the
reason
for
why
it
should
be
there.

20
But
also,
we've
heard
a
lot
this
morning
21
about
the
AAMA's
proposal,
their
counter
proposal.
We
want
22
to
make
it
clear
to
the
Board
that
we
feel
like
this
23
proposal
should
be
soundly
rejected
because
it
does
not
24
meet
the
California
air
quality
needs,
does
not
provide
the
25
equivalent
pollution
reductions.
That's
by
the
AAMA's
own
165
1
admissions.
And
by
the
way,
my
understanding
of
the
2
trade­
offs
they're
making
with
the
vehicle
categories
less
3
than
6,000
pounds,
where
they
are
trading
off
some
­­
they
4
claim
they're
tightening
the
ULEV
standard
and
trading
off
5
or
laxing
the
LEV
standard
for
passenger
cars.

6
That
proposal
actually
loses
2
tons
per
7
day.
They're
not
offsetting
that
in
the
lower.
So
they
8
may
claim
that
they
are
trying
to
offset
more
relaxed
LEV
9
standards.
My
understanding
from
staff
is
they
have
not
10
fully
offset
it.
The
other
reason,
of
course,
that
we
want
11
you
to
reject
AAMA's
proposal
is
this
question
of
diesel,

12
which
I'll
get
into
a
little
bit
more.
But
it's
a
13
potential
for
substantial
increases
in
diesel
as
a
toxic
14
air
contaminant
in
our
air.

15
Finally,
the
ARB
proposal,
from
our
16
evaluation,
is
technically
feasible
and
cost­
effective.

17
California
needs
every
ton
of
emission
reductions
you
can
18
get.

19
*
*
*

20
21
22
23
24
25
166
1
2
STATE
OF
CALIFORNIA
)
)
ss.
3
COUNTY
OF
LOS
ANGELES
)

4
5
I,
Lynne
R.
Rutledge,
CSR
11091,
a
Certified
6
Shorthand
Reporter
in
and
for
the
State
of
California,
do
7
hereby
certify:

8
That
the
foregoing
proceeding
was
taken
down
9
by
me
in
shorthand
at
the
time
and
place
named
therein
and
10
was
thereafter
reduced
to
typewriting
under
my
supervision;

11
that
this
transcript
is
a
true
record
of
the
testimony
12
given
by
the
witnesses
and
contains
a
full,
true
and
13
correct
record
of
the
proceedings
which
took
place
at
the
14
time
and
place
set
forth
in
the
caption
hereto
as
shown
by
15
my
original
stenographic
notes.

16
I
further
certify
that
I
have
no
interest
in
17
the
event
of
the
action.

18
EXECUTED
this
17th
day
of
November
1998.

19
20
_____________________________

21
Lynne
R.
Rutledge,
CSR
#
11091
22
23
24
25
1
CALIFORNIA
AIR
RESOURCES
BOARD
2
3
4
5
6
PUBLIC
HEARING
TO
CONSIDER
THE
"
LEV
II"
)
AND
"
CAP
2000"
AMENDMENTS
TO
THE
)
7
CALIFORNIA
EXHAUST
AND
EVAPORATIVE
)
EMISSION
STANDARDS
AND
TEST
PROCEDURES
)
8
FOR
PASSENGER
CARS,
LIGHT­
DUTY
TRUCKS
)
98­
12­
1
AND
MEDIUM­
DUTY
VEHICLES,
AND
TO
THE
)
9
EVAPORATIVE
EMISSION
REQUIREMENTS
FOR
)
HEAVY­
DUTY
VEHICLES.
)
10
___________________________________________)

11
12
TRANSCRIPT
OF
PROCEEDINGS
13
November
5,
1998
14
9530
Telstar
Avenue
15
El
Monte,
California
16
17
18
19
20
21
22
23
REPORTED
BY:
24
Terri
L.
Emery
CSR
No.
11598
25
Our
File
No.:
1­
49953
1
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
326­
5900
1
APPEARANCES
OF
BOARD
MEMBERS:

2
Chairman
DunlapMr.
Calhoun
Supervisor
DeSaulnier
3
Ms.
Edgerton
4
Dr.
Friedman
Mr.
Parnell
5
Supervisor
Patrick
Mrs.
Rakow
6
Ms.
Riordan
7
Supervisor
Roberts
Supervisor
Silva
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
326­
5900
1
I
N
D
E
X
2
Public
Comments
PAGE
Roland
Hwang
(
co
ntinued)
167
3
Janet
Hathaway
179
Bonnie
Holmes­
Gen
186
4
Patrick
Pudell
201
Aaron
Lowe
202
5
Tom
Riley
205
Lynn
Cardwell
206
6
Johan
Gallo
208
Chris
Walker
210
7
John
Valencia
211
Bob
Warden
215
8
Mike
Villegas
216
Ellen
Garvey
219
9
Chung
Lui
222
Greg
Vlasik
226
10
Cece
Martin
227
Jennifer
Jennings
233
11
ALABC
Representative
235
Terence
Poles
235
12
William
Rosenberg
242
Jed
Mandel
246
13
Pat
Charboneau
248
Bob
Jorgenson
250
14
Tim
Carmichael
258
Joe
Caves
262
15
Sumary
of
Letters
Received
by
Board
267
16
Close
of
Record
271
17
Ex
Parte
Communications
271
18
Motion
on
Revised
Proposed
Resolution
291
19
Motion
­
Delete
.2
Partial
ZEV
Credit/
Gasoline
292
20
Result
of
Motion
to
Delete
Partial
Credit
297
21
Motion
­
Delete
TLEV
Standards
in
Staff
Proposal
298
22
Result
of
Motion
to
Delete
TLEV
Standards
304
23
Result
of
Motion
to
Adopt
LEV
II
with
Exception
of
TLEV
Standards
305
24
Open
Comment
Period
305
25
3
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
326­
5900
1
MR.
HWANG:
At
U
of
C
we
agree
that
every
2
ton
counts
at
this
point.
We
need
to
make
continued
3
progress
on
the
1994
ozone
SIP
obligations
including
M­
2
4
and
the
black
box.
Even
larger
amounts
of
reductions
are
5
necessary
for
PM2.5
attainment
in
the
future.
That
will
6
come
to,
I
believe,
around
the
year
2003.
We
need
to
be
7
setting
ourselves
up
now.
That's
going
to
require
large
8
amounts
of
nitrogen
oxide
emission
reductions.
LEV
II,
I
9
would
say,
is
vital,
absolutely
necessary,
if
we
are
going
10
to
meet
the
2.5
standards.

11
Finally,
for
7
tons
is
not
just
7
tons
of
12
loss.
The
Air
Board
I
know
has
been
extremely
diligent
13
about
pursuing
every
possible
measure
as
long
as
it's
14
technically
feasible
and
cost
effective.
A
variety
of
15
measures
were
adopted
in
the
1974
ozone
SIP.
Five
measures
16
I
counted
at
less
than
10
tons
per
day
benefits
and
17
fortunately
the
on­
road
motorcycle
controls
too,
which
is
18
probably
a
couple
of
tons.

19
I
want
to
jump
to
my
third
point
because
I
20
think
there's
been
a
lot
of
discussion
this
morning
about
21
the
feasibility
of
the
6000­,
8500­
pound
vehicles
to
meet
22
the
passenger
car­
type
standards.
We
believe
that
in
fact
23
not
only
is
it
feasible,
but
the
4
percent
work
truck
24
exemption
is
not
necessary.

25
Our
understanding
is
that
CARB
took
the
Ford
167
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
326­
5900
1
Expedition
you
see
outside
and
gauge
it
over
cycle
which
2
simulated
the
towing
drive
cycle
of
a
Ford
pickup
truck
3
that
weighs
10,000
GVW
that
can
tow
14,000
pounds.
This
is
4
the
worst
case
scenario.
This
is
a
work
truck­
type
5
scenario.
This
is
a
work
truck
that
goes
beyond
the
6
8500­
pound
cutoff,
so
it
seems
to
us
staff
has
really
7
demonstrated
that
this
can
be
done
for
work
trucks.

8
Furthermore,
I
think
we've
also
talked
about
9
the
amount
of
lead
time
the
automobile
companies
have,

10
whether
it
be
8
years
or
maybe
­­
Kevin
from
General
11
Motors,
maybe
it's
6
years,
but
the
standards
do
not
fully
12
roll
into
2007,
which
means
that
there's
quite
a
bit
of
13
leeway.

14
And
of
course
we
talked
about
there's
the
15
ability
for
the
manufacturers
for
technicatalyst
currently
16
allowed
in
regulations
to
protect
the
catalyst
from
towing
17
conditions
by
which
they
are
fueled.
Currently
in
the
18
regulations
I
understand
staff
continues,
will
continue
19
that
provision.
There
doesn't
appear
to
be
any
kind
of
20
legitimate
argument
to
make
the
catalyst
to
be
burned
out.

21
CHAIRMAN
DUNLAP:
Do
you
think
we
ought
to
22
cut
this
out
and
take
this
out
of
the
package
and
certainly
23
I'd
go
to
15.
Okay.

24
MR.
HWANG:
That's
right.
That's
right.

25
That's
our
recommendation.
168
BARNEY,
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1
CHAIRMAN
DUNLAP:
All
right.

2
MR.
HWANG:
Again,
one
of
the
main
points
3
you
will
see
today
I
think
from
our
fellow
enviros
is
the
4
issue
of
diesel.
Why
should
we
allow
diesel
into
our
light
5
duty
vehicle
fleet,
all
be
it
there
are
fuel
economy
6
benefits.

7
The
Union
of
Concerned
Scientists
and
other
8
environmentalists
deeply
care
about
cutting
the
issue
of
9
emissions.
However,
we
don't
believe
it's
appropriate
or
10
necessary
for
that
fuel
economy
bench
to
come
at
the
11
expense
of
public
health.
We
believe
that
the
ARB
TLEV
12
standards
themselves
are
too
weak.
They
should
be
13
tightened
to
help
protect
the
levels,
the
gasoline
14
equivalent
levels,
or
the
TLEV
category
should
be
phased
15
out
completely.

16
Let
me
try
to
drive
home
a
point
here
with
17
the
next
slide.
This
is
the
potential
for
diesel,

18
light­
duty
diesel
vehicles
to
penetrate
into
our
passenger
19
vehicle
fleet
under
AAMA's
proposal
and
under
ARB's
20
proposals
also,
and
as
you
can
see
there
could
be
as
high
21
as
we
estimate
a
20­
percent
penetration
with
AAMA's
22
proposal
which
could
lead
to
the
next
slide,
a
tremendous
23
increase
in
diesel
exhaust
particulates
from
on­
road
24
vehicles.

25
This
is
a
­­
you
know,
this
is
not
just
us
169
BARNEY,
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1
crying
wolf.
This
is
a
very
real
type
of
scenario
of
what
2
we
could
be
seeing
in
the
future.
Manufacturers
have
3
doubled
the
sales
in
the
heavy
and
light
trucks
in
the
last
4
five
years.
We
are
fuel
neutral.
We
are
technology
5
neutral.
However,
we
cannot
trade
off
environmental
goals
6
one
for
another,
especially
when
technologies
are
available
7
to
address
both.

8
As
I
mentioned
before,
we
are
­­
Union
of
9
Concerned
Scientists
is
supportive
of
allowing
hybrids
and
10
methanol
fuel
cells
for
partial
ZEV
credit,
but
we
are
11
opposed
to
gasoline
SULEVs.
We
had
long
discussions
with
12
staff
about
this
and
I
expect
we
will
have
continued
13
discussions,
but
we
are
recommending
to
drop
that
provision
14
of
allowing
the
conventional
gasoline
SULEV
to
qualify
to
15
receive
credit.
16
CHAIRMAN
DUNLAP:
How
does
that
square
with
17
your
fuel
neutral
policy
that
you
just
espoused
a
moment
18
ago?
You're
fuel
neutral,
but
you
don't
want
to
give
19
gasolines
credit
even
if
they're
cleaner
than
gasoline
20
powered
SULEVs
credit.

21
MR.
HWANG:
The
ZEV
program
­­

22
CHAIRMAN
DUNLAP:
That's
a
neat
trick.
If
I
23
could
figure
out
how
to
do
that
in
other
areas,
we
could
do
24
a
lot
of
different
things,
but
that
doesn't
feel
right
to
25
me.
170
BARNEY,
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MR.
HWANG:
It
is
our
belief
the
ZEV
program
2
is
a
program
intended
to
commercialize
true
zero
emitting
3
vehicles,
battery­
electric
vehicles
and
hydrogen
fuel
cell
4
vehicles.
That
is
the
goal,
and
the
10­
percent
level
is
5
the
level
to
ensure
a
marketplace
in
which
they
can
6
compete.

7
CHAIRMAN
DUNLAP:
Also,
we
kind
of
squeaked
8
away
the
power
plant
emissions.
There's
some
issues
there,

9
too.
It's
not
quite
pure.
It's
not
a
big
point
with
me,
I
10
just
kind
of
want
to
let
you
know
where
I'm
coming
from.

11
MR.
HWANG:
Our
point
is
this.
We
agree
12
there
should
be
some
flexibility
in
the
ZEV
program
as
long
13
as
it
gets
us
towards
those
technologies
which
we
need
to
14
solve,
not
just
our
ozone
problems
but
to
solve
the
fine
15
particulates
problem,
our
air
toxics
problems
and
our
16
climate
change
problems
in
the
future.

17
A
gasoline
SULEV
gives
us
air
quality
18
benefits.
However,
it's
not
going
to
help
us
kick
the
oil
19
habit,
it's
not
going
to
reduce
the
air
toxics,
it's
not
20
going
to
help
us
with
contamination.

21
CHAIRMAN
DUNLAP:
Okay.

22
MR.
HWANG:
Other
recommendations
that
kind
23
of
summarize
our
letter
is
that
first
of
all,
we
believe
24
that
we're
supportive
of
ARB
extending
the
durability
25
requirements.
We
think
that
is
an
extremely
crucial
171
BARNEY,
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1
component
of
ensuring
that
vehicles
are
clean
in
use
and
2
that
the
burden
of
cleaning
up
the
vehicles
does
not
3
continue
to
fall
upon
drivers
under
the
inspection
and
4
maintenance
programs.
It's
a
very
excellent
program,
but
5
very
burdensome
also.
Some
communities
believe
that.

6
Five
is
strengthen
the
CAP
2000.
We
would
7
like
to
discuss
more
with
staff
post
this
hearing
about
8
that.

9
Six
is
that
we
want
to
make
sure
the
ozone
10
eating
technologies
­­
we
are
in
favor
of
innovative
11
technologies.
We
want
to
make
sure
that
the
ozone
eating
12
technology
is
fully
evaluated
before
the
methodology
is
13
finalized.
We
would
like
the
process
for
finalizing
that
14
credit
be
a
stakeholder
open
process.

15
Finally,
separately
from
LEV
II,
we
do
16
believe
the
ARB
should
consider
strengthening
the
fuel
17
standards
that
are
cost
effective.

18
In
conclusion,
I
think
the
Board
today
were
19
really
looking
and
we
support
ratification
of
the
LEV
II
20
program.
We
believe
in
strengthening
the
proposal
in
the
21
three
ways
that
we
recommended.

22
Finally,
we
really
implore
you
to
reject
23
AAMA's
proposal
because
it
does
not
meet
California's
air
24
quality
needs.
You
can't
put
7
tons
here
when
it
certainly
25
won't
be
cost
effective
and
will
be
difficult
to
find
it
172
BARNEY,
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1
elsewhere,
and
we're
very
concerned
about
the
increase
in
2
diesel
emissions.

3
CHAIRMAN
DUNLAP:
Okay.
Very
good.

4
Janet,
are
you
up
next?

5
MS.
EDGERTON:
Can
I
ask
something?

6
CHAIRMAN
DUNLAP:
We
can
interject
if
you
7
want,
but
I
kind
of
wanted
to
move
through
this.

8
MS.
EDGERTON:
I
wanted
to
focus
on
two
9
areas
that
you
specifically
recommended.
One
is
the
point
10
that
you
made
about
not
relaxing
pollution
standards
for
11
diesel
and
indicating
that
the
TLEV
standards
are
nine
12
times
higher
for
NOx
and
four
times
higher
than
PM10
at
LEV
13
for
standards
at
120,000
miles.

14
What
I
want
to
ask
the
staff,
this
just
15
seems
to
make
a
lot
of
sense
to
me.
I
think
we
just
got
16
$
25
million,
in
fact,
I
know
we
just
got
$
25
million
­­

17
worked
very
hard
to
get
that
with
the
legislature
and
the
18
environmentalists
and
the
Governor.
That
was
appropriated
19
by
the
legislature
to
Air
Resources
Board
to
help
to
retire
20
dirty
diesel
vehicles
from
the
road.
And
I
know
we're
21
going
to
need
another
$
75
million
over
the
next
three
years
22
to
retire
heavy­
duty
diesel,
particularly
heavy
polluting
23
diesel
vehicles
from
our
roads.
That
happened
over
this
24
summer.

25
In
addition,
as
you
all
know
and
as
you
173
BARNEY,
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1
mentioned,
nine
years
of
study
was
concluded
and
finding
2
that
diesel
particulates
is
a
toxic
air
contaminant.
Why
3
would
we
have
a
measure
in
here
which
provides
that
4
light­
duty
vehicles
which
are
diesel
get
to
be
polluting
5
more
starting
in
the
year
2004,
five
years
away?

6
MR.
KENNY:
The
TLEV
standard
basically
was
7
proposed
as
part
of
LEV
I
in
order
to
essentially
provide
a
8
maximum
level
of
flexibility
to
the
manufacturers
to
meet
9
the
average
standard.
The
average
standard
continues
as
10
part
of
LEV
II
to
go
down
from
2004
to
2010.
What
we
are
11
proposing
with
regard
to
the
TLEV
standard
is
that
we
12
maintain
it
and
that
we
maintain
it
through
2007
with
13
regard
to
the
existing
TLEV
standard.
That
TLEV
standard
14
would
then
phase
out.

15
There
is
an
alternative
to
the
TLEV
16
standard,
however,
that
would
begin
in
2004,
and
that
TLEV
17
standard
would
then
basically
go
forward
through
2010
with
18
an
incremental
reduction
in
2007.
The
benefit
of
all
that
19
is
we
are
trying
to
set
up
a
scenario
in
which
we
are
able
20
to
address
the
heavy­
duty
sector
and
the
need
that
we
have
21
in
the
heavy­
duty
sector
for
the
development
of
the
NOx
22
catalysts
are
fairly
high
efficiency
in
order
to
get
fairly
23
substantial
reductions
there
because
the
NOx
inventory
for
24
that
heavy­
duty
sector
is
so
large.

25
We
don't
see
the
incentive
in
that
174
BARNEY,
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1
heavy­
duty
sector
to
develop
that
catalyst
on
its
own.
We
2
do
think
that
in
fact
we
can
drive
these
types
of
numbers
3
down,
and
we
are
talking
about
the
TLEV
numbers
going
down
4
from
where
they
currently
are,
that
in
fact
we
provide
a
5
very
good
incentive
to
develop
some
level
of
catalystic
6
advancement
that
will
allow
us
to
then
take
that
and
7
transfer
it
to
the
heavy­
duty
sector.

8
The
benefit
from
an
overall
perspective
is
9
that
the
market
penetration
in
the
light­
duty
sector
is
10
fairly
small,
and
yet
if
we
can
get
those
catalysts
11
developed,
what
we
get
in
the
heavy­
duty
sector
is
the
12
opportunity
for
very
substantial
emission
reductions.
So
13
that
is
our
basic
theory
behind
what
we're
trying
to
do
14
here.

15
MS.
EDGERTON:
I
know
these
are
very
16
difficult
balls
and
strikes
to
call,
and
I
appreciate
that,

17
and
you
may
be
right.

18
I
do
make
the
comment
that
it
seems
like
­­

19
it's
overwhelmingly
clear
we're
robbing
Peter
to
pay
Paul,

20
and
it
does
not
­­
we're
trying
to
do
something
in
the
21
light­
duty
sector,
light­
duty
vehicle
area
that
will
help
22
the
heavy­
duty
vehicle
area.

23
My
question
is
why
don't
we
just
do
it
in
24
the
heavy­
duty
sector
and
let
the
light­
duty
sector
which
25
currently
does
not
have
significant
diesel
­­
175
BARNEY,
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1
MR.
KENNY:
I
think
the
answer
to
that,
if
I
2
might,
is
what
we're
trying
to
do
here
is
set
a
very
3
aggressive
alternative
TLEV
standard.

4
When
you
look
at
it
in
the
year
2007,
it
5
really
requires
substantial
advancement
for
compliance
to
6
occur,
and
in
fact
that
compliance
does
occur.
The
market
7
penetration
even
in
the
light­
duty
sector
is
still
8
relatively
small,
and
yet
if
that
advancement
occurs,
the
9
opportunities
on
the
heavy­
duty
side
where
the
incentive
10
does
not
really
exist
can't
be
taken
advantage
of,
and
we
11
will
be
able
to
transfer
that
technology
over.

12
On
the
other
hand,
if
in
fact
for
some
13
reason
manufacturers
cannot
get
to
the
point
where
they
can
14
meet
the
2007
standards,
then
we
have
a
safety
valve
there.

15
The
safety
valve
is
in
fact
they
don't
have
that
standard
16
essentially
available
to
them
in
terms
of
light­
duty
17
compliance
because
it
guides
you
down
to
very
low
numbers,

18
low
numbers
in
terms
of
hydrocarbon,
low
numbers
in
terms
19
of
NOx
and
low
numbers
in
terms
of
particulates
from
where
20
the
current
TLEV
standard
is.

21
MS.
EDGERTON:
Doesn't
this
increase
the
22
number
of
diesel
particulates
from
the
light­
duty
sector
23
even
if
they
achieve
this
goal?

24
MR.
KENNY:
Yes.

25
MS.
EDGERTON:
And
they're
toxic
air
176
BARNEY,
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&
ASSOCIATES
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1
contaminants.

2
MR.
KENNY:
The
answer
is
yes
to
that,
but
3
the
alternative
is
that
when
we
look
at
this
from
a
broader
4
picture,
if
in
fact
we
can
get
that
technology
transferred
5
to
the
heavy­
duty
side,
we'll
get
reductions
eventually,

6
and
those
reductions
are
things
that
we
need.
We
get
the
7
reductions
in
NOx
and
we
also
have
the
potential
for
also
8
getting
some
PM
reductions
there,
so
the
combination
of
9
those
two
things
from
our
perspective
is
worth
this
effort.

10
MS.
EDGERTON:
Mr.
Kenny,
I
don't
want
to
11
take
too
much
of
your
time,
so
I'll
try
to
wrap
up
this
12
point
here.

13
I
have
tremendous
respect
for
your
wisdom
14
and
for
your
proposal
there,
and
I
think
it
might
be
right
15
and
I
expect
it
will
probably
prevail,
but
I
do
want
to
say
16
that
from
my
own
point
of
view,
quite
honestly
­­
and
of
17
course
we're
lame
ducks
and
so
forth
­­
but
I
do
believe
18
that
the
three
things
that
in
all
of
our
policies
do
need
19
to
move
forward
simultaneously
addressing
whether
we're
20
advancing
or
rather
reducing
our
emissions
in
terms
of
21
toxic
air
contaminants
and
whether
we're
reducing
emissions
22
in
terms
of
gas
emissions
at
the
same
time.

23
I
know
that's
not
yet
in
our
official
ARB
24
mandate
from
the
California
legislature,
but
it
is
in
fact
25
in
our
real
world
life,
and
I
think
that's
where
we're
177
BARNEY,
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&
ASSOCIATES
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1
going.
And
this
is
a
very
difficult
question
for
people
2
always
because
it's
the
means
and
the
end
in
discussion.

3
However,
in
just
one
woman's
judgment
it's
just
a
little
4
too
convoluted
for
me,
so
I
would
prefer
to
not
have
that
5
there.

6
My
second
concern
is
we
have
­­

7
CHAIRMAN
DUNLAP:
Lynne,
I'll
let
you
go
as
8
long
as
you
want
to,
but
I
would
prefer
you
wait
because
if
9
we're
going
to
telegraph
where
we
come
down
on
each
of
10
these
points,
we're
going
to
be
here
a
while.
I'd
rather
11
get
to
the
witnesses
and
then
you
can
talk
and
run
through
12
this
stuff.

13
MS.
EDGERTON:
I'll
just
say
the
other
area
14
I
have
some
concern
about
is
what
exactly
the
ZEV
category
15
properly
should
be,
whether
it
is
the
same
issue
that
you
16
quite
correctly,
I
thought,
raised
about
the
.2
for
17
gasoline
vehicles
there
and
whether
that
should
be
in
this
18
particular
proposal.

19
Now,
I
would
like
to
ask
a
question
and
20
think
the
testimony
of
witnesses
can
answer
this.
My
21
understanding
is
one
of
the
benefits
of
having
it
in
there
22
is
that
it
will
weaken
attacks
on
the
overall
10­
percent
23
ZEV
mandate.
This
is
not
a
surprise
to
anybody.
Everybody
24
knows
that.

25
There's
been
a
lot
of
talk
about
effort
to
178
BARNEY,
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1
defeat
it,
weaken
it,
and
one
of
the
things
that
this
does
2
is
strengthen
it
because
it
provides
participation
from
3
gas.
I
was
interested
to
see
that
you
all
­­
I
don't
know
4
if
all
of
you
are
in
the
same
place,
but
you
all
seem
to
5
think
that's
not
worth
doing.
6
CHAIRMAN
DUNLAP:
We
can
have
a
good
7
discussion
at
the
end
on
that.
I'm
not
at
odds
with
that
8
per
se.
Okay.

9
Janet,
and
is
Bonnie
back
there
somewhere?

10
We'll
have
you
two
come
up
and
I
was
generous
with
Roland.

11
I'll
be
equally
generous
with
you
guys,
but
after
this
I'm
12
going
to
have
an
auction.
The
auction
is
going
to
be
13
whoever
can
go
in
three
minutes
or
less
I'm
letting
up
14
early
out
of
order,
so
witnesses
get
ready
and
I'll
move
15
you
over
to
the
bull
pen
and
get
you
going.

16
Janet,
go
ahead.

17
MS.
HATHAWAY:
I
know
people
are
impatient
18
to
move
on,
but
I
think
it's
important
to
spend
some
more
19
time
on
the
diesel
issue.

20
MS.
SHELBY:
Would
you
please
identify
21
yourself
for
the
record?

22
MS.
HATHAWAY:
My
name
is
Janet
Hathaway.

23
I'm
a
senior
attorney
with
the
Natural
Resources
Defense
24
Counsel.

25
I
wanted
to
second
Roland's
comments.
His
179
BARNEY,
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1
comments
are
in
fact
shared
with
other
environmentalists.

2
And
on
the
point
that
Lynne
just
asked
about,
the
reason
3
why
we
don't
support
giving
gasoline
vehicles
partial
ZEV
4
credits
is
even
the
fueling
emissions
associated
with
5
gasoline
vehicles
are
more
than
the
total
emissions
that
6
are
associated
with
powering
the
batteries
for
the
7
electric,
so
there
is
no
equivalence.
There
is
no
way
a
8
gasoline
vehicle,
even
if
it
had
no
tailpipe
emissions,
9
could
come
out
equal.
So
that's
­­
our
fundamental
10
principal
is
not
in
favor
of
one
particular
type
of
11
technology,
it's
evaluate
the
total
emissions
that
are
12
associated
with
ZEVs,
and
if
you
can
get
that
then
you
13
deserve
partial
ZEV
credit.

14
But
with
gasoline,
just
the
fueling
side
of
15
the
emissions,
the
distribution
of
the
gasoline,
the
16
evaporation
from
gasoline
tanks
and
so
on,
even
before
it
17
gets
to
the
vehicle,
exceed
the
ZEV
emissions.
So
that's
18
the
reason.

19
Now,
I
would
like
to
just
turn
to
the
diesel
20
issue.
I
think
it's
important
for
us
to
think
about
this
21
in
terms
of
sort
of
a
paraphrase
of
the
Hippocratic
oath,

22
first
do
no
harm.
Right?

23
DR.
FRIEDMAN:
That's
not
the
Hippocratic
24
oath.

25
MS.
HATHAWAY:
Well,
it's
a
paraphrase.
180
BARNEY,
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1
It's
what's
commonly
referred
to.
Do
no
harm
is
a
good
2
principal
even
if
it's
not
the
Hippocratic
oath.

3
DR.
FRIEDMAN:
Hippocrates
never
said
that.

4
(
Laughter)

5
MS.
HATHAWAY:
There's
always
somebody
who
6
knows
a
lot
more
than
me.
So
do
no
harm
is
an
important
7
principal
for
ARB,
and
nine
times
out
of
ten
when
we
come
8
before
you
as
environmentalists,
we're
not
arguing
about
9
whether
your
proposal
does
harm
at
all.
We're
all
talking
10
about
doing
more
progress
and
faster,
and
that
generally
11
has
been
our
feeling
about
LEV
II.
It's
a
good
proposal.

12
We'd
like
more
and
faster.

13
On
the
diesel
issue,
however,
we're
talking
14
about
something
that
could
literally
do
harm.
Currently
15
there
are
very
few
diesels
in
the
light­
duty
fleet,
and
16
gasoline
vehicles
in
the
light­
duty
fleet
have
very
little
17
particle
emissions.
Diesels,
on
the
other
hand,
even
if
18
they
have
the
best
technology
that
we
know
of
for
right
now
19
would
have
almost
an
order
of
magnitude
ten
times
higher
20
particle
emissions,
and
your
Board
has
just
decided
that
21
diesel
is
a
toxic
air
contaminant.
That
is
consistent
with
22
all
these
other
illustrative
agencies
throughout
the
world
23
that
understand
that
diesel
is
in
fact
associated
with
24
increased
cancer
risk.

25
So
not
only
because
of
cancer
hazards
but
181
BARNEY,
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1
because
of
the
particle
hazard,
allowing
the
introduction
2
of
diesels
into
the
light­
duty
fleet
really
seriously
could
3
do
some
harm.
It
goes
backwards.

4
The
studies
as
you
all
reviewed
them
are
5
very
consistent.
There's
really
not
a
whole
lot
of
6
question
about
the
cancer
risk
and
I
applaud
you
all
for
7
listing
diesel
as
a
toxic
air
contaminant.

8
There's
also
evidence
that
diesel
may
9
disrupt
the
immune
system,
may
be
associated
with
asthma
10
and
other
respiratory
diseases,
may
actually
aggravate
our
11
air
quality
problems
in
ways
that
we
haven't
yet
12
quantified,
and
that's
in
addition
to
the
lung
cancer
and
13
the
particle
risk.
14
So
why
are
automakers
pushing
for
light­
duty
15
diesels?
And
that,
I
think,
is
the
fundamental
question.

16
The
answer
is
simple.
They
are
making
tremendous
profit
on
17
the
very
heavy,
light­
duty
vehicles,
but
they're
getting
18
penalized
from
the
federal
government
because
their
fuel
19
economy
is
not
up
to
snuff.
So
what
they
want
is
a
slight
20
improvement
in
fuel
economy
that
will
allow
them
to
keep
21
selling
these
very
big
SUVs
and
making
$
10,000
per
vehicle
22
profit
on
those
vehicles.
That's
a
tremendous
incentive.

23
But
does
California
need
these
diesels?
I
24
don't
think
so,
not
unless
there's
something
that
nobody
25
has
talked
to
us
about
that
is
behind
these
diesels.
182
BARNEY,
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1
Diesels
are
not
a
green
machine.
They're
a
slight
2
improvement
in
fuel
economy.

3
Can
diesels
be
made
clean?
Now,
I
mentioned
4
that
the
particles
are
about
an
order
of
magnitude
higher
5
than
comparable
gasoline
vehicles.
So
even
though
the
6
standard,
the
TLEV
standard,
doesn't
look
like
it's
all
7
that
weak,
the
truth
is
current
gasoline
vehicles
are
8
what's
going
to
be
replaced
by
these
diesels,
and
they
are
9
much
dirtier.
So
the
standard
in
the
sense
isn't
really
10
the
benchmark.
The
benchmark
is
today's
air.

11
We
don't
have
a
lot
of
diesels
in
the
12
light­
duty
fleet.
We're
going
to
be
introducing
them
13
because
it's
profitable
for
the
automakers
to
go
that
route
14
and
enable
them
to
meet
the
needs
of
the
federal
government
15
without
in
any
way
compromising
the
weight
of
these
16
vehicles
and
will
enable
them
to
get
this
profitability
but
17
not
clean
up
our
air.
And
that's
a
very
big
problem.

18
So
let's
ask
the
question.
Can
diesels
be
19
as
clean
as
gasoline?
Well,
we
don't
know
because
we
20
haven't
demanded
this
of
manufacturers.
They
have
never
21
put
all
the
available
equipment
that
could
reduce
the
22
particles
and
reduce
the
hydrocarbons
on
the
diesels.
They
23
have
not
been
requested
to
do
that.

24
This
standard
would
not
require
oxydation
25
catalysts,
a
currently
available
technology,
on
our
183
BARNEY,
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1
light­
duty
vehicles.
So
the
sequence
is
we
have
these
very
2
fine
particles
that
could
be
trapped.
They're
difficult
to
3
trap,
but
they
could
be
trapped.
We
have
these
gaseous
4
hydrocarbons
that
we
know
are
carcinogens.
Those
could
be
5
reduced
by
an
oxydation
catalyst,
and
if
you
set
a
standard
6
that
says
look,
if
you
automakers
want
to
bring
diesels
7
into
the
market,
at
least
make
them
as
clean
as
gasoline,

8
suddenly
they
have
an
incentive
to
use
that
technology.

9
So
I
submit
to
you
that
the
incentive
is
10
there
for
the
industry
to
come
forward
with
some
good
11
technology
to
clean
diesel
up
at
least
to
the
gasoline
12
level
so
that
at
the
very
least
we
would
be
doing
no
harm.

13
So
the
risk
assessment
that
you
all
14
evaluated
when
you
looked
at
diesel
last
month,
in
15
August
­­
it
was
more
than
last
month
­­
assumes
that
there
16
would
be
no
increase
in
diesel
in
the
light­
duty
fleet.

17
There
were
assumptions
that
there
would
continue
to
be
some
18
increase
in
the
heavy­
duty
fleet,
but
did
not
assume
19
light­
duty,
mainly
introduction
of
diesels.
That
would
20
have
to
be
reconsidered.
Our
risk
from
diesel
even
now
is
21
unacceptably
high
in
terms
of
the
lung
cancer
risk.

22
You
just
convened
a
group,
a
series
of
23
different
committees
to
try
to
look
at
ways
of
reducing
the
24
lung
cancer
risk
from
diesel.
Why
make
that
more
25
problematic?
Why
undermine
the
progress
there
by
allowing
184
BARNEY,
UNGERMANN
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ASSOCIATES
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1
even
more
diesels
on
the
road?

2
The
bottom
line
is
the
light­
duty
diesels
3
aren't
necessary,
so
if
we're
going
to
introduce
them,

4
let's
have
them
as
clean.

5
Truly
clean
diesels,
I
don't
know
if
they
6
can
do
it
or
not.
They
have
an
incentive
to
try,
but
7
diesels
are
not
the
only
way
to
reduce
fuel
consumption.

8
And
if
the
goal
on
the
part
of
the
auto
industry
is
to
9
reduce
fuel
consumption,
they
can
do
it
by
other
means.
It
10
might
be
somewhat
requesting
them
to
be
inventive,
but
one
11
thing
they
can
clearly
do
is
reduce
weight.
Reducing
12
weight
will
save
lives,
save
lives
of
pedestrians,
save
13
lives
of
people
in
automobile
accidents
with
these
giant
14
SUVs,
they
smash
them.

15
CHAIRMAN
DUNLAP:
I
could
lose
a
few
pounds
16
too,
Janet.

17
MS.
HATHAWAY:
A
few
pounds
would
be
about
18
right
­­
aerodynamic.
One
more
slide;
okay?

19
CHAIRMAN
DUNLAP:
Okay.
It's
interesting
­­

20
MS.
HATHAWAY:
Finally,
we
need
the
cleaner
21
cars.
You're
moving
in
the
right
direction
with
LEV
II.

22
In
this
particular
you're
actually
losing
ground,
and
it
23
seems
to
me
that
putting
on
all
this
on
the
manufacturers
24
to
actually
use
the
best
available
catalyst
on
diesels
is
25
something
you
can
and
you
should
do
here.
185
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1
CHAIRMAN
DUNLAP:
Okay.

2
MS.
HATHAWAY:
Finally,
diesels
should
be
at
3
least
as
clean
as
our
gasoline
vehicles
if
we're
going
to
4
introduce
them.
Thanks.

5
One
other
point.
I
think
some
of
the
6
automakers
made
this
point,
but
I
want
to
underline
that
we
7
agree
with
it.
The
fuels
and
the
vehicles
should
be
looked
8
at
as
a
system.
Cleaner
fuels
are
a
way
to
ensure
that
our
9
vehicles
stay
clean
over
the
lifetime
and
that
the
10
catalysts
don't
degrade
that
rapidly,
so
I
really
11
appreciate
that
and
I
hope
that
we
can
work
with
the
Board
12
on
that
issue
soon.

13
CHAIRMAN
DUNLAP:
Okay.
Thank
you,
Janet.

14
Any
questions
for
Ms.
Hathaway?

15
Very
good.
Thank
you.

16
Bonnie,
you're
up.

17
MS.
HOLMES­
GEN:
Thank
you
for
the
18
opportunity
to
speak,
Mr.
Chairman
and
members.
I'm
very
19
glad
to
be
here
today.

20
I'm
going
get
to
my
bottom
line
so
all
of
21
our
very
well
thought
out
but
brief
points
on
why
we
22
believe
this
proposal
­­

23
MS.
SHELBY:
Would
you
please
identify
24
yourself
for
the
record?

25
MS.
HOLMES­
GEN:
Yes.
My
name
is
Bonnie
186
BARNEY,
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ASSOCIATES
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1
Holmes­
Gen.
I'm
a
senior
lobbyist
with
Sierra
Club,

2
California.

3
We
believe
the
stakes
are
very
high
here
4
today,
and
the
results
of
this
rulemaking
will
determine
in
5
large
part
whether
we
are
going
to
be
able
to
meet
our
6
state
air
quality
standards
on
time.
We
strongly
support
7
the
need
to
close
loopholes
in
vehicle
emission
standards
8
and
regulate
sport
utility
vehicles,
and
we
applaud
9
especially
that
portion
of
the
proposal,
but
we
do
continue
10
to
have
major
concerns
that
we're
just
not
getting
all
of
11
the
emissions
reductions
that
we
can
achieve
today.
In
12
fact,
we
are
alarmed
that
the
proposal
moves
us
backwards
13
in
two
areas.
These
have
been
mentioned
so
I'll
go
through
14
them
quickly.

15
A
road
to
zero
emission
program
by
giving
16
credit
to
low
emitting
gasoline
vehicles
and
it
encourages
17
the
introduction
of
more
diesels
into
California.
And
that
18
concerns
us
that
at
the
same
time
we're
talking
about
a
19
ground­
breaking
regulation
of
sports
utilities,
that
we're
20
talking
about
eroding
progress
on
zero
emission
vehicles.

21
That
really
concerns
us.

22
We've
talked
about
the
need
for
every
ton
of
23
emission
reduction
and
I
want
to
emphasize
that
again.
We
24
can
do
this.
We
can
get
every
ton
if
we
tighten
up
the
25
staff
proposal
and
get
rid
of
unnecessary
emissions
for
187
BARNEY,
UNGERMANN
&
ASSOCIATES
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1
work
trucks,
get
rid
of
credits
for
non­
electric
vehicles
2
and
get
rid
of
weaker
standards
for
diesels.
We
cannot
3
assume
that
there
will
be
other
measures
to
plug
the
holes.

4
The
AAMA
proposal,
we
strongly
oppose
that
5
proposal
and
appreciate
that
your
staff
pointed
out
there's
6
at
least
8
tons
of
reduction
you
would
not
get
with
the
7
AAMA
proposal.
We
believe
there's
still
tons
you
can
get
8
by
tightening
up
the
staff
proposal
before
you,
and
if
we
9
don't
tighten
up
and
plug
the
holes,
we're
not
sure
where
10
you're
going
to
get
these
other
emission
reductions
to
fill
11
the
black
box.

12
We
know
that
vehicle
emissions
are
at
least
13
half
of
the
air
pollution
problem.
The
most
cost
effective
14
way
to
reduce
vehicle
emissions
is
to
build
the
cars
right,

15
to
build
the
vans
correctly,
to
build
the
trucks
correctly,

16
to
get
that
technology
on
the
trucks
when
they
come
out
of
17
the
factory.

18
The
2010
window
is
getting
smaller
and
19
closer
and
we
still
have
not
figured
out
a
way
to
get
all
20
of
the
emissions
reductions
for
the
black
box.
There's
21
also
been
shortfalls
in
regulations
that
have
previously
22
been
adopted
by
your
Board.
I
would
point
out
one
of
the
23
first
proposals
the
Board
adopted
was
8
tons
short,
so
we
24
need
to
be
gaining
speed
here
and
not
losing
tons.

25
CHAIRMAN
DUNLAP:
This
will
take
care
of
a
188
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1
chunk
of
the
black
box
as
you
know.

2
MS.
HOLMES­
GEN:
I
appreciate
that,
but
not
3
all
of
it.

4
So
number
one
point,
after
the
general
5
testimony,
we
strongly
oppose
the
relaxation
of
pollution
6
standards
to
accommodate
diesel
light­
duty
vehicles.

7
Very
briefly,
introduction
of
diesel
8
vehicles
is
contrary
to
our
clean
air
goals.
It's
9
especially
inappropriate
after
the
ARB
listing
in
August.

10
And
I
would
just
point
out,
you
know,
you've
already
heard
11
about
the
nine
times
and
the
four
times.
We
were
very
12
strongly
opposed
to
establishing
a
special
category
for
13
diesels,
and
I
wanted
to
point
out
that
in
August
when
your
14
Board
did
adopt
the
diesel
particulate
listing,
we
15
testified
in
strong
support
of
your
action
and
we
said
that
16
the
next
big
challenge
that
you're
going
to
face
is
that
17
you're
going
to
be
facing
the
challenge
of
those
who
want
18
to
introduce
more
diesels
into
California
and
nationally
19
into
the
passenger
car
fleet
under
the
guise
of
20
environmental
protection.

21
We
need
to
resist
those
efforts,
and
here
we
22
are
facing
­­
I
didn't
quite
realize
we
were
facing
quite
23
so
quickly
­­
but
we
are
facing
the
challenge
today
in
this
24
rulemaking.
We
urge
you
to
stand
against
special
standards
25
for
vehicles.
189
BARNEY,
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We
also
oppose
allowing
the
non­
electric
2
drive,
gasoline
powered
SULEVs
to
qualify
for
the
partial
3
ZEV
credit.
We
need
to
be
pushing,
and
we
want
you
as
a
4
Board
to
be
pushing
for
development
of
true
zero
emission
5
vehicles,
for
battery
and
fuel
cell
vehicles,
and
we
6
believe
that
there's
great
support
in
this
new
7
administration
that
has
just
elected
to
do
that.
There
8
will
be
a
lot
of
effort
going
into
the
zero
emission
9
program.
We
don't
want
to
back
down
now,
and
we're
very
10
concerned
that
approving
these
ZEV
credits
will
take
some
11
of
the
steam
out
of
technology
advancements
for
ZEVs
and
we
12
don't
believe
gasoline
vehicles
can
ever
be
truly
13
equivalent.
I
think
that
point
was
made
earlier.

14
A
third
major
point,
we
do
oppose
the
15
relaxation
of
pollution
standards
for
so­
called
work
16
trucks.
We
do
believe
ARB
should
adopt
single
passenger
17
car
standards
for
all
of
the
vehicles
in
the
weight
classes
18
that
you're
covering
up
to
the
8500
pounds.
We
disagree
19
with
the
proposal
to
allow
so­
called
work
trucks
to
emit
40
20
percent
more
nitrogen
oxide.
We
can't
afford
those
tons.

21
We
really
want
to
stand
behind
the
staff
22
that
has
done
testing
on
this.
They've
expressed
to
you
23
the
testing
that
was
done
covered
work
trucks,
covered
cars
24
and
trucks
that
were
carrying
heavy
loads,
and
based
on
25
this
testing
there
is
no
need
for
a
special
exemption
for
190
BARNEY,
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1
work
trucks.
If
you
are
going
to
be
considering
this
and
2
we
really
don't
believe
you
should,
we
think
at
a
minimum
3
that
your
Board
should
place
a
sunset
on
this
exemption,
4
maybe
a
two­
year
sunset,
and
take
that
as
an
opportunity
to
5
study
what
is
happening
under
that
exemption
and
look
at
6
what
kinds
of
cars
are
receiving
that
exemption.

7
And
right
now
in
the
proposal
there's
no
8
particular
way
to
look
at
what
are
the
cars
getting
this
9
exemption.
Are
they
work
trucks?
How
are
they
being
used?

10
Is
it
necessary
any
longer?
We
don't
think
that
exemption
11
should
be
going
on
for
an
eternity
certainly.

12
We
ask
you
to
strongly
consider
some
kind
of
13
cutting
back
on
that
exemption.
We,
of
course,
would
like
14
to
eliminate
it,
but
at
least
put
a
sunset
on
it
and
have
a
15
study
on
it.

16
Fourth
major
point,
we
believe
that
you
17
should
drop
or
at
a
minimum
delay
the
proposal
to
allow
the
18
Premiere
ozone
catalyst
to
qualify
for
smog
reduction
19
credits,
especially
zero
emission
credits.
We
believe
this
20
technology
is
premature.
We've
talked
to
Mr.
Dunlap,

21
Chairman,
about
this.
It
needs
additional
testing
and
22
should
not
be
included
in
the
proposal
at
this
time.
We
23
would
ask
to
you
remove
that
part
of
the
proposal.

24
In
summary,
what
we
want
you
to
do
today
is
25
say
no
to
the
automakers
and
others
who
are
requesting
191
BARNEY,
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1
weakening
the
delay
in
the
LEV
II
regulation.
We
want
you
2
to
say
no
to
those
who
would
push
more
diesels
into
3
California
in
the
light
passenger
fleet.
We're
urging
you
4
not
to
accept
the
myths
and
exaggerations,
the
5
misrepresentations
and
wrong
assumptions
that
are
being
6
cast
out
about
the
cost
and
the
availability
of
cleaner
7
technologies.
We're
asking
you
to
support
the
need
for
the
8
best
emission
standards
that
are
technologically
feasible
9
for
sports
utilities,
and
this
means
the
ARB
staff
proposal
10
should
be
tightened
even
further
than
it
is.

11
When
you
go
to
adopt
a
resolution
today,
we
12
hope
that
you
will
ask
yourself,
how
can
we
get
every
ton
13
of
emissions
reductions
possible
out
of
this
rulemaking
to
14
achieve
healthier
air
as
quickly
as
possible?
How
can
we
15
best
promote
true
electrical
technology?
How
can
we
reduce
16
diesel
particulates
and
diesel
NOx
in
this
rulemaking?

17
If
you
do
that,
I
believe
the
answers
will
18
be
to
tighten
up
the
regulation,
to
not
trade
zero
emission
19
vehicles
for
diesels,
to
eliminate
the
transitional
low
20
emission
category
­­
and
I
forgot
to
specifically
stress
21
that,
but
we
do
believe
that
category
was
an
introductory
22
category
and
there's
no
need
for
it
really
at
this
point.

23
That
was
an
introductory
category
and
now
we
need
to
meet
24
the
low
emission
vehicle
standards
that
are
more
stringent.

25
We
believe
it
would
eliminate
the
Premiere
192
BARNEY,
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1
catalyst
from
the
program
and
that
you
ensure
that
only
2
true
zero
emission
vehicles
qualify
for
ZEV
credits.

3
CHAIRMAN
DUNLAP:
Thank
you,
Bonnie.
Are
4
there
any
questions?

5
MS.
EDGERTON:
Ms.
Holmes­
Gen,
in
your
6
material
here
you
indicate
that
in
exchange
for
­­
maybe
7
it's
not
in
exchange
for
­­
that
with
respect
to
the
.2
8
SULEV
partial
ZEV
credit,
you
oppose
that.
However,
you
9
support
providing
additional
flexibility
between
2003
and
10
2005
to
restore
a
ramp
that
was
lost.
You're
looking
at
11
me.
Are
you
familiar
with
this?

12
MS.
HOLMES­
GEN:
Well,
I'm
not
sure.
Is
13
this
the
letter
that
we
submitted?

14
MS.
EDGERTON:
Section
B
of
the
green
one
15
that
you
signed,
this
green
one.

16
MS.
HOLMES­
GEN:
Those
are
Roland's
17
comments.
I'm
sorry.
I
can
have
Roland
answer
that
18
question.

19
MS.
EDGERTON:
Oh,
Roland
can
answer
that
20
question.

21
MR.
HWANG:
I'm
not
sure
I
know
exactly
what
22
your
question
is.

23
MS.
EDGERTON:
Some
flexibility
in
2003
24
through
2005.

25
MR.
HWANG:
Right.
Union
of
Concerned
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Scientists
does
support
allowing
for
partial
ZEV
credit
for
2
hybrid
electrical
vehicles
to
have
an
electric
range
and
3
for
methanol
powered
fuel
cells,
like
that
part
of
the
4
proposal.
We
also
believe
that
flexibility
helps
5
compliance
with
the
program
in
the
early
years
because
in
6
2003
the
manufacturers
are
responsible
for
10­
percent
zero
7
emission
vehicles.
The
original
program
as
conceived
8
started
at
2
percent
in
1998
and
ran
up
to
10
percent.

9
I
think
that
if
the
manufacturers
are
saying
10
they
can
no
longer
meet
at
10
percent,
that's
partly
11
because
the
Air
Board
is
being
very
generous
to
the
12
manufacturers
and
rolling
back
the
program
from
1998
to
13
2003.
And
we
admit
there
is
some
difficulty
in
trying
to
14
ramp
up
production
to
the
10­
percent
level
without
having
15
some
steps
in
between.
That's
why
we
support
that
16
flexibility.

17
CHAIRMAN
DUNLAP:
That's
the
distinction.

18
MS.
EDGERTON:
So
it
seems
there
are
two
19
things
that
come
to
mind.
One
would
be
that
you're
saying
20
more
concrete
it
should
be
8
percent
in
2003
and
10
in
21
2005,
or
the
other
alternative
is
to
keep
it
10
percent
but
22
let
there
be
an
aggregating
possibility
there,
so
that
if
23
the
company
missed
the
10
percent,
in
2003
they
can
do
­­

24
say
they
get
a
5
percent
in
2003
and
they
can
have
15
25
percent
in
2004,
so
that
by
the
end
of
2005
they
would
have
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BARNEY,
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1
the
equivalent
of
10
percent
for
each
of
three
years.
Is
2
either
one
of
those
what
that
means?

3
MR.
HWANG:
Essentially.
The
merits
between
4
those
two
different
pathways,
as
you
suggested
that's
two
5
different
pathways.
The
merits
between
those
two
­­
and
6
it's
very
difficult
to
assess
at
this
point
which
is
the
7
better
pathway.
I
do
agree,
though,
there's
some
8
tremendous
technologies
coming
out,
Toyota's
Acreas
for
9
example,
and
many
manufacturers
are
working
on
other
hybrid
10
vehicles.

11
In
fact,
I
just
read
Automotive
News
12
yesterday.
General
Motors
plans
to
bring
a
hybrid
electric
13
vehicle
to
the
marketplace,
so
I
think
that's
appropriate
14
to
flex
the
program,
bring
in
and
capture
the
benefits
of
15
some
of
these
technologies
to
get
us
towards
that
true
zero
16
emission
vehicle
technology.

17
CHAIRMAN
DUNLAP:
I
think
we've
got
that.

18
Can
we
go
on.
Can
I
do
my
auction
now?

19
MS.
WALSH:
Chairman
Dunlap,
if
I
could
just
20
suggest
here
that
given
notice
for
the
meeting
today,
this
21
is
an
issue
that
is
outside
the
scope
of
that
notice,
and
22
while
this
is
a
significant
issue
and
probably
one
that
may
23
bear
discussion
in
the
future,
it
really
is
not
something
24
that
we
would
be
able
to
do
today
given
the
notice.

25
MS.
EDGERTON:
Could
the
­­
for
example,
if
195
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1
the
Board
were
to
withdraw
the
.2
percent
for
the
gasoline
2
vehicles,
could
the
Board
ask
the
staff
then
to
look
at
the
3
possibility
of
some
sort
of
averaging
for
the
remaining
ZEV
4
category
between
the
years
2003,
2005,
to
wind
us
up
in
the
5
same
place
but
give
more
flexibility
there?

6
MS.
WALSH:
In
the
context
of
the
regulation
7
as
proposed
­­

8
MR.
KENNY:
I
think
what
I
understood
you
to
9
say
is
if
in
fact
the
Board
was
to
say
no
to
the
.2
for
10
SULEV
vehicles,
could
the
Board
then
give
directions
to
11
staff
to
put
these
people
back
on
credit.
We
could
do
that
12
but
not
in
the
context
of
the
current
hearing
today.

13
We
would
have
to
bring
a
different
proposal
14
to
the
Board.
The
notice
today
was
written
in
such
a
way
15
that
the
10­
percent
requirement
is
not
up
for
change
today.
16
MS.
EDGERTON:
We
could
ask
to
you
come
back
17
and
report
that
to
the
Board
early
next
year?

18
MR.
KENNY:
Sure.

19
CHAIRMAN
DUNLAP:
Mike,
I
would
like
to
give
20
Tom
a
chance
to
explain
his
body
language
during
the
21
conversation,
not
the
part
where
she
said
we're
all
excited
22
about
the
change
in
the
administration.

23
(
Laughter)

24
CHAIRMAN
DUNLAP:
The
part
where
we're
25
talking
about
can
we
get
diesel
fuel
cleaner
and
are
we
196
BARNEY,
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automatically
­­

2
MR.
CACKETTE:
­­
Diesel
vehicles
cleaner.

3
CHAIRMAN
DUNLAP:
Right.
Become
dirtier
by
4
this
action.

5
MR.
CACKETTE:
Why
I
flinched
at
first
was
6
the
comment
that
what
we
seem
to
be
implicit,
if
we're
not
7
going
to
ban
diesels
from
this
program,
then
at
least
we
8
ought
to
make
them
have
catalysts.
And
in
fact
the
diesels
9
that
are
being
sold
under
the
existing
LEV
I
rules
which
do
10
allow
diesels
­­
and
there
are
only
two
models
right
now,

11
Mercedes
and
Volkswagen
­­
those
do
both
come
with
12
oxidation
catalysts
on
them.

13
The
standards
that
we're
talking
about
for
14
diesels
in
LEV
II
terminate
the
existing
standards
that
15
lets
diesels
come
in
and
replace
it
with
one
that's
about
16
40
percent
tighter.
And
under
that
scenario
we
believe
17
that
you'll
not
only
end
up
with
an
oxidation
catalyst,

18
that
you'll
end
up
with
a
reduction
catalyst
that
takes
NOx
19
and
gets
rid
of
it,
as
well
as
oxidation
catalysts
which
20
help
get
rid
of
some
of
the
particulate.

21
And
it's
what
Mr.
Kenny
said,
that's
what
22
we're
looking
for
as
a
technology
foreseen
because
the
car
23
manufacturers
have
a
strong
incentive
to
improve
fuel
24
economy
and
they
want
to
do
it
through
some
diesels.

25
They
have
a
strong
economic
driver
to
sell
197
BARNEY,
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&
ASSOCIATES
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1
more
diesels.
They're
in
kind
of
a
stagnant
market.
If
2
they
can
make
heavy­
duty
trucks
and
if
they
can
introduce
a
3
few
into
this
market,
it's
significant
to
them.

4
That
puts
two
economic
drivers
behind
5
getting
this
technology
into
place,
and
the
return
on
the
6
benefit
is
what
we're
willing
to
gamble
on
because
we're
7
talking
about
just
a
few
percent
of
light­
duty
vehicles
8
that
under
this
constrained
end
law
average
could
actually
9
beat
diesels,
these
TLEV
diesels.

10
But
if
we
get
that
technology,
the
return
on
11
investment
in
terms
of
emission
reductions
is
somewhere
12
between
10
and
15
to
1
by
putting
that
technology
on
13
18­
wheel
trucks.
That's
where
the
big
NOx
sources
are
that
14
are
left,
so
we
were
kind
of
­­
admittedly
we
were
gambling
15
that
the
technology
will
be
developed,
but
if
it's
not,

16
with
the
stringency
of
the
standard,
we
propose
there
won't
17
be
diesels
in
the
light­
duty
sector.

18
Either
the
technology
happens
or
Janet's,

19
the
environmentalist
viewpoint
is
realized,
we
don't
have
20
any
diesels,
one
of
the
two.
We
think
it's
a
risk
we're
21
taking.
It
may
be
a
slight
step
backwards
now,
but
it
22
could
be
a
fairly
giant
leap
forward
for
controlling
diesel
23
truck
emissions.

24
MS.
EDGERTON:
Wouldn't
that
also,
once
you
25
got
there,
put
a
lot
of
pressure
to
keep
that
category
open
198
BARNEY,
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ASSOCIATES
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1
and
expand?

2
CHAIRMAN
DUNLAP:
That
depends
on
the
will
3
of
the
Board
to
let
the
inventories
tell
us
what
kind
of
4
progress
we're
making.
I
can
tell
you
­­
I
think
5
everybody's
been
put
on
notice,
the
Board
certainly,
the
6
staff,
the
engine
manufacturers,
environmentalists,
that
7
particulate
emissions
in
particular
are
priority
number
one
8
for
all
of
us
to
control
better.
So
anything
that
would
be
9
done
to
make
that
more
difficult,
that
role
to
be
more
10
difficult,
would
certainly
be
something
that's
going
to
be
11
problematic
from
a
long­
term
policy
standpoint,
so
I
don't
12
think
­­

13
MR.
CACKETTE:
Mr.
Chairman,
there's
14
safeguards,
though,
because
the
way
we've
designed
this
15
program
­­
and
somebody
said
it's
complicated
and
I
have
to
16
admit
that
is
very
true.
It's
constrained
on
hydrocarbon
17
emissions
to
a
fleet
average
for
the
manufacturer.
At
some
18
point
the
only
way
they
can
sell
more
diesels
is
because
19
they
are
given
higher
hydrocarbon
emissions
credit.

20
They're
assigned
a
standard
that's
a
high
value.

21
The
only
way
you
can
sell
more
diesels
is
to
22
ratchet
them
down
and
make
them
the
next
cleaner
standard.

23
So
if
they
want
more,
they
have
to
make
them
cleaner
than
24
the
standards
we
are
talking
about.
So
it
is
somewhat
25
self­
constraining,
and
I
don't
think
there's
a
possibility
199
BARNEY,
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&
ASSOCIATES
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5900
1
that
under
this
rule
the
door
can
go
open
for
more
than
the
2
sliver
that
it's
open
now.
We
can't
open
it
wide
up.

3
CHAIRMAN
DUNLAP:
Okay.
We're
going
to
move
4
along.
Thank
you.
Nice
job.

5
All
right.
Here's
the
auction
part
of
the
6
program
today.
I've
got
25
witnesses
left,
not
even
7
halfway
through.
I've
been
generous
with
the
time.
The
8
witnesses
who
are
remaining
have
also
been
patient.
Is
9
there
anyone
here
­­
I
want
to
see
hands
­­
who
can
get
up
10
and
give
us
their
remarks
in
three
minutes
or
less?

11
(
Laughter)

12
CHAIRMAN
DUNLAP:
Keep
the
hands
up.
Where
13
are
they?

14
Pat,
you
come
on
up
first.
The
rest
of
you
15
line
up
in
the
front
row
and
we'll
talk
to
you
one
at
a
16
time.
I'm
sure
you've
all
signed
up
with
the
clerk.
Greg,

17
you
had
your
hand
up.
Come
on,
let's
go.
Jerry
Secundy,

18
did
your
hand
go
up?

19
MR.
SECUNDY:
Bob
and
I
just
worked
it
out.

20
He's
going
to
speak
for
us.

21
CHAIRMAN
DUNLAP:
So
you're
off
the
list?

22
MR.
SECUNDY:
I'm
off
the
list.

23
CHAIRMAN
DUNLAP:
All
right.
Jerry,
you're
24
a
fine
man.

25
Front
row,
three
minutes.
Anybody
longer
is
200
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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5900
1
in
the
back.
Pat,
good
to
see
you.
Welcome.

2
MR.
PUDELL:
Chairman
Dunlap
and
members
of
3
the
Board,
my
name
is
Patrick
Pudell.
I
am
representing
4
the
American
Lung
Association
of
California
and
its
medical
5
arm,
the
California
Thoracic
Society.

6
We
strongly
support
the
LEV
II
proposal
as
a
7
reasoned,
deliberate
approach
of
California
to
achieve
8
federal
one­
hour
ozone
standard
as
contained
in
the
ZEV.

9
Health
risks
of
both
short­
and
long­
term
exposure
to
the
10
ozone
have
been
demonstrated
in
chamber
and
longitudinal
11
studies,
additional
health
risks
related
to
PM10
and
PM2.5
12
in
which
the
smallest
particles
have
been
documented
by
13
studies
showing
premature
death,
increased
hospital
visits
14
and
other
serious
health
problems.

15
We
echo
and
endorse
the
concerns
regarding
diesel
16
fuel
as
articulated
by
my
colleagues
in
the
environmental
17
community.
We
also
oppose
allowing
gasoline
SULEVs
to
18
qualify
for
partial
ZEV
credit
because
such
an
allowance
19
would
undermine
the
goal
of
the
ZEV
program
to
20
commercialize
vehicles
with
zero
tailpipe
emissions.

21
We
urge
your
support
of
the
regulation
with
22
the
exceptions
as
noted.
Thank
you.

23
CHAIRMAN
DUNLAP:
Thank
you
for
taking
the
24
time
to
join
us.
Okay.
Who's
next.
Yes,
sir.

25
MR.
LOWE:
My
name
is
Aaron
Lowe
and
I'm
201
BARNEY,
UNGERMANN
&
ASSOCIATES
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1
Vice
President
for
Regulatory
Government
Affairs
of
the
2
Automotive
Parts
and
Accessories
Association.
In
addition
3
to
the
APAA,
I'm
testifying
on
behalf
of
a
broad
range
of
4
aftermarket
groups
that
are
listed
in
the
testimony
so
I
5
won't
repeat
them.

6
These
groups
represent
the
independent
7
aftermarket
comprised
of
manufacturers
and
manufacturer
8
representatives,
rebuilders,
distributors
and
retailers
of
9
parts
and
services.
Our
industry
is
comprised
of
10
competitive
options
of
otherwise
obtaining
repairs
and
11
parts
strictly
from
franchise
dealerships,
and
that
keeps
12
vehicle
maintenance
prices
the
lowest
in
the
world.

13
We
oppose
the
warranty
provisions
of
the
14
proposal,
the
staff
proposal
as
it
was
written,
a
15­
year,

15
150,000­
mile
emissions
warranty
and
credits
on
an
8­
year,

16
100,000­
mile
warranty.

17
We
don't
oppose
the
durability
part
and
18
consider
it
otherwise.
I
want
to
make
that
clear.

19
Inclusion
of
the
extended
warranty
requirement
would
do
20
nothing
to
increase
vehicle
durability
and
would
actually
21
result
as
not
a
consumer
benefit,
and
we
think
it
will
hurt
22
many
of
the
small
automotive
repair
businesses
in
this
23
state.

24
Our
major
contention
is
that
warranties
do
25
not
serve
to
improve
vehicle
durability.
The
car
always
202
BARNEY,
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&
ASSOCIATES
1­
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1
has
recall
and
durability
testing
to
bring
that
about,
and
2
we
see
there's
also
competition
in
the
industry
right
now.

3
Durability
has
been
increasing
due
to
competition
and
4
consumer
expectation
since
the
80s,
and
we
see
that
trend
5
continuing
with
or
without
this
proposal.

6
If
anything,
warranties
are
a
sales
tool
and
7
should
remain
that
way,
and
CARB
should
not
be
involved
in
8
that.
We
also
do
not
believe
that
warranties
will
somehow
9
repel
consumers
to
go
into
repair
shops
to
get
their
cars
10
repaired
because
it
will
be
free.
We
don't
think
consumers
11
react
just
because
they
get
their
repairs
for
free.

12
Convenience
is
also
a
major
reason
why
they
do
not
get
13
their
cars
repaired.

14
This
provision
will
actually
work
against
15
that
by
making
it
more
inconvenient,
by
forcing
car
owners
16
into
dealerships
which
they
have
shown
in
surveys
to
not
17
prefer.
We
don't
understand
why
CARB
would
want
to
send
18
the
consumer
back
to
places
they
prefer
not
to
go.

19
Another
factor
why
we
don't
think
warranties
20
improve
durability
is
most
car
owners
don't
know
they
have
21
a
warranty
by
the
time
they
get
the
car.
CARB's
own
survey
22
in
the
late
80s
found
that
22
percent
of
the
voters
don't
23
think
they
have
an
emission
warranty
and
60
percent
do
not
24
know
of
the
coverage.
Therefore
there's
very
little
25
incentive
for
maintenance
in
this
proposal.
203
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
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5900
1
In
truth,
the
maintenance,
the
warranties
2
also
provide
a
false
sense
of
security
to
the
motorist,
if
3
he
knows
about
it,
that
that
car
is
going
to
last
for
the
4
warranty
period
and
therefore
he
has
to
do
nothing
to
that
5
car
but
drive
it
around.
We
don't
think
that
is
in
the
6
best
interest
of
clean
air.

7
CHAIRMAN
DUNLAP:
Mr.
Lowe,
in
conclusion
8
you're
going
to
provide
me
and
my
colleagues
with
some
9
language
that
you
would
have
us
use
to
change
these
rules,

10
for
us
to
look
at.
Will
you
do
that
for
me?

11
MR.
LOWE:
Yes.
We've
already
done
that.

12
CHAIRMAN
DUNLAP:
Send
it
up
here
anew
and
13
let
me
take
a
look
at
it.
Does
that
do
it
for
you?

14
MR.
LOWE:
Well,
we
just
want
to
make
the
15
case
that
the
warranty,
there
is
no
data
since
the
20
years
16
you've
had
emissions
warranties.
There's
been
no
data
to
17
support
that
it
actually
is
a
benefit
at
this
time
to
18
durability,
that
has
shown
to
prove
to
be
a
benefit
to
19
consumers,
and
yet
the
Board
has
gone
ahead
every
year
and
20
tried
to
­­
in
this
case
tried
to
increase
the
warranties.

21
Just
looking
at
the
other
proposals
that
they've
pushed,

22
there
should
be
some
data.

23
CHAIRMAN
DUNLAP:
Let
me
see
the
language,

24
would
you?

25
MRS.
RAKOW:
Mr.
Chairman.
204
BARNEY,
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&
ASSOCIATES
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1
CHAIRMAN
DUNLAP:
Yes.

2
MRS.
RAKOW:
Regarding
the
language,
I
think
3
the
service
station
repair
people
will
also
be
testifying
4
regarding
their
concern
about
the
150,000­
mile
warranty
5
unless
Mr.
Lowe
was
testifying
for
them,
and
I
had
talked
6
to
staff
about
this
and
I
know
there
have
been
meetings
7
with
staff,
and
I
think
later
on
they
will
see
proposed
8
language.

9
CHAIRMAN
DUNLAP:
All
right.
That's
fine,

10
Mrs.
Rakow.
I
want
to
make
sure
the
language
lines
up
and
11
we
know
what
the
problem
is.

12
MR.
RILEY:
Mr.
Chairman,
my
name
is
Tom
13
Riley
representing
the
Automotive
Service
Councils
of
14
California.
We
are
2700
small
"
mom
and
pop"
garages
15
distributed
throughout
the
state
that
are
currently
16
involved
in
the
smog
check
program.

17
We
believe
in
what
you're
trying
to
do.
We
18
think
the
staff
has
a
very
difficult
task
before
them
as
19
evidenced
by
the
wide
range
of
testimony
today.
One
point
20
I
wanted
to
make
that
has
not
yet
been
made
is
that
our
21
preference
­­
we
believe
that
the
warranty
provision
of
22
this
regulatory
proposal
will
be
devistating
for
our
small
23
businesses.

24
We
would
prefer
that
the
decision
only
on
25
the
warranty
provision
be
delayed
for
a
period
of
time
to
205
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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5900
1
allow
staff
to
sit
down
with
us
and
work
through
this.
If
2
that
does
not
happen,
we
would
like
having
this
regulatory
3
proposal
going
out
to
have
an
18­
month
period
to
work
with
4
staff,
and
I
believe
that
Mr.
Cackette
has
that
language
5
before
him
now.

6
I
used
the
word
"
devastating".
I
recognize
7
that's
a
harsh
word,
and
we
have
one
of
our
members
here
8
who
is
in
the
Rankin
file
of
people
out
there
in
the
9
current
smog
check
program.
Her
name
is
Lynn
Cardwell.

10
MS.
CARDWELL:
Thank
you
for
hearing
my
11
testimony.
I'll
be
very
brief.
I
think
I
can
do
this
in
12
three
and
a
half
minutes.

13
My
name
is
Lynn
Cardwell
and
I
own
an
auto
14
repair
shop
in
Sacramento,
California.
We
are
a
smog
check
15
facility.
I
have
a
lot
of
qualifications
and
I
think
I'll
16
shortcut
through
all
that
and
tell
you
we
know
what
we're
17
doing.
We've
worked
in
every
smog
program
since
the
18
inception
of
smog
programs,
so
all
of
our
technicians
are
19
qualified.
We
have
many
specialists
in
various
areas.
We
20
­­
I'm
going
to
just
bypass
all
of
that.

21
I'm
also
an
environmentalist,
I
suppose,

22
part­
time.
I'm
very
proud
of
the
American
Lung
Association
23
that
gave
me
the
Clean
Air
Award
last
year.
I
believe
in
24
what
the
Board
is
doing
in
cleaning
up
the
air
and
I
25
support
that.
206
BARNEY,
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&
ASSOCIATES
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1
My
concern
is
­­
and
I
will
give
one
2
specific
reason
for
my
concern.
This
regulation
seems
to
3
direct,
by
the
150,000­
mile
warranty,
customers
as
captive
4
customers
to
the
dealerships
for
their
service,
and
the
5
reason
is
­­
and
I
don't
have
a
copy.
Thankfully
­­
I
6
don't
have
a
transparency,
but
the
third
page
of
the
letter
7
that
you
have
before
you,
I
believe
just
the
flow
of
data
8
between
the
various
computer
systems
on
a
car,
and
you
have
9
an
ECM
and
BCM
and
IPC
and
SIR.
And
I
can
tell
you
all
10
those
things
and
what
they
mean,
but
I
don't
care
so
much
11
as
they
are
totally
interdependent
and
the
relationship
is
12
inseparable.

13
You
cannot
send
a
customer
to
have
their
14
emission
system
worked
on.
If
you
touch
the
car,
you
have
15
touched
the
emission
system,
so
we
would
like
to
ask
the
16
Board
to
address
this
in
future
months
and
talk
with
17
industry
and
determine
the
impact
on
small
businesses
like
18
ourselves.
Thank
you.

19
CHAIRMAN
DUNLAP:
Appreciate
that.
We
20
certainly
see
you
as
a
partner
and
we
know
that
you
take
21
your
share
of
spears
and
arrows
relative
to
smog
check
and
22
other
programs.
We
know
you're
an
important
partner,
so
23
that's
not
lost.
It
is
not
our
position
­­
and
I've
talked
24
to
staff
about
it
several
times
­­
to
hurt
you
in
any
way.

25
MS.
CARDWELL:
But
one
of
the
things
about
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BARNEY,
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1
warranties
you
would
expect
us
to
do
is
look
after
the
2
consumer
when
we
can,
and
we
think
in
some
cases
these
3
manufacturers
may
be
for
significant
periods
of
time
taking
4
care
of
this
problem.

5
CHAIRMAN
DUNLAP:
The
motive
is
not
to
harm
6
you.
I
can
assure
you.

7
MS.
CARDWELL:
And
I
do
believe
that.
I
8
think
it
would
be
­­

9
CHAIRMAN
DUNLAP:
I
must
say
­­

10
MS.
CARDWELL:
­­
an
entirely
unintentional
11
consequence
of
the
­­

12
CHAIRMAN
DUNLAP:
And
I'm
convinced
the
13
manufacturers
want
to
make
a
durable
product
that
works
14
well.
We
all
want
the
same
thing.
It's
how
to
coexist
so
15
we
don't
step
on
each
other.

16
MS.
CARDWELL:
There
is
a
network
of
repair
17
shops
that
have
had
advanced
training.
We
call
ourselves
18
Gold
Shield.
We
would
like
to
participate
as
service
19
providers.

20
CHAIRMAN
DUNLAP:
Great.
Thank
you
and
21
congratulations
on
that
award.
All
right.

22
Yes,
sir.
You
are
­­

23
MR.
GALLO:
My
name
is
Johan
Gallo.

24
Mr.
Chairman,
members
of
the
Board,
I'm
the
President
of
25
the
Auto
Repair
Coalition.
We
represent
over
10,000
repair
208
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1
dealers
in
California
that
constitutes
over
100,000
jobs
2
and
about
$
5
billion
in
sales.

3
The
main
concern
we
have
is
the
extended
4
warranty
issue,
as
by
a
lot
of
people
that
went
before
me.

5
Our
concern
is
we
would
like
the
opportunity
to
work
with
6
staff
in
order
to
refine
this
and
give
us
an
opportunity
to
7
stay
in
the
repair
business.
There's
no
way
the
1200
8
automotive
dealers
in
California
can
begin
to
fix
the
26
9
million
vehicles
in
our
fleet.
That's
the
reality
of
it.

10
For
to
us
help
you
keep
the
air
clean
by
being
in
the
smog
11
check
program,
by
becoming
Gold
Shield
shops
and
doing
12
things
we
need
to
do
to
clean
up
the
air,
we
need
an
13
opportunity
to
refine
the
extended
warranty
portion
and
be
14
given
an
opportunity
to
work
with
staff
to
do
so.

15
As
we
look
at
the
numbers
and
get
to
the
16
bottom
line,
as
we
surveyed
some
of
our
members,
the
17
proposed
warranty
changes,
in
our
business,
currently
22
18
percent
of
our
fleet
that
we
work
on
fall
within
that
19
7­
year
plus,
70,000­
mile
plus
warranty
issue.
What
that
20
means
for
us
in
sales
is
in
excess
of
$
5
million
which
21
impacts
jobs,
tax
revenue,
and
the
ability
to
stay
in
22
business.

23
We
want
the
opportunity
to
work
with
staff,

24
and
for
the
sake
of
brevity
we
would
like
that
opportunity
25
and
hope
the
Board
hears
us.
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CHAIRMAN
DUNLAP:
Okay.

2
MR.
GALLO:
Thank
you.

3
CHAIRMAN
DUNLAP:
All
right.
Very
good.

4
Thank
you.

5
MR.
WALKER:
Good
afternoon.
I'm
Chris
6
Walker
from
the
California
Service
Station
and
Automotive
7
Repair
Association.
Thank
you
for
the
opportunity
to
speak
8
briefly.

9
I
would
like
to
begin
by
thanking
Chairman
10
Dunlap,
Executive
Officer
Mike
Kenny,
Deputy
Executive
11
Officer
Mr.
Cackette,
and
Jim
Schoning
for
the
generous
12
time
in
the
last
few
weeks
working
with
us.

13
We
cumulatively
­­
a
quarter
of
a
billion
14
dollars
in
the
last
12
months
to
engage
in
the
smog
check
15
program
as
well
as
train
their
employees,
become
the
elite
16
emissions
task
force
if
you
will
to
reduce
emissions
in
the
17
state
of
California.
We
would
like
to
continue
the
war
on
18
smog
and
do
not
want
to
see
our
business
one
day,
8
years,
19
10
years
from
now
go
on
the
way
to
dealerships,
so
we
20
appreciate
the
opportunity
to
work
with
you.

21
Again,
the
biggest
point
we
disagreed
with
22
staff
is
that
we
believe
there
has
been
an
inadequate
23
economic
analysis
of
the
impact
on
industry
and
consumers.

24
I'm
sorry
to
see
that
Supervisor
Roberts
is
gone
because
I
25
was
going
to
say
our
contention
of
warranties
is
not
going
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to
cost
$
7,000
a
car,
but
we
do
believe
it's
over
$
150
a
2
car.
But
in
any
event,
we're
working
to
come
to
a
3
conclusion
on
some
language.

4
CHAIRMAN
DUNLAP:
Thank
you.
Mr.
Valencia.

5
MR.
VALENCIA:
I
am
John
Valencia.
I
6
represent
the
California
Automotive
Task
Force.

7
All
of
the
good
people
before
me
are
part
of
8
the
16
organizations
with
16,000
members
and
over
100,000
9
employees
in
California.
They've
asked
me
to
ask
you
to
10
either
defer
or
actually
delete
the
warranty,
extended
11
warranty
emissions
provision
from
this
proposal,
and
it's
12
the
only
component
of
this
proposal
we
care
about
for
two
13
specific
reasons.

14
One,
it
is
illegally
ineligible,
and
two,

15
there
hasn't
been
adequate
cost
analysis
assessment
of
the
16
impact
on
small
business
if
you
do
adopt
that
component
of
17
this
overall
proposal.
The
rest
of
the
proposal
we
18
allotted
and
we
support.

19
As
you
know,
we
perform
better
than
70
20
percent
of
the
automotive
repairs
in
the
aftermarket
in
21
California,
so
we
have
a
very
big
stake
in
clean
air.

22
Here's
what
you
create
in
the
warranty.
You
23
create
a
legal
entitlement
for
manufacturers.
That
24
entitlement
is
to
sell
vehicles
in
California
which
don't
25
meet
the
standards
that
they've
spent
all
day
telling
you
211
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are
technologically
infeasible,
those
vehicles
won't
meet
2
those
standards.
But
if
they
agree
to
offer
an
extended
3
warranty
for
their
vehicle,
their
vehicle
line,
they
earn
4
artificial
credits
towards
meeting
those
emission
standards
5
they
told
you
they
can't
meet
anyway.
And
that's
how
this
6
component
helps
them
get
around
limits
that
they
say
they
7
can't
meet
anyway.

8
You
can't
do
that
because
the
legislature
9
hasn't
said
you
can
do
that.
That's
a
transaction
that
10
you,
this
Board,
don't
have
the
authority
to
do.

11
Here's
what
California
law
does
require
you
12
to
do.
It
requires
you
to
cite
the
specific
statute
of
law
13
authorizing
the
adoption
of
a
regulation.
It
also
requires
14
to
you
refer
to
the
specific
authority
under
which
you're
15
promulgating
this
regulation.

16
Here's
what
the
staff
report
rests
on.
It
17
rests
on
Health
and
Safety
Code,
three
sections,
43101,

18
43101.5
and
43205,
all
of
which
the
legislature
enacted
19
with
limits
and
none
of
which
authorize
this
particular
20
transaction
or
this
particular
component
of
the
regulation
21
that
you're
reviewing.

22
In
addition,
the
Administrative
Procedure
23
Act
requires
any
regulation
­­
and
you've
heard
me
appear
24
before
this
Board
previously
­­
it
requires
a
much
better
25
assessment,
much
more
detailed
assessment
of
cost
impact
on
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small
business.

2
Now,
here's
what
the
staff
report
says
at
3
page
II
62.
This
about
sums
it
up.
There's
not
much
more
4
to
it
than
this
brief
quote.
"
Staff
is
not
convinced,

5
however,
there
would
be
a
net
shift
in
business
to
6
dealerships
due
to
an
extended
warranty.
Extended
7
warranties
should
result
in
emission­
related
components
8
much
less
likely
to
fail
in
the
early
years
of
a
vehicle's
9
life,
thus
dealers
compared
with
new
merchants
today
10
potentially
providing
an
increase
in
independent
repair
11
facility
business
for
vehicle
maintenance
because
of
their
12
perceived
advantages
over
dealerships."

13
That
about
sums
it
up.
What
the
law
14
requires
you
to
do,
however,
is
much
more
specific.
The
15
ARB
has
to
put
together
facts,
evidence,
documents,

16
testimony
that
says
that
there
won't
be
an
impact.
This
17
report
tries
to
have
it
both
ways.
The
report
suggests
on
18
the
one
hand
there
won't
be
an
impact
to
the
aftermarket,

19
but
it
also
conceives
there
will
be
an
aftermarket
20
automotive
impact.
You
can't
have
it
both
ways
in
this
21
report
because
if
you
say
there
won't
be
an
impact,
you
22
have
put
in
writing
before
you
for
adoption
the
facts
and
23
evidence
that
suggest
why
there
won't
be
an
impact
on
the
24
aftermarket.
If,
however,
as
the
report
also
does,
if
you
25
concede
there's
an
impact
on
the
automotive
aftermarket,
213
BARNEY,
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then
state
law
requires
you
­­
and
this
is
the
California
2
Administrative
Procedure
Act
­­
requires
you
to
identify
3
alternatives
to
that
impact.

4
Well,
here's
what
the
Board
staff
says
at
5
that
same
page.
"
Perhaps
helping
to
offset
the
effects
on
6
the
repair
industry,
durability
from
extended
emission
7
warranty
could
be
an
increase
in
repairs
due
to
8
proliferating
comfort
and
convenience
options
on
new
9
vehicles."

10
Staff
sees
our
future
in
repairing
vanity
11
mirrors
and
lights
and
leather
seat
butt
warmers.
That's
12
essentially
what
they're
talking
about.

13
MS.
RIORDAN:
I
have
a
task
which
the
14
Chairman
has
given
me
to
move
this
along.

15
MR.
VALENCIA:
I
have
concluded.
In
fact,

16
those
are
the
two
key
elements.
I've
managed
to
submit
17
them
to
into
the
record,
that
we
expect
the
Office
of
18
Administrative
Law
to
look
at
and
ultimately
reject
this
19
component,
but
we
would
ask
you
to
anticipate
that's
what
20
OAL
would
do
and
if
not,
delete
it.
Thank
you.

21
MS.
RIORDAN:
The
next
person
that
has
the
22
ability
to
stay
within
three
minutes,
come
on
up
and
would
23
you
please
state
your
name
for
the
record?

24
MR.
WARDEN:
Bob
Warden
representing
Western
25
States
Petroleum
Association,
companies
that
produce
most
214
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of
the
transportation
fuel
used
in
California.

2
Fuel
standards
have
come
up
several
times
3
today,
although
the
CARB
staff
has
not
proposed
fuel
4
modifications
as
part
of
the
LEV
II
program.
In
fact
5
Ms.
Guerrero
said
this
morning
that
the
staff
had
6
demonstrated
that
LEV
II
emission
standards
could
be
met
7
even
for
large
sport
utility
vehicles
using
cleaner
burning
8
gasoline,
CBG­
2.

9
Western
States
Petroleum
Association
agrees
10
the
fuel
standards
should
not
be
part
of
the
LEV
II
11
program.
One
manufacturer
this
morning
requested
12
consideration
of
new
fuel
standards
as
part
of
the
program.

13
If
one
is
going
to
consider
new
or
bona
fide
fuel
standards
14
as
part
of
the
LEV
II
program,
then
one
needs
to
examine
15
the
need
and
cost
and
cost
effectiveness
of
the
entire
16
program,
the
fuel
vehicle
system
including
fuel­
side
costs.

17
Granting
staff's
conclusion
that
fuel
18
modifications
are
not
required
to
meet
LEV
II
emission
19
standards,
any
proposals
to
change
fuel
standards
should
be
20
studied
independently,
not
as
part
of
LEV
II.
The
CARB
21
staff
has
started
the
study
process
for
such
fuel
22
specifications,
standard
changes
in
the
deliberate
process
23
for
both
gasoline
and
diesel
fuel.
Thank
you.

24
MS.
RIORDAN:
Thank
you.
Just
a
moment
for
25
this
witness.
Are
there
any
questions
for
this
gentleman?
215
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Seeing
none,
I
thank
you.

2
The
next
gentleman
can
step
forward
and
then
3
I'm
going
to
move
to
Ellen
Garvey.

4
MR.
VILLEGAS:
Members
of
the
Air
Resources
5
Board,
I'm
Mike
Villegas
of
Air
Pollution
Control
District.

6
I'm
representing
our
Air
Pollution
Control
Officer
Richard
7
Baldwin
who
cannot
be
here
today.
I'll
be
providing
8
testimony
on
behalf
of
the
Air
Pollution
Control
Board
to
9
convey
their
support
for
the
proposal
before
you
today.

10
You
have
before
you
one
of
the
most
11
important
emission
reduction
strategies
and
cleaner
burning
12
fuel
requirements.
Our
board
urges
you
to
adopt
the
13
proposed
regulation.
A
Copy
of
our
proposal
was
provided
14
to
you
several
weeks
ago.

15
Ventura
County
has
the
nation's
16
nonattainment
for
the
federal
one­
hour
standard,
and
of
17
course
we're
going
to
be
nonattainment
for
the
8­
hour
and
18
the
new
more
stringent
61­
percent
of
our
ozone
precursory
19
emission
with
on­
road
motor
vehicles
accounting
for
49
20
percent
of
those
emissions.

21
The
District
has
already
implemented
for
all
22
categories
of
stationary
sources.
Reduction
and
control
of
23
emissions
from
motor
vehicles
is
one
of
the
most
cost
24
effective
strategies
still
available.
Subsequently
our
25
interest
in
what
you're
willing
to
do
today
is
very
high.
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BARNEY,
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In
1990,
your
Board
adopted
for
low
emissions
and
clean
2
fuels.
LEV
I
set
increasingly
more
stringent
standards
for
3
light­
duty
cars
and
trucks
to
the
model
year
2003.
An
4
important
aspect
of
this
regulation
was
the
clean
fuel
5
requirement,
the
introduction
of
clean
fuels,
especially
6
sulfuric
acid,
to
not
only
meet
the
current
standards
but
7
allow
them
to
meet
even
more
stringent
in
the
future.

8
The
increased
sales
of
full­
sized
pickup
9
trucks
and
the
recent
introduction
of
the
popular
SUV
has
10
greatly
altered
the
mix
of
light­
duty
trucks
to
cars.
It
11
is
now
common
of
light
trucks
and
SUVs
to
be
used
for
12
primary
transportation.
Once
dominated
by
cars,
it
is
13
approaching
a
split
between
cars
and
light­
duty
trucks.

14
In
1990,
over
80
percent
of
the
vehicle
15
sales
were
cars.
In
1997,
we're
looking
at
54
percent,

16
with
light
trucks
and
SUVs
climbing
to
46
percent.
The
17
trend
has
had
a
substantial
impact
on
California's
air
18
quality
because
although
these
vehicles
are
essentially
19
used
as
passenger
cars,
they're
certified
to
less
stringent
20
emission
standards
designed
for
commercial
work
trucks.

21
The
reclassification
in
the
LEV
regulation
22
of
the
light­
duty
truck
and
medium­
duty
vehicle
categories
23
will
require
them
to
meet
more
stringent
standards.
The
24
amendments
are
applicable
to
both
gasoline
and
diesel
25
powered
vehicles
and
are
essential,
necessary
to
meet
our
217
BARNEY,
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1
state
implementation
plan
goals
for
vehicles.

2
The
emission
reductions
that
will
result
3
from
the
implementation
of
this
regulation
and
the
4
reclassification
of
light­
duty
and
medium­
duty
vehicles
are
5
critical
to
Ventura
County's
efforts
to
meet
the
new
8­
hour
6
federal
standard
and
the
more
stringent
state
standard.

7
In
addition
to
the
other
aspects
of
the
8
regulation,
the
new
super
low
emission
category
and
its
use
9
in
generating
partial
ZEV
credits
if
provided
with
the
10
150,000­
mile
warranty
will
provide
incentives
for
11
automobile
manufacturers
to
make
greater
contributions
to
12
our
emission
reduction
goals.

13
Gasoline
powered
vehicles
currently
have
14
broad
public
acceptance,
much
greater
than
current
­­
we
15
have
electric
vehicles,
and
offering
the
manufacturers
an
16
incentive
for
decelerated
introduction
of
a
technology
that
17
is
transparent
to
the
motoring
public.
It
is
not
a
win­
win
18
situation
for
air
quality
and
the
manufacturers.

19
California
has
always
been
a
leader
in
air
20
pollution
control.
This
has
been
especially
true
for
motor
21
vehicle
emission
control.
The
adoption
of
today's
proposal
22
will
provide
for
you
an
opportunity
to
continue
this
23
leadership.
This
proposed
regulation
is
achievable
and
24
it's
needed.
Therefore
on
behalf
of
our
Board,
I
urge
you
25
adopt
this
regulation.
218
BARNEY,
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1
MS.
RIORDAN:
Thank
you.
Any
questions
for
2
the
witness?
Thank
you.

3
Ellen
Garvey,
come
forward,
please.
You're
4
going
to
represent
both
CAPCOA
and
Bay
Area
AQMD?

5
MS.
GARVEY:
Yes.
Madam
Chair
and
members
6
of
the
Board,
good
afternoon.
My
name
is
Ellen
Garvey
and
7
I
am
the
Executive
Officer
at
the
Bay
Area
AQMD
and
wearing
8
two
hats.
9
First
I
would
like
to
speak
on
behalf
of
the
10
Bay
Area
District
and
secondly
on
behalf
of
CAPCOA.
I
am
11
here
today
to
support
your
proposal
for
the
new
LEV
II
12
standards
and
the
new
LEV
II
regulations.
The
San
13
Francisco
Bay
area
has
almost
five
million
cars
that
14
produce
about
half
of
the
overall
air
pollution
in
the
nine
15
bay
area
counties.
While
the
state
has
done
an
admirable
16
job
in
the
past
years
reducing
emissions
from
the
vehicles,

17
we
still
have
problems
with
ozone
as
well
as
particulate
18
matter,
and
we
still
have
opportunities
to
mitigate
those
19
problems.
The
LEV
II
program
is
a
very
important
step
in
20
this
process.

21
Adoption
of
the
LEV
II
regulations
is
very
22
important
for
the
long­
term
air
quality
prospects
for
the
23
bay
area
as
well
as
for
many
other
nonattainment
areas
24
throughout
the
state.
EPA's
recent
redesignation
for
25
nonattainment
with
the
national
one­
hour
ozone
standard
has
219
BARNEY,
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1
triggered
new
attention
and
what
we
can
do
selectively
to
2
help
continue
to
reduce
pollution
emissions
from
those
3
sources.

4
We
know
that
mobile
sources
represent
the
5
largest
sector
of
emissions
in
the
bay
area
for
ozone,
and
6
they
are
also
mainly
contributors
of
nitrate
and
7
particulate
matter.
To
adopt
new
motor
vehicle
standards
8
as
well
as
new
motor
vehicle
regulations
is
a
noteworthy
9
event.

10
We
supported
and
have
benefited
from
ARB's
11
prior
actions
to
implement
clean
fuels
and
clean
vehicle
12
programs,
your
goal
in
getting
new
as
well
as
effective
13
emission
control
technologies
on
the
road.
We
have
seen
14
the
successful
introduction
and
customer
acceptance
of
15
ultra
low
emission
vehicles
as
well
as
zero
emission
16
vehicles,
and
in
fact
I
have
some
personal
experience
with
17
both.
Recently
I
purchased
a
new
personal
car,
a
Honda
18
Accord
which
meets
the
ULEV
certifications,
and
I
can
19
verify
for
you
today
it
performs
well,
gets
good
gas
20
mileage,
and
all
in
all
it's
a
great
car.
My
agency
has
21
also
purchased
two
vehicles,
a
Toyota
RAV
4
as
well
as
an
22
EV­
plus
with
great
user
satisfaction
and
sparked
a
lot
of
23
public
interest.
They're
comfortable,
they're
reliable
and
24
fun
to
drive.
So
we
feel
very
positive
about
the
ability
25
of
the
manufacturers
to
develop
and
implement
new
as
well
220
BARNEY,
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1
as
cleaner
technologies.

2
We
also
feel
very
positive
about
ARB's
role
3
in
the
foster
of
such
an
implementation.
You
and
your
4
staff
play
a
vital
role
in
expediting
the
research
grants,

5
setting
of
certification
and
durability
standards
and
6
lastly
through
monitoring
compliance.
Your
current
7
proposal
gaps
and
strengthens
some
areas
where
levels
of
8
control
can
be
improved.
These
measures
will
ultimately
be
9
of
great
benefit
to
the
bay
area
as
well
as
other
10
nonattainment
areas
throughout
the
state
by
achieving
11
additional
emission
reductions
beyond
those
attainable
with
12
the
current
LEV
program.

13
LEV
II
will
help
ensure
we
attain
and
14
maintain
California's
state
standards
for
ozone
and
15
particulate
matter.

16
I
bring
with
me
today
a
resolution
from
my
17
Board.
This
resolution
was
brought
yesterday
before
18
Director
DeSaulnier
and
members
of
my
Board.
I
ask
this
be
19
made
a
part
of
the
record.

20
In
closing
I
would
like
to
say
it
is
21
critical
ARB
adopt
the
new
requirements
as
soon
as
possible
22
so
we
can
get
the
process
started
and
see
the
benefits
in
23
the
near
future.

24
With
the
permission
of
the
Chair,
I
would
25
like
to
indulge
your
Board
for
just
a
few
more
minutes
and
221
BARNEY,
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&
ASSOCIATES
1­
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1
speak
on
behalf
of
CAPCOA
in
support
of
LEV
II,
and
I
bring
2
with
me
today
another
resolution
signed
by
the
membership
3
of
CAPCOA
which
occurred
last
week
in
Monterey,
which
the
4
Chairman
also
attended,
and
we
appreciate
your
taking
the
5
time.

6
The
testimony
I
have
just
provided
is
7
essentially
the
same
as
CAPCOA,
so
I'll
not
take
the
time
8
to
repeat
it.
I
will
say
California
air
districts
9
throughout
California
support
LEV
II.
We
ask
you
to
adopt
10
these
requirements
so
we
can
see
the
benefits
of
it
in
the
11
near
future.

12
Thank
you
for
your
time
today,
and
I
will
be
13
happy
to
answer
any
questions
that
you
have.

14
CHAIRMAN
DUNLAP:
Any
questions?
Thank
you.

15
I
appreciate
that.
Always
a
pleasure
to
see
you.
16
Greg,
I
know
you're
going
to
be
speedy,
but
17
before
you
go
up
there,
is
Bob
Carr
here
from
the
San
Luis
18
Obispo
APC?
Had
he
signed
up?
Chung,
are
you
a
19
three­
minute
or
less
guy?

20
DR.
LUI:
I'll
try.

21
CHAIRMAN
DUNLAP:
You
do
three
minutes,
and
22
Greg,
you're
up
next.

23
DR.
LUI:
The
important
issue,
I
think,
is
24
the
need
of
good
air
quality
in
our
basins.
I
do
want
to
25
say
that
Barry
Waters,
our
acting
Executive
Officer
Thomas,
222
BARNEY,
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&
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1
and
he
sent
me
here
to
represent
the
District
on
these
2
issues,
and
I
want
to
go
back
really
fast
on
the
air
3
quality
issue.

4
CHAIRMAN
DUNLAP:
You've
got
to
introduce
5
yourself
to
the
court
reporter.

6
DR.
LUI:
My
name
is
Chung
Lui
for
the
7
record.
I
am
the
Assistant
Deputy
Executive
Officer
for
8
the
South
Coast
AQMD.

9
This
chart
I'm
showing
here
is
the
reason
we
10
are
here
mostly,
and
I
can
probably
say
that
in
the
new
11
8­
hour
ozone
standards
we
are
making
progress,
even
this
12
year,
but
we
still
have
a
long
way
to
go.
The
reason
is
13
that
we
still
are
over
10
days.
We
cannot
meet
the
14
standards
in
our
basin.
We
have
the
worst
quality
air
in
15
this
basin,
but
I
have
to
say
that
ARB's
program
in
the
16
past
two
decades,
probably
in
principal,
is
responsible
for
17
the
improvements.
And
I
also
want
to
say
something
about
18
this
morning's
use
of
control.
We
support
LEV
I.
We
see
19
progress.
Not
only
on
weekdays,
but
on
weekends,
and
we
20
believe
with
LEV
II,
the
progress
to
be
made
on
weekdays
21
and
weekends.
Let's
go
to
the
next
one.

22
We
do
have
another
air
pollution
problem.

23
It's
the
PM2.5
standards
newly
adopted
by
the
EPA.
As
24
these
charts
show,
that
PM2.5
is
probably
a
more
25
discriminating
pollutant
in
terms
of
our
basins.
223
BARNEY,
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1
Everywhere
you
can
see
problems
almost
at
the
same
levels.

2
Also
I
want
to
direct
attention
to
the
3
parts,
the
yellow
part
and
the
pink
part,
the
two
biggest
4
components.
One
is
the
nitrate
component,
the
yellow,
and
5
the
pink
is
ammonia.
Ammonia
nitrate
is
the
single
most
6
important
component
for
PM2.5,
which
is
a
pollutant
killing
7
our
premature
child
here,
and
I
want
to
emphasize
with
8
control
this
is
going
to
come
a
long
way.
So
I
really
want
9
to
put
the
case
on
this
here,
but
we
still
want
to
say
that
10
even
PM10
would
need
improvements.

11
We
have
a
long
way
to
go.
The
1997
AQMD
12
called
for
68
percent
of
VOC
reduction
and
57
percent
13
reduction
NOx.
With
the
new
standards
of
PM2.5
and
8­
hour
14
ozone
standards,
we
have
even
farther
to
go,
and
really
15
most
of
them,
I
would
say
50
percent
of
the
reduction,
we
16
need
to
achieve
clean
air.
We
don't
know
what
to
do
here.

17
If
we
know
what
to
do
with
LEV
II,
let's
do
it.

18
And
especially
this
morning
I
heard
ARB's
19
stipulation
one­
dollar­
per­
pound
cost
effectiveness.
I'm
20
saying
in
our
basin
nowadays,
in
south
coast
we
are
21
stationary
sources.
We
use
a
mainly
10
per
ton.

22
We
do
have
some
input
here
and
quickly
spend
23
about
one
minute
to
summarize
them
all.
We
don't
want
to
24
provide
a
loophole
for
diesel.
We
don't
want
legislation
25
to
become
a
starting
point
to
bring
diesel
back
as
224
BARNEY,
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1
passenger
cars,
and
we
all
know
here
with
one
sports
2
vehicle
coming
to
increase
one
passenger
car.
That's
not
3
replacing
work
truck.
We
all
know
that.
Let's
face
it.

4
If
we
want
to
bring
something
back
with
5
higher
emissions,
we're
going
to
have
worse
air
quality.

6
We
don't
want
that.
We've
got
to
have
one
standard
for
all
7
things
over
8500
pounds.
We
also
want
to
make
sure
the
8
four­
part
ZEV
would
be
LEV,
and
we
want
to
work
with
ARB
9
staff
on
this.

10
And
number
three,
we
believe
the
technology
11
here,
if
we
push
for
two
or
three
years
ahead
of
schedule
12
for
this
hydrocarbon
base,
we
can
achieve
air
better
and
13
sooner.

14
Number
four
and
five
quickly.
We
think,
we
15
believe
the
ARB
staff
did
an
excellent
job,
that
we
want
to
16
support
on
the
emissions
which
we
really
lacked
in
the
17
past,
and
I
think
value
is
a
good
thing
we
strongly
18
support.

19
Lastly,
the
district
pushed
for
the
ozone
so
20
hard,
we
want
to
eventually
­­
even
with
the
defeat
of
21
Proposition
7,
we
want
this
to
be
part
of
the
program
and
22
want
to
make
sure
it's
qualifiable
execution
is
real.
With
23
that,
I'm
putting
my
presentation,
and
if
there's
any
24
questions.

25
CHAIRMAN
DUNLAP:
Thank
you,
Chung.
Any
225
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
326­
5900
1
questions
of
the
witness?
Okay.
Thank
you.

2
Mr.
Vlasek?

3
MR.
VLASEK:
Good
afternoon,
Chairman
and
4
members.
My
name
is
Greg
Vlasek.
I
represent
the
5
California
Natural
Gas
Vehicle
Coalition.
We
are
a
6
40­
member
industry
association
of
Sacramento,
California.

7
I
have
a
single
point.
Our
members,
our
8
coalition
supports
the
partial
ZEV
credit
for
CNG
super
LEV
9
vehicles.
We
are
aware
of
the
evidence
that
staff
has
10
accumulated
in
making
the
decision
to
include
that
11
provision.
In
some
cases
our
members
provided
that
12
information
to
the
staff
and
have
been
working
on
that
for
13
a
number
of
years,
so
we
very
much
appreciate
the
14
recognition
of
natural
gas
vehicles
as
continuing,
as
the
15
benchmark
for
what
is
achievable
in
terms
of
emissions
from
16
IC
engines,
and
our
job
now
of
our
industry
is
to
continue
17
to
build
the
infrastructure
in
California,
to
increase
the
18
demand
for
these
vehicles
and
give
customers
assurance
19
there's
plenty
of
fuel
available
so
we
can
help
get
the
20
vehicle
manufacturers'
incremental
cost
down
from
that
21
dreaded
$
7,000.
Thank
you
very
much.

22
CHAIRMAN
DUNLAP:
Thank
you.
Let
me
run
23
through
the
list
of
folks
who
haven't
testified
yet.
We
24
have
two
representatives
from
Engelhard,
one
Terence
Poles.

25
Is
your
colleague
with
you?
Bill,
did
you
sign
up?
226
BARNEY,
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1
MR.
ROSENBERG:
I
did.

2
CHAIRMAN
DUNLAP:
You're
not
on
my
list
3
here,
Bill.
So
we
have
Jed
Mandel
in
the
bull
pen
over
4
here,
Pat
Charboneau,
Bob
Jorgenson,
Tim
­­
where's
Tim
5
Carmichael?
Tim
in
the
bull
pen,
Jennifer
Jennings,
Bruce
6
Bykowski,
Cece
Martin,
Wayne
Nastri
and
Joe
Caves.
Is
Joe
7
out
there
anywhere?
Did
Joe
already
go?
Come
on
over
8
here,
Joe.
We
have
a
rule
in
here
today.
Cece,
you're
up.

9
MS.
MARTIN:
Good
afternoon,
Chairman
Dunlap
10
and
members
of
the
Board.
My
name
is
Cecille
Martin.
I'm
11
Deputy
Executive
Director
of
the
California
Electric
12
Transportation
Coalition
and
I
am
speaking
today
for
our
13
board
of
directors.

14
I
believe
you
received
letters
from
Sempra
15
Energy
and
SEV
and
Los
Angeles
Department
of
Water
and
16
Power,
and
then
my
comments
will
supplement
that
and
we'll
17
only
be
speaking
today
on
the
zero
emissions
vehicle
18
portion
of
LEV
II.

19
Now,
Chairman
Dunlap,
it's
your
last
Board
20
meeting.

21
CHAIRMAN
DUNLAP:
It
is?

22
MS.
MARTIN:
And
I
wanted
to
be
really
kind,

23
but
I
have
to
take
a
small
issue
with
something
that
you
24
said
earlier
which
possibly
you
didn't
really
mean
the
way
25
I
took
it.
227
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1
CHAIRMAN
DUNLAP:
I
probably
didn't.

2
MS.
MARTIN:
That
CARB
has
swept
away
3
utility
emissions,
and
in
fact
that's
very
much
opposite
is
4
the
case.
That
in
fact
the
bar,
the
lower
bar
for
the
5
SULEV
to
meet
with
their
tailpipe
is
the
upper
bar
of
6
potentially
what
utility
emissions
could
be
if
they
weren't
7
as
regulated
as
they
are
in
this
state.
Utility
emissions
8
are
very
clean,
and
it
is
also
that
statement
that
gets
our
9
hackles
up
a
little
bit
because
we
like
to
remind
people
10
that
every
vehicle
on
the
road
has
upstream
emissions.

11
For
us,
they're
power
plants
and
they're
12
very
clean,
but
as
other
witnesses
have
mentioned,
they're
13
refueling,
distributions
and
marketing
as
other
fuels,
and
14
we
like
to
look
at
it
as
a
whole
package.

15
So
I
want
to
tell
you
today
that
we
are
in
16
general
support
of
what
you're
doing.
In
fact
there's
only
17
one
exception
and
that
exception
is
that
we
don't
believe
18
gasoline
SULEVs
have
the
ZEV
characteristics
described
in
19
the
report.
We
think
it's
theoretically
inconsistent
with
20
the
way
in
which
ZEV
characteristics
have
been
described.

21
I
would
leave
it
at
that,
but
there
are
a
22
few
other
things
I
need
to
say
because
I
understand
that
23
some
of
the
documents
that
the
Board
has
received
recently
24
said
that
ZEVs
don't
really
have
a
big
part
of
the
future.

25
And
I
want
to
tell
you
that
the
EV
market
228
BARNEY,
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ASSOCIATES
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1
has
just
begun.
Ten
years
ago
an
EV
market
was
your
2
Board's
vision
and
today
it's
a
reality.
The
Board
has
3
changed
the
world's
view
of
our
transportation
future
by
4
making
EVs
a
part
of
the
transportation
mix.

5
You
have
done
an
incredible
thing.
You've
6
created
a
legacy
that
holds
the
future
and
you
haven't
7
stopped
there.
You've
gone
beyond
regulation
by
8
recognizing
that
help
is
needed
to
develop
this
new
market,

9
to
ensure
its
success
and
the
continued
commitment
from
all
10
of
the
stakeholders.

11
CARB
has
supported
vehicle
and
12
infrastructure
incentives,
infrastructure
development,

13
safety
training
and
now
have
a
developing
EV
loader
program
14
and
more.
We
appreciate
this.
The
market
needs
it.
The
15
market
needs
your
continuing
support.

16
Now
as
we
look
to
the
future,
we
see
that
17
the
challenge
that
you
face
is
to
craft
a
mobile
source
18
strategy
to
get
the
state
to
attainment
in
2010
and
19
maintain
that
level
of
cleaner,
healthier
air
in
the
years
20
beyond.
The
Board's
successful
strategies
to
technologies
21
have
resulted
in
the
most
significant
mobile
emissions
22
reductions,
and
yet
there
is
a
shadow
stalking
this
23
success.

24
Predictions
for
California's
growth
turn
25
every
mile
gained
into
an
inch.
With
population
expected
229
BARNEY,
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1
to
double
in
the
next
30
or
40
years,
California
can
expect
2
an
accompanying
doubling
of
cars
and
trucks.
This
growth
3
trend
turns
26
million
vehicles
into
46
million.
In
the
4
interim,
these
emissions
must
still
be
multiplied
by
the
5
number
of
vehicles
in
the
state
and
by
the
increasing
6
vehicle
miles
traveled.

7
It
is
within
this
perspective
that
CARB's
8
reasoning
behind
the
gold
standard
becomes
clear.
True
9
ZEVs
are
a
necessary
part
of
mobile
source
strategy
because
10
zero
times
46
million
is
still
zero.
Cal.
ATC
is
not
11
suggesting
that
EVs
will
make
up
100
percent
of
12
California's
vehicles.
We
are
suggesting,
however,
that
13
the
unique
characteristics
of
battery
electric
and
other
14
vehicles
that
rely
on
electric
drive
systems
like
hybrid
15
electric,
that
accompanies
growth
by
offering
100
percent
16
or
some,
for
example
there,
of
zero
emission
miles.

17
We
believe
that
this
perspective
is
an
18
important
one
to
keep
in
mind
today
when
considering
19
increasing
flexibility
to
the
2003
10­
percent
ZEV
20
requirement.
The
zero
emission
miles
that
have
become
the
21
gold
standard
are
also
the
less
costly
miles
both
in
terms
22
of
the
environment
and
the
fuel
when
they
are
derived
from
23
California's
clean
electricity
generation.

24
EVs
and
HEVs
that
plug
into
fuel
capture
25
this
benefit,
and
this
benefit
takes
on
more
importance
as
230
BARNEY,
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ASSOCIATES
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1
we
move
on
to
the
next
century.
As
more
California
2
vehicles
meet
the
new
SULEV
standard,
the
largest
source
of
3
fuel
emissions
will
be
the
combination
of
evaporatives
that
4
occur
upstream
of
the
vehicle.

5
Electric
drive
addresses
the
fuel
cycle
6
issue.
When
fueled
by
electricity,
electric
drive
offers
7
the
lowest
fuel
cycle
emissions
of
any
fuel
and
completely
8
eliminates
the
emissions
that
occur
from
fuel.

9
California's
power
mix
can
be
considered
in
the
manner
10
staff
is
proposing
that
versions
should
be
considered,
that
11
is
that
they
will
be
driven
a
certain
portion
of
the
time
12
as
zero
emission
vehicles.

13
When
considering
the
types
of
power
14
generation
that
serve
California,
a
significant
portion
of
15
these
sources
deliver
electricity
emission
free.
This
16
emissions
reduction
opportunity
is
not
available
from
any
17
other
transportation
fuel.

18
Cal.
ATC
has
been
asked
how
electricity
19
deregulation
will
effect
the
state's
power
generation.

20
Well,
we
don't
use
a
crystal
ball.
Energy
analysts
have
21
said
that
deregulation
will
likely
spur
reductions
as
22
utilities
sell
off
power
plants
and
new
energy
providers
23
power
them
cleaner
over
time,
decreasing
current
and
future
24
power
plant
regulation
and
technology
advancement.

25
Best
available
retrofit
control
technology
231
BARNEY,
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1
will
assure
lower
than
current
emission
levels
and
level
2
the
impacted
areas
like
the
South
Coast
Air
Quality
3
Management
District
who
have
an
emissions
cap
for
power
4
plants
over
their
entire
basin,
further
encouraging
this
5
downward
trend.

6
Today
we've
heard
a
little
bit
about
this
7
150,000­
mile
warranty,
and
we
believe
that
deterioration
is
8
another
shadow
that
follows
even
the
cleanest
vehicle,
9
followed
by
an
internal
combustion
engine
over
the
life
of
10
the
conventional
vehicle
and
will
also
continue
to
occur
11
although
hopefully
with
on­
board
diagnostics.

12
Again
looking
to
the
future,
Cal.
ATC
feels
13
it
is
important
to
know
the
longer
vehicle
lifetime
14
durability
without
any
off­
cycle
emissions.
Because
they
15
have
eliminated
the
need
for
a
tailpipe,
EVs
stay
clean
16
without
smog
check
and
with
no
possibility
of
equipment
17
failure.

18
CHAIRMAN
DUNLAP:
Cece,
I
have
the
letter.

19
You're
doing
good.

20
MS.
MARTIN:
I
am
not
going
to
go
through
21
the
bottom
part.
I
would
like
to
do
three
more
paragraphs.

22
CHAIRMAN
DUNLAP:
Okay.

23
MS.
MARTIN:
Okay.
There
are
additional
24
electric
drive
benefits
that
although
not
directly
part
of
25
CARB
ZEV
program,
remain
an
area
of
concern
in
the
state
232
BARNEY,
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&
ASSOCIATES
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1
and
the
world.
California
EVs
offer
significant
net
2
reductions
of
CO2
up
to
70
percent.
Vehicles
with
even
3
partial
electric
drive,
as
long
as
they
are
fueled
in
part
4
by
electricity,
will
always
offer
CO2
benefits
because
5
electric
drives
displace
CO2
created
by
gasoline
6
combustion.

7
Overall
reduction
of
CO2.
Electric
drive
8
can
be
two
to
three
times
more
­­
and
EVs,
electric
drive
9
vehicles,
for
the
portion
they're
on
electric
do
not
expose
10
the
population
to
toxics,
Benzene,
and
all
known
for
their
11
effects
on
human
health.

12
Now
I'm
going
to
skip
through
the
rest
of
13
this
because
I
know
you
have
my
written
testimony,
but
I
14
did
want
to
end
by
saying
that
our
organization
has
been
to
15
many
of
these
hearings
and
often
our
testimony
is
a
small
16
part
of
the
whole,
and
we
want
you
to
know
we
didn't
17
overlook
the
whole
and
we
want
to
commend
you
for
the
hard
18
work
that
we've
seen
you
do
this
year,
1998.
We
feel
19
you've
taken
on
the
challenge
and
that
you've
been
very
20
consistent
in
passing
the
measures
that
are
critical
to
21
success,
and
we
feel
this
program,
if
passed
today,
would
22
create
a
significant
contribution
towards
the
ZEV
and
23
toward
the
reduction
in
mobile
source
emissions.
We
would
24
like
to
thank
you
for
that
in
the
broadest
sense.

25
CHAIRMAN
DUNLAP:
Thank
you.
Any
questions
233
BARNEY,
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1
of
the
witness?
Okay.
Very
good.

2
Engelhard,
you're
up
next.
Is
there
any
3
other
three­
minute
people
in
that
group
by
chance?
There's
4
two
three­
minute
people.
Would
you
yield,
sir?
The
lady
5
in
red
in
the
back.
Sorry.
Hang
on.
We'll
get
to
you
and
6
there's
­­

7
MS.
JENNINGS:
Thank
you,
Chair.
My
name
is
8
Jennifer
Jennings.
I'm
here
on
behalf
of
the
Planning
and
9
Conservation
League
and
I
forgot
blue,
gray
and
brown
was
10
the
color
requirement
for
ARB
hearings.

11
I
submitted
written
comments
and
I
don't
12
want
to
go
over
those.
I
want
to
support
the
comments
made
13
by
my
colleagues
on
their
three
major
points.
14
We
oppose
the
credit
for
gasoline
SULEVs
15
because
they
do
not
have
the
characteristics.
Introduction
16
of
diesels,
I
think
that
if
you
want
advances
in
heavy­
duty
17
diesel
technology,
you
need
to
address
that
directly
rather
18
than
indirectly,
and
we
applaud
the
restrictions
on
the
19
SUV,
but
we
do
not
think
the
evidence
supports
the
work
20
trucks.

21
I
also
want
to
say
in
addition
to
my
written
22
comments
that
we
do
support
the
extended
warranty
control
23
system.
I
was
not
aware
that
was
an
issue
so
I
didn't
24
include
it
in
my
letter,
but
I
think
it's
a
very
important
25
proposal
and
we
urge
you
to
stick
with
it.
234
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1
Thank
you
very
much.

2
CHAIRMAN
DUNLAP:
Thank
you.
Thanks
for
3
your
patience.

4
By
the
way,
I
think
we
have
eight
witnesses
5
left.

6
ALABC
REPRESENTATIVE:
Thank
you,
Chairman
7
Dunlap.

8
My
name
is
­­
Advanced
Lead
Acid
Battery
9
Consortium.
We're
here
in
support
of
the
proposed
LEV
II
10
program.
I
think
staff
has
done
an
excellent
job.
I
think
11
it's
only
appropriate
you're
here
in
the
South
Coast
Basin
12
as
you
consider
adopting.
The
ALABC
does
have
some
ideas
13
in
terms
of
increasing
the
flexibility
with
regard
to
the
14
ZEVs
and
we've
had
discussions
with
staff
and
they've
15
agreed
to
continue
those
discussions
and
move
forward
in
16
terms
of
additional
range
and
addressing
the
fast
recharge
17
capabilities.

18
So
again,
we
urge
you
to
adopt
the
LEV
II
19
proposal.
Thank
you.

20
CHAIRMAN
DUNLAP:
Thank
you.
Any
questions?

21
Terry,
you're
up.
Thank
you
for
your
patience,
too.

22
MR.
POLES:
Thank
you.

23
CHAIRMAN
DUNLAP:
But
I
think
you
did
24
signify
you
were
in
the
neighborhood
of
a
three­
minute
job
25
I
thought;
is
that
right,
Bill?
235
BARNEY,
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1
MR.
POLES:
Three,
three
and
a
half
minutes
2
or
so.

3
Chairman
Dunlap
and
members
of
the
Board,
my
4
name
is
Terry
Poles.
I
am
the
Director
of
New
Ventures
for
5
Engelhard,
developer
of
the
Premiere
ozone
catalyst
system.

6
First
of
all
I
would
like
to
thank
the
staff
7
for
their
cooperation
over
the
last
three
years
and
really
8
putting
together
a
full
scientific
study
of
this
9
technology.
Premiere
catalyst
involves
coating
automotive
10
or
truck
radiators
or
other
heaters
as
shown.
This
special
11
catalyst
destroys
between
17
and
19
percent
of
the
ozone
in
12
the
air
that
passes
through
this
coating.
As
far
as
CARB's
13
action,
to
introduce
the
Premiere
catalyst
in
the
program
14
will
not
only
provide
complying
with
the
LEV
requirements,

15
but
it
will
also
illustrate
California's
support
for
the
16
development
of
new
technologies.
These
can
reduce
the
17
exposure
of
citizens
to
harmful
pollutions.
In
this
way
18
the
Board
can
encourage
the
industry
to
continue
its
19
research
and
development
activities
to
bring
forward
new
20
innovative
technologies
that
will
be
needed
to
meet
the
21
needs
of
California
citizens
in
the
coming
years.

22
An
analogy
of
this
technology
can
be
drawn
23
back
to
the
mid­
1970s
when
Volvo
Car
Company
first
began
24
using
innovative
ideas.
That
was
the
three­
way
catalytic
25
converter
which
was
being
developed
by
Engelhard
236
BARNEY,
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1
Corporation.
Today
it
continues
to
spend
more
than
$
50
2
million
a
year
to
develop
new
technologies
like
the
3
catalytic
converter
and
Premiere
catalyst
system.

4
Volvo
has
again
demonstrated
its
5
technological
leadership.
It
plans
to
install
the
catalyst
6
on
its
new
line
of
SAT
vehicles
beginning
next
year.
We
7
believe
that
Volvo's
voluntary
action
like
the
events
in
8
the
mid­
1970s
will
usher
in
a
new
technological
innovation.

9
Recognition
of
the
potential
air
quality
10
benefits
from
this
approach
will
support
the
11
commercialization
of
this
and
other
innovative
12
technologies.
The
South
Coast
Air
Quality
Management
13
District
and
the
CARB
staff
has
recognized
the
potential
14
air
quality
benefits.
The
SCAQMD
has
concluded
in
its
1997
15
Air
Quality
Management
Plan
control
measure
programs
to
16
reduce
­­
levels
which
prefers
to
the
Premiere
catalyst
and
17
its
use
on
air
conditioning
utilities.
The
Premiere
18
catalyst
directly
destroys
ozone
which
is
coated.
It
is
19
therefore
a
fuel
neutral
technology.

20
The
primary
applications
of
the
technology
21
as
shown
in
this
slide
are
in
automobiles,
trucks,
urban
22
bus
radiators
where
it's
already
applied
in
some
areas,
and
23
residential
and
commercial
air
conditioning
systems.

24
Application
of
the
Premiere
catalyst
coating
to
an
25
automobile
or
truck
radiator
takes
advantage
of
the
237
BARNEY,
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existing
air
flow
being
used
for
engine
cooling
and
the
2
moderate
temperatures
associated
with
the
air
cooling
3
system.
The
radiator
even
on
vehicles
is
currently
4
designed
effectively
and
becomes
an
ozone
scrubbing
device.

5
Testing
in
California
has
shown
that
the
6
Premiere
catalyst
reduces
ozone
concentration
in
the
air
by
7
approximately
75
percent
or
more.
Manufacturers
also
8
suggested
that
enhancements
to
the
radiator
and
cooling
9
system
could
increase
the
effectiveness
of
the
Premiere
10
catalyst
considerably.

11
The
Premiere
catalyst,
unlike
traditional
12
ozone
control
measures,
directly
destroys
the
ozone
rather
13
than
the
OCs
and
NOx.
To
understand
the
potential
quality
14
benefits
from
this
approach
and
relate
the
benefits
from
15
traditional
ozone
control
strategists,
we
began
working
16
almost
four
years
ago
with
John
Seinfeld
at
Cal
Tech
and
17
others
recognized
in
atmospheric
modeling,
with
CARB
18
modelists
and
from
the
AQMD.
These
provide
the
methodology
19
in
the
CARB
staff
proposal
for
assessing
the
air
quality
20
benefits
of
the
Premiere
catalyst.

21
In
summary,
we
appreciate
the
support
that
22
we
have
received
from
CARB
staff
in
evaluating
the
Premiere
23
catalyst
and
developing
a
reasonable
approach
for
assessing
24
the
value
of
this
innovative
technology
in
the
LEV
program.

25
We
look
forward
to
working
with
the
staff
to
determine
the
238
BARNEY,
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appropriate
procedures,
for
demonstrating
durability
of
the
2
catalyst
and
other
specifications
of
the
particular
3
catalyst
applications.

4
We
encourage
the
Board
to
approve
the
5
staff's
recommendation.
Thank
you.

6
I'll
be
glad
to
answer
any
questions.

7
MR.
CALHOUN:
Excuse
me,
Terence.
This
is
a
8
relatively
new
technology
as
you
know,
and
there's
people
9
who
couldn't
understand
the
mechanisms
of
how
it's
taking
10
place.
I
was
having
a
discussion
with
someone
in
the
past
11
week
or
so
and
I
was
told
that
some
of
the
ozone
that
is
12
initially
converted
is
lost.
By
that,
I
mean
some
of
it
is
13
reconverted
to
ozone.
Do
you
have
any
knowledge
of
that
at
14
all?

15
MR.
POLES:
Mr.
Calhoun,
we
have
conducted
16
some
chamber
assessments
at
the
University
of
North
17
Carolina
and
here
in
California
which
gets
at
the
issue
of
18
does
this
ozone
reform
after
it's
being
destroyed.
Almost
19
immeasurable
quantities
are
reformed.
Once
the
ozone
is
20
destroyed,
it
stays
destroyed.

21
MR.
CALHOUN:
I
think
that's
important,

22
although
the
staff
has
tried
to
build
into
the
proposal
23
certain
amounts
that
you
would
have
to
accomplish,
that
you
24
would
have
to
accomplish
in
order
to
get
credit.
I
think
25
it's
important
you
take
those
factors
into
consideration.
239
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CHAIRMAN
DUNLAP:
Ms.
Edgerton.

2
MS.
EDGERTON:
I
wanted
the
staff
to
clarify
3
one
point
with
respect
to
this
catalyst,
Premiere
4
ozone­
eating
catalyst.
Is
the
one
person
­­
that's
5
supposed
to
apply
to
any
vehicle
that
has
that
technology
6
applied
on
it,
or
is
it
supposed
to
­­
not
the
1
percent,

7
the
credit.
Is
that
supposed
to
apply
to
any
vehicle
that
8
has
this
or
is
it
supposed
to
apply
only
to
vehicles
which
9
otherwise
qualify
under
the
ZEV
partial
credit?

10
MR.
CACKETTE:
It
can
be
used
by
any
11
vehicle.

12
MS.
EDGERTON:
The
thing
that
confuses
me,

13
if
it's
used
by
any
vehicle
it
might
be
double
benefit
in
14
the
sense
that
a
car
is
motoring
along
and
it's
emitting
a
15
certain
amount
of
emissions
which
will
produce
ozone
and
16
also
eating
up
some
of
those,
so
it
might
have
a
net
­­

17
your
overall
emissions
factor
for
the
car
would
already
18
have
been
reduced
by
the
ozone­
eating
catalyst,
wouldn't
19
it?

20
MR.
CACKETTE:
Well,
the
way
it
works
is
21
return
the
ozone­
eating
capability
of
that
into
negative
22
grams
per
mile
of
hydrocarbons
which
then
could
be
added
to
23
the
tailpipe
emissions
to
determining
compliance
with
the
24
standard,
so
that's
how
the
scheme
works.
So
it
has
to
be
25
standard,
but
essentially
get
credit
in
negative
grams
per
240
BARNEY,
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1
mile
of
hydrocarbons
for
the
ozone
that
it
siphoned
out
and
2
removed.

3
MS.
EDGERTON:
So
it
gets
the
credit
versus
4
the
­­
and
gets
the
credit
toward
the
ZEV
standard.

5
MR.
CACKETTE:
Yes,
that's
true.
SULEV
6
without
a
catalystic
radiator,
also.
To
gain
the
ZEV
7
credit,
you
have
to
have
the
SULEV
standard,
but
then
you
8
have
to
have
the
150,000­
mile
warranty,
you
have
to
have
9
zero
incentive,
half
a
gram
of
­­
you
have
to
have
OBD
10
compliance
for
150,000
miles.
You
have
to
have
all
these
11
things
that
are
a
threshold
before
you
get
a
ZEV
credit.

12
CHAIRMAN
DUNLAP:
Thank
you.
Tom
or
Mike,

13
with
this
I'm
not
trying
to
be
critical
of
this
technology.

14
Are
we
talking
about
granting
any
credits
here
for
nothing?

15
We
are
getting
emission
reduction;
right?
And
they're
16
going
to
be
credited
accordingly;
right?

17
MR.
CACKETTE:
We've
looked
at
this
very
18
carefully
and
there's
no
doubt
it
reduces.
The
only
issues
19
remaining
are
things
like
durability
issues,
what
happens
20
if
you
get
in
an
accident,
do
you
get
one
that's
coated.

21
The
uncertainty
level
in
the
chemistry
that
develops
the
22
credit
numbers
is
relatively
small
as
the
credits
are
23
relatively
small,
so
I
don't
think
there's
a
lot
of
risk
24
associated
with
this
device,
and
it's
always
going
to
be
25
positive.
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CHAIRMAN
DUNLAP:
The
briefings
I've
had
is
2
these
folks
are
willing
to
work
with
us
to
make
sure
that
3
it
is
durable
and
the
credits
are
real,
and
that
people
4
know
it's
having
a
positive
effect.
So
I
know
there's
5
people
that
kicked
it
a
little
bit
today.
I'm
just
trying
6
to
understand
the
rationale.
Mr.
Rosenberg.

7
DR.
FRIEDMAN:
I
just
want
to
add,
the
8
cross­
sectional
area
is
a
key
determinant
so
the
effect,
if
9
I'm
right,
would
be
relatively
greater
in
a
big
truck
than
10
an
automobile?

11
MR.
ROSENBERG:
That's
absolutely
right.

12
The
benefit
is
proportional
to
the
volume
of
air.
So
13
that's
the
two
things,
the
size
of
the
radiator
and
how
14
quickly
the
air
passes
through.

15
CHAIRMAN
DUNLAP:
Great.

16
MR.
ROSENBERG:
Mr.
Chairman,
members,
my
17
name
is
William
Rosenberg.
I'm
president
of
AQ
Ventures
18
and
I
serve
as
an
advisor
to
Engelhard.
In
1990
when
you
19
passed
the
LEV
I,
I
was
the
assistant
administrator
of
the
20
EPA
serving
along
with
Jack
Crammel
and
the
Bush
21
administration,
and
it
was
great
to
work
with
you
in
that
22
capacity
and
I'm
glad
to
be
here
today.

23
I
put
aside
my
prepared
text
to
make
a
24
couple
of
points.
In
my
opinion
I
think
this
is
one
of
the
25
most
important
potential
pollution
control
technologies
242
BARNEY,
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that
has
come
along
in
a
long
time.
Because
of
the
fact
2
that
it's
totally
transparent,
it
goes
­­
it
comes
in
the
3
form
of
a
paint
actually.
It
looks
like
a
paint.
It
goes
4
on
the
radiator
of
a
car
or
goes
on
the
air
conditioning
5
condenser
coil
in
your
backyard
or
goes
on
the
air
6
conditioner
of
a
bus
or
radiator
of
a
bus.
And
yet
even
7
these
are
all
small
negative
sources.
The
modeling
that
8
Tom
Cackette
talked
about
that
had
been
reviewed
by
the
9
South
Coast
Air
Quality
Management
District
and
by
your
10
people
with
the
benefit
of
SAI
and
other
very,
very
good
11
people,
shows
if
this
were
on
all
air
conditioners,

12
theoretically
it
could
be
potentially
as
much
as
a
10,
15,

13
or
20
percent
­­
if
you
took
20
tons
of
VOV
out
of
the
air,

14
you
get
about
the
same
ozone
benefit
as
if
you
put
this
on
15
all
the
radiators.

16
We
were
very
disappointed
when
Proposition
7
17
was
defeated
because
this
would
be
a
way
to
make
this
18
happen.
The
utilities
could
have
put
this
on
people's
air
19
conditioners
and
had
this
paid
for
with
the
South
Coast,

20
but
this
is
a
very
important
step
forward.

21
I
think
the
fact
that
they
spent
millions
of
22
dollars
of
private
money
developing
this
is
attributed
to
23
the
policies
of
this
Board
because
you
have
set
the
24
opportunity
for
people
to
come
forward
with
new
25
technologies.
This
is
really
new.
This
is
out
of
the
box
243
BARNEY,
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in
a
real
sense,
although
it
will
help
in
what
you're
2
doing.

3
One
of
the
issues
I
did
want
to
address
for
4
a
moment
and
then
I'll
sit
down,
is
that
as
the
Chairman
5
mentioned,
before
any
company
­­
whether
it's
Volvo
or
6
anyone
else
­­
gets
any
credits
whatsoever,
they're
going
7
to
have
to
bring
their
testing,
their
car
and
test
it
8
before
new
certification
tests
under
CARB
staff
direction
9
as
to
durability,
as
to
impact
of
different
environments,

10
they
would
have
to
meet
the
same
warranties
for
this
credit
11
as
anybody
else
would
have
to
meet.

12
There's
an
OBV
II
requirement
that
has
to
13
get
worked
out,
so
the
actual
credits
will
be
the
function
14
of
a
car
company
coming
forward
two
to
three
years
from
15
now,
request
this
on
the
radiator
and
saying
we
believe
16
under
your
rules
and
regulations
with
your
testing
we're
17
entitled
to
0.1
grams­
per­
mile
credit
or
something
of
that
18
sort.

19
This
is
not
going
to
solve
the
problems,

20
but
it
is
a
step
forward.
It
does
enable
car
companies
to
21
meet
your
stringent
requirements,
and
if
we're
lucky
and
it
22
is
on
buses
and
trucks
and
on
air
conditioners
and
on
cars,

23
besides
them
being
very
happy,
I
think
the
air
quality
in
24
this
region
will
improve
dramatically.

25
We
really
do
appreciate
you,
and
the
staff
244
BARNEY,
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has
given
to
bringing
forward
new
technology,
and
it's
a
2
lot
harder
on
the
outside
to
do
that
than
it
looked
like
in
3
the
EPA,
and
you
guys
have
really
made
it
work.

4
Thank
you
very
much.

5
CHAIRMAN
DUNLAP:
One
comment
I
made
when
6
Tom
or
Mike
and
I
met
with
Bill
Rosenberg
­­
and
Bill,
you
7
can
tell
this
story
better
than
I
­­
I
was
impressed
with
8
your
commentary
about
the
rigorous
nature
of
the
staff
9
review
of
any
new
technology,
in
particular
yours,
really
10
putting
us
through
the
paces
here.
That
impressed
me,
not
11
only
in
the
diligence
of
the
staff
trying
to
get
to
the
12
bottom
of
how
much
value
could
be
attributed
to
this,
but
13
also
to
your
and
Engelhard's
contribution
to
working
14
through
this.
It's
not
easy.

15
MR.
ROSENBERG:
They
were
outstanding,
and
16
of
course
they
have
a
lot
of
experience
with
Engelhard.

17
They
did
develop
the
three­
way
catalyst
back
in
the
70s.

18
I'm
sure
some
of
the
catalysts
they
were
testing
were
19
probably
from
them
or
it
involved
their
technology.

20
The
company
views
itself
in
the
same
21
business
that
the
Board
is
in,
and
although
they
very
much
22
want
to
serve
their
customers,
the
car
companies,
to
give
23
them
cost
effective
solutions
to
these
problems,
but
this
24
part
of
your
LEV
II
proceeding
I
think
will
be
one
of
the
25
finest
moments
of
this
Board
and
provide
great
dividends
in
245
BARNEY,
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1
the
future
if
these
other
potentials
can
occur.

2
CHAIRMAN
DUNLAP:
Thank
you.
Okay.
Six
3
witnesses
remaining.
Jed
Mandel,
Pat
Charboneau,
Bob
4
Jorgenson,
Tim
Carmichael,
Bruce
Bykowski
and
Joe
Caves.

5
We'll
go
in
that
order
unless
someone
wants
6
to
change.

7
MR.
MANDEL:
Good
afternoon.
I'm
Jed
Mandel
8
speaking
on
behalf
of
the
Engine
Manufacturers
Association.

9
As
you
know
from
my
frequent
appearances
before
you
this
10
year,
EMA's
members
make
a
number
of
products
regulated
by
11
the
California
Air
Resources
Board.
Today
I
am
principally
12
addressing
issues
of
concern
of
diesel
engine
13
manufacturers.

14
As
we
have
discussed
with
you
and
the
staff
15
in
this
and
other
rules,
diesel
engine
manufacturers
have
16
achieved
significant
success
in
reducing
the
emissions
of
17
NOx
particulate
matter
and
hydrocarbon
from
compression
18
engines,
and
also
as
we
have
discussed,
we
have
submitted
19
today
even
greater
reductions
and
even
more
might
be
20
feasible.

21
The
engine­
out
emission
levels
which
have
22
been
achieved
from
diesel
engines
have
truly
been
23
remarkable.
We
believe
there's
an
opportunity
to
replicate
24
that
success
in
applying
aftertreatment
technologies
to
25
diesel
engines.
246
BARNEY,
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&
ASSOCIATES
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1
However,
there
are
significant
technical
2
barriers
which
must
be
overcome.
These
include
the
fact
3
that
compression
ignition
engines
are
lean
burning.
That
4
is,
their
exhaust
is
relatively
cool,
and
the
most
5
promising
advanced
technologies
are
very
sensitive
to
fuel
6
sulfur.
If
these
problems
can
be
overcome,
and
we
believe
7
that
they
can,
there
will
be
an
opportunity
to
optimize
8
emissions
performance,
commercialize
advanced
technologies
9
and
apply
those
technologies
to
a
wide
range
of
diesel
10
engine
applications.
That's
the
prize
we
must
focus
on.

11
The
staff
has
proposed
an
unbelievably
12
challenging
set
of
standards.
The
diesel
engine
13
manufacturers
will
do
their
best
to
provide
products
which
14
can
comply,
and
by
so
doing
to
give
Californians
the
15
opportunity
to
have
a
power
choice
that
provides
them
the
16
performance,
durability,
high­
torque
pulling
power
and
17
outstanding
fuel
economy
they
want,
all
without
adverse
18
emissions
impacts
and
while
maintaining
the
well
recognized
19
low
CO
and
low
CO2
and
essentially
zero
evaporated
20
emissions
associated
with
diesel
engines.

21
Because
the
standards
are
so
challenging
and
22
the
availability
of
technological
breakthroughs
is
still
23
uncertain,
it
is
critical
ARB
continue
to
monitor
and
24
report
on
progress
being
made
as
part
of
the
technology
25
review
process.
We
look
forward
to
working
with
the
staff
247
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
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1
on
that
effort
and
sharing
our
knowledge
and
our
expertise
2
with
them
and
with
you.

3
On
a
brief
personal
note,
EMA
has
appeared
4
before
this
Board
at
almost
every
one
of
your
hearings
this
5
year.
This
has
had
two
benefits.
It
has
had
assured
full
6
employment
for
EMA
staff
and
it
has
provided
us
an
7
opportunity
to
work
with
this
Board
and
its
Chairman.

8
One
might
not
think
that
would
be
a
positive
9
experience
since
you
are
the
regulators
and
we
are
the
10
regulated
industry.
That
has
not
been
the
case
even
though
11
we
don't
always
agree.
We
thank
you
for
your
willingness
12
to
work
with
us.

13
We
wish
the
Chairman
well
in
his
future
14
endeavors.
Two
of
EMA's
members,
Navistar
and
Cummins,
are
15
going
to
follow
me
with
specific
comments.
However
if
you
16
have
any
questions,
as
always
we
would
be
pleased
to
answer
17
them.

18
CHAIRMAN
DUNLAP:
Thank
you.
You
want
to
19
introduce
them?
Go
ahead,
Jed.

20
MR.
MANDEL:
Pat
Charboneau.

21
MR.
CHARBONEAU:
Chairman
Dunlap,
members
of
22
the
Board
and
staff,
my
name
is
Pat
Charboneau.
I'm
the
23
Vice
President
of
Engine
Engineering
for
Navistar.
I
24
appreciate
the
opportunity
to
speak
here
today.

25
First
I
would
like
to
say
we
really
248
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
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1
appreciate
the
staff's
willingness
to
listen
carefully
to
2
our
concerns
and
to
try
to
respond
to
these
concerns,
and
3
we
will
support
the
LEV
II
proposal
as
it
moves
forward.

4
Having
said
that,
I
want
to
make
it
clear
5
this
proposal
sets
a
tremendous
technical
challenge
in
6
front
of
us.
We
cannot
meet
the
standards
with
our
current
7
technology,
but
Navistar
has
a
history
and
will
therefore
8
focus
our
advanced
technologies
on
meeting
the
new
9
challenge.

10
Navistar
was
the
first
engine
manufacturer
11
to
demonstrate
it
was
possible
to
meet
the
heavy­
duty
one,

12
the
four­
particulate
standard
five
years
ahead
of
time,
and
13
we
did
this
by
coming
out
to
California
and
providing
a
14
demonstration.
Last
year
we
presented
two
demonstrations
15
to
meet
the
2004
emission
standards,
and
one
of
those
16
demonstrations
actually
used
a
pass
trap
with
a
serum
fuel
17
additive
and
came
within
gasoline
level
particulate
18
standards
certified
in
California
to
the
LEV
standard.
19
To
meet
the
emissions
challenges,
clean
20
diesel
fuel
will
allow
Navistar
to
leverage
its
advanced
21
technology,
sulfur
content
down
to
30
parts
per
million.

22
Navistar
looks
forward
to
working
with
the
23
Board
and
the
staff
to
achieve
nationwide
low
sulfur
diesel
24
fuel
standards
that
will
propel
further
technological
25
breakthroughs.
249
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
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1
We
appreciate
the
opportunity
to
making
2
another
contribution
to
cleaning
California
air
by
3
impacting
light­
and
heavy­
duty
diesel
vehicles
with
4
cleaner
fuel.
Thank
you.

5
CHAIRMAN
DUNLAP:
Thank
you.
We'll
hear
6
from
your
colleague
now,
Bob
Jorgenson.
Good
to
see
you.

7
MR.
JORGENSON:
Thank
you.
Chairman
Dunlap,

8
members
of
the
Board,
good
afternoon.
My
name
is
Bob
9
Jorgenson.
I'm
the
Director
of
Product
Developmental
10
Management
at
Cummins
Engine
Company.

11
As
many
of
you
know,
Cummins
Engine
Company
12
has
manufactured
diesels
for
on­
highway,
mobile
off­
highway
13
and
stationary
applications
around
the
globe.
We
are
in
14
the
process
of
developing
a
family
of
smaller
engines,
one
15
target
for
which
is
light­
duty
trucks.

16
Compression
ignition
engines
have
a
number
17
of
attributes
which
we
believe
will
make
them
attractive
in
18
this
market.
For
the
purchasers
of
these
vehicles,
first
19
and
foremost
is
the
improved
fuel
economy.
Direct
20
injection,
compression
engines
offer
50
to
70
percent
of
21
improvement
over
their
spark­
ignited
counterparts.
In
22
addition,
their
towing
capacity
will
offer
a
much
sought
23
after
asset,
but
there
are
also
significant
environmental
24
attributes
of
compression
ignition
engines.

25
The
great
fuel
economy
I
just
mentioned
250
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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1
translate
into
much
less
CO2
emitted
per
mile
traveled.

2
CO2,
of
course,
has
been
implicated
as
a
global
warming
or
3
greenhouse
gas.
Such
a
significant
reduction
in
CO2
4
emitted
by
even
a
small
segment
of
the
light­
duty
vehicle
5
sector
could
go
a
long
way
in
helping
us
meet
the
challenge
6
posed
in
the
report.
The
high
combustion
temperatures
and
7
pressures
of
the
compression
engine's
cycle
is
inherently
8
very
low
CO
and
hydrocarbon
exhaust
emissions.
In
9
addition,
there
are
negligible
evaporative
emissions
from
10
diesel
fueled
engines.

11
Furthermore,
the
production
of
diesel
fuel
12
produces
significantly
less
hydrocarbons
than
does
the
13
reduction
of
the
same
amount
of
gasoline.

14
Unfortunately,
on
the
other
hand,
the
high
15
combustion
temperatures
and
pressures
of
the
diesel
cycle,

16
again
responsible
for
the
good
fuel
economy
and
low
CO
17
hydrocarbon
emission
do
tend
to
produce
higher
NOx
18
emissions
and
the
non­
premix
nature
of
the
combustion
of
19
diesel
has
a
tendency
to
produce
particulate
emissions.
In
20
the
heavy­
duty,
on­
highway
arena
where
combustion
ignitions
21
have
been
predominate
for
many
years,
and
where
we've
had
22
significant
very
stringent
emission
standards,
we've
shown
23
the
capability
to
reduce
NOx
70
percent
and
particulate
90
24
percent
of
unregulated
levels.

25
We're
very
proud
of
that
achievement,
but
251
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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1
the
standards
proposed
by
the
staff
today
will
necessitate
2
significant
reductions
in
both
NOx
and
PM
well
beyond
these
3
levels
and
represent
significant
technological
challenge.

4
Cummins
is
committed
to
making
these
further
5
reductions
while
maintaining
the
fuel
economy
advantage
as
6
well
as
the
advantages
in
CO,
hydrocarbons
and
CO2
7
emissions.
We
believe
that
the
most
cost
effective
means
8
to
do
this
will
involve
significant
engine
modifications
9
but
will
also
necessitate
fuel
changes
and
continued
10
invention
and
development
in
the
area
of
lien
11
aftertreatment.

12
Cummins
is
working
with
several
fuel
13
providers
to
understand
the
impacts
of
various
fuel
changes
14
and
has
a
number
of
research
programs
with
aftertreatment
15
manufacturers
and
several
national
research
laboratories.

16
We
believe
that
this
work
will
enable
us
to
meet
the
17
stringent
proposed
standards.

18
Thank
you
for
the
opportunity
to
present
19
these
comments.
And
again,
if
there
are
any
questions,
I
20
would
be
happy
to
answer
them.

21
MR.
CALHOUN:
I've
been
listening
to
your
22
testimony
and
that
of
the
person
preceding
you
very
23
carefully,
and
you
make
­­
not
issue,
but
you
emphasize
the
24
need
for
cleaner
fuel,
and
are
you
saying
that
low
sulfur
25
in
the
California
diesel
fuel
is
going
to
be
necessary?
252
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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5900
1
I
know
you
talked
about
doing
this
2
nationwide
and
having
California
become
a
partner,
because
3
that's
obvious
to
nationwide
technology.
But
where
are
4
you?

5
MR.
JORGENSON:
Yes.
The
­­
as
you've
6
heard,
sulfur
­­
the
reduction
of
sulfur
is
an
enabler.

7
First
of
all,
sulfur
in
the
fuel
become
­­
a
significant
8
proportion
of
sulfur
in
the
fuel
become
sulfate
in
the
9
exhaust.
Sulfate
is
a
particulate
it
in
and
of
itself.
To
10
reduce
sulfur
in
the
fuel
is
to
reduce
sulfur
in
the
11
atmosphere.
But
furthermore,
probably
as
important
or
more
12
important
is
that
the
NOx,
the
lien
NOx
aftertreatment
that
13
is
unique
for
diesel
because
of
the
lien
operating
14
conditions,
is
a
very
important
characteristic.

15
We,
though,
are
concerned
about
the
fuel
16
cost
for
our
customers.
Fuel
cost
is
a
very
important
17
element
of
technology,
of
their
costs,
and
we
want
to
make
18
sure
that
we're
doing
this
in
the
most
cost
effective
19
manner
possible.
So
the
combination
of
engine
changes
20
versus
fuel
changes,
we're
looking
to
see.
We're
trying
to
21
make
that
again
the
most
cost
effective
set
of
changes.

22
MR.
CHARBONEAU:
Also,
once
again,
the
very
23
low
sulfur
is
an
enabler.
Will
we
have
to
have
this
in
24
order
to
achieve
California
objectives?
We
want
to
achieve
25
gas­
like
objectives.
It's
absolutely
mandatory,
but
when
253
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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5900
1
you
do
that,
when
you
have
30
parts
per
million
capability,

2
you
now
have
the
potential
to
take
on
this
challenge.
So
3
it's
inherent.
It's
something
we
have
to
do,
is
something
4
we
want
to
work
with
ARB
Board
members
and
the
EPA
to
5
achieve.

6
CHAIRMAN
DUNLAP:
If
I
might
interject,
I
7
appreciate
the
lack
of
finger­
pointing
on
that
answer,
that
8
it's
an
enabler,
it's
a
partnership
meaning
we're
working
9
together
with
the
fuel
providers
to
make
sure
you
get
the
10
optimal
arrangement,
and
I
appreciate
that.
And
I
think
11
that
kind
of
discussion
has
evolved.
I
heard
some
other
12
things
earlier,
not
to
make
you
bad
guys,
but
there's
been
13
a
whole
lot
of
back
and
forth
finger­
pointing,
so
I
14
appreciate
that
collaterally,
that
attitude.

15
MS.
EDGERTON:
This
is
a
comment
to
Mr.

16
Charboneau
and
Mr.
Jorgenson.
Not
personally,
but
I
want
17
to
be
sure
it's
not
a
personal
comment
because
it's
a
18
comment
about
your
industry,
the
diesel
industry
and
the
19
engine
manufacturers.

20
I
feel
differently
about
your
statements
21
today
than
I
might
have
felt
a
month
ago.
You
say
your
22
industry
has
a
commitment
to
fuel
economy
and
to
engine
23
changes
and
fuel
changes.
That's
just
been
the
problem,

24
hasn't
it.
We've
just
had
a
$
1
billion
settlement
against
25
your
industry
for
setting
your
computers
so
that
­­
254
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
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5900
1
MR.
CHARBONEAU:
Can
I
make
a
comment
here?

2
The
Navistar
has
provided
information
both
to
the
EPA
and
3
to
CARB
that
they
have
not
done
anything
in
operation
in
4
our
engines,
in
our
vehicles
that
goes
over
the
standard.

5
We
provided
that
information
to
the
EPA
and
the
combination
6
of
agreement
we
have
with
both
EPA
and
CARB
says
that
that
7
is
in
fact
the
case.
So
from
the
Navistar
perspective,
we
8
are
achieving
the
standards
and
continue
to
achieve
the
9
standards.

10
We
are
the
only
manufacturer
with
11
unconditional
certificates
by
the
EPA
that
say
we
are
100
12
percent
legal.

13
MS.
EDGERTON:
Correction.
I
don't
know
14
specifically
except
for
what
I
have
read
which
was
that
15
most
of
the
diesel
engine
manufacturers
had
been
involved
16
in
this
effort
to
have
their
engines
testes
meeting
our
17
standards,
and
then
when
they
got
out
on
the
road
in
order
18
to
achieve
greater
fuel
efficiency,
they
programmed
them
so
19
they
would
be
performing
to
a
different
standard.

20
And
that
is
not
impressive.
That's
not
the
21
kind
of
thing
that
makes
me
take
seriously
what
you
all
22
say,
and
it's
not
a
personal
thing.
It's
hard
to
say
to
23
anybody.
You're
standing
here,
and
I
appreciate
your
24
saying
Navistar
didn't
do
it,
but
it's
not
something
that
25
makes
me
want
to
make
it
more
difficult
for
other
255
BARNEY,
UNGERMANN
&
ASSOCIATES
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5900
1
stationary
sources
in
California.
More
of
the
emissions
2
are
going
to
have
to
come
from
them
in
order
to
make
it
3
possible
for
your
company
to
get
special
allowances
so
that
4
diesel
can
continue
along
the
route
you
want.

5
It's
always
a
tradeoff,
and
I
think
what
I
6
would
suggest
is
that
if
you
can
come
up
with
the
7
technologies
that
will
be
competitive
­­
and
this
is
for
8
me
­­
if
you
can
come
up
with
them,
I'm
sure
this
Board
9
will
consider
them
and
we'll
take
that
into
account,
but
I
10
am
not
inclined
at
this
point
to
include
the
TLEV
diesel
11
issue
as
something
I
can
support.

12
I
did
want
to
say
for
the
record
that
a
13
factor
has
been
my
disappointment
in
the
way
that
the
14
recent
issue
­­

15
CHAIRMAN
DUNLAP:
Well,
just
perhaps
a
word
16
of
caution.
Ms.
Edgerton,
if
we
were
to
apply
that
same
17
standard
to
everybody
that's
come
before
us
today,
various
18
points
in
their
interaction
with
us
where
they've
had
a
19
compliance
problem
or
with
the
environmental
community
who
20
may
have
disagreed
with
us
ensued,
or
whatever
it
is,
we
21
would
be
yelling
at
each
other
all
the
time.
So
I
think
22
one
of
the
things
I
learned
perhaps
too
well
is
we
need
to
23
try
to
look
past
some
of
that
and
find
common
ground.

24
Mr.
Kenny
and
I
have
had
this
conversation
25
and
I've
had
it
with
Ms.
Walsh.
We
expect
the
staff
to
256
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enforce
the
rules
that
we
pass
and
be
aggressive
about
it
2
and
show
no
fear
or
favor
and
just
do
the
job.
As
3
policymakers,
we
need
to
at
least
be
able
to
separate.

4
The
issue
before
us
today
and
another
rule
5
problem
or
issue,
or
if
we
can't
do
that,
we're
not
going
6
to
have
I
think
interaction
that
is
going
to
be
meaningful.

7
So
I
appreciate
the
concern
you
have
and
I
share
it
too,

8
but
again
just
want
to
remind
you
and
others,
We
would
be
9
yelling
at
Sam
every
time
he
showed
up.
At
the
same
time
10
we
would
be
giving
him
awards
for
the
EV
I
because
it
was
a
11
remarkable
thing.
Sorry,
Sam.

12
(
Laughter.)

13
CHAIRMAN
DUNLAP:
The
point
is
we
have
to
14
look
past
those
kinds
of
issues
and
there
have
been
times
15
we've
enacted
rules
and
missed
the
mark
and
felt
strongly
16
about
it,
but
there
needs
to
be
a
civil
exchange.
My
point
17
is
I
tend
to
let
that
go
under
my
bridge
a
little
more.

18
Okay.
Thank
you,
gentlemen.

19
I
probably
offended
everyone
in
the
room
20
with
that
comment.
It
was
not
my
intention.

21
MS.
EDGERTON:
Anyone
you
didn't
offend,
I
22
offended.

23
CHAIRMAN
DUNLAP:
Two
remaining
witnesses,

24
both
from
the
environmental
community.
Tim
Carmichael
and
25
Joe,
I
guess
you're
going
to
bat
clean
up
today.
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Is
there
anyone
else
who
has
not
signed
up
2
to
testify
that
desires
to?
All
right.
Tim,
welcome.

3
Thanks
for
your
patience.

4
MR.
CARMICHAEL:
Thank
you,
Chairman
Dunlap.

5
Tim
Carmichael
for
Coalition
for
Clean
Air.

6
I
could
start
on
just
a
lighter
comment
real
7
quickly.
There
have
been
changes
at
the
coalition
recently
8
and
changes
here,
dynamic
times.
I
wanted
to
let
you
know
9
that
one
of
my
recent
executive
decisions
was
to
create
a
10
new
division
at
the
coalition
dedicated
exclusively
to
11
working
on
reducing
emissions
in
the
restaurant
industry.

12
(
Laughter.)

13
CHAIRMAN
DUNLAP:
I
certainly
have
a
lot
of
14
well
wishers.

15
Some
of
my
colleagues
indicated
they're
16
going
to
be
looking
into
that
issue
too.
Thank
you
Tim.

17
MR.
CARMICHAEL:
With
that
said,
I
do
have
18
serious
comments.

19
I
would
like
to
cover
just
a
couple
of
20
points
covered
earlier
today,
step
back
from
the
details.

21
I
have
one
detail
that
I
want
to
focus
on,
but
just
take
a
22
step
back
and
look
at
the
fundamentals
of
today's
decision
23
from
the
environmental
community's
perspective,
from
my
24
perspective.

25
There
are
three
challenges,
three
tests
this
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proposal
needs
to
meet
for
your
approval.
One,
are
the
2
emission
reductions
necessary.
I
don't
think
there's
3
anybody
in
the
room
that's
going
to
debate
that
issue.

4
Here
in
southern
California,
throughout
this
state,
we've
5
got
a
long
ways
to
go
to
get
from
where
we
are
with
regard
6
to
clean
air.
Clearly
the
emission
reductions
are
7
necessary.

8
Two,
is
it
technically
feasible?
There
was
9
an
exchange
this
morning
which
I
found
quite
interesting
10
between
the
auto
industry
and
your
staff
and
there
was
a
11
challenge
almost.
Is
the
ARB
staff
as
credible
as
the
12
automobile
industry.
From
my
perspective,
the
automobile
13
industry
has
a
bit
of
a
checkered
past,
and
saying
that
14
standards
challenges
can't
be
met
­­
and
there
are
numerous
15
examples
throughout
the
70s,
80s
and
even
into
the
90s.

16
If
I
was
going
to
pick
a
fight
with
the
17
staff
or
be
critical
of
them,
I
would
suggest
that
their
18
flaw
is
being
too
conservative.
They
don't
push
hard
19
enough.

20
If
they
come
forward
and
say
something
can
21
be
done,
they
have
checked
it
and
checked
it
and
checked
22
it,
I
think
there's
one
thing
we
can
rely
on,
is
that
if
23
the
staff
says
it
can
be
done,
it
can
be
done.

24
And
the
third
test
that
I
think
is
critical
25
in
today's
decision
process,
is
it
cost
effective.
You
259
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heard
not
only
your
own
staff,
but
other
representatives
2
from
air
agencies.
Other
individuals
explained
how
3
inexpensive
these
reductions
are.
I
don't
want
to
minimize
4
the
fact
that
a
lot
of
money
is
going
to
be
spent
to
5
achieve
these
standards,
but
relative
to
other
control
6
programs
that
we
have
under
way
and
will
soon
be
adopted,

7
these
are
inexpensive
and
absolutely
have
to
be
adopted,

8
and
we
have
to
go
after
these
emission
reductions
where
we
9
have
found
them
and
know
they
can
be
achieved.

10
I
do
want
to
address
one
of
the
issues
11
specifically
that's
in
the
proposal
that
we
have
real
12
problems
with,
and
I
didn't
have
documents
prepared
in
13
advance
and
would
just
like
to
have
these
in
front
of
you.
14
Just
for
clarity's
sake,
this
is
from
the
document
that
was
15
on
the
back
table
today.
It's
the
staff's
suggested
16
changes,
and
at
page
2,
the
table
that
lists
the
standard
17
and
I've
highlighted
­­
I
know
this
issue
has
been
raised
18
already,
but
I
want
the
Board
to
know
exactly
where
we
are
19
on
this
issue
and
see
the
numbers
that
have
created
such
a
20
problem
for
the
environmental
community.

21
Specifically,
the
numbers
for
the
TLEV
22
standard
for
oxides
of
nitrogen
and
particulates
are
23
clearly
much
higher,
much
weaker
than
the
standards
24
proposed
for
LEV.
The
only
reason
those
standards
are
25
higher
is
to
accommodate
a
dirtier
fuel.
This
agency
for
a
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long
time
has
professed
a
principal
of
fuel
neutrality,
and
2
yet
here
we
are
proposing
standards
to
take
effect
five
3
years
down
the
road
that
clearly
make
a
distinction
between
4
the
standard
and
a
dirtier
fuel
diesel.
We
have
a
real
5
problem
with
that
and
ask
you
to
consider
seriously
6
removing
this
piece
of
the
proposal.
It
is
not
necessary.

7
This
standard
is
not
necessary
for
gasoline
8
vehicles.
It
only
exists
to
accommodate
diesel
vehicles
9
and
that
is
fundamentally
contrary
to
the
principals
10
professed
by
this
agency,
so
we
urge
you
to
pull
this
piece
11
of
the
proposal.

12
I
won't
belabor
the
other
points
that
have
13
been
raised
on
warranty
issues.
Strongly
support
for
the
14
strengthening
the
warranties.

15
We
have
the
desire
to
continue
to
examine
16
the
Premiere
catalyst
and
make
sure
that
it
really
is
17
achieving
reductions
before
we
give
credit
for
it.

18
We
have
concerns
about
the
relaxation
of
the
19
CAP
2000.
The
SULEV
issue
has
been
raised
for
many
months
20
by
organizations,
but
fundamentally
this
is,
I
think,
the
21
biggest
issue
and
the
biggest
problem
with
this
proposal.

22
There
are
a
lot
of
good
things
in
this
23
proposal
and
we
are
here
to
support
the
proposal
and
want
24
to
see
it
adopted,
but
it
sets
a
double
standard
and
it's
a
25
double
standard
that
shouldn't
be
set
and
we
urge
you
to
261
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pull
this
component
and
not
accommodate
a
dirtier
fuel.

2
Thank
you
very
much.

3
CHAIRMAN
DUNLAP:
Tim,
was
there
any
­­
the
4
whole
idea
about
the
work
trucks
and
loads,
and
you
5
listened
to
all
that
today.
Did
any
of
that
testimony,

6
commentary
move
you
at
all?
I'm
talking
about
from
a
7
practical
standpoint
because
you've
got
to
understand.

8
Sitting
up
here
­­
and
you
and
others
from
the
community
9
may
be
here
one
day.
That's
one
of
the
things
we're
10
charged
with
doing,
trying
to
find
that
balance.
Did
that
11
resonate
with
you
in
any
way?

12
MR.
CARMICHAEL:
I
understand
why
it's
part
13
of
the
proposal,
but
I
disagree
with
the
reason
for
14
including
it.
I
think
the
staff
has
done
an
excellent
job
15
of
demonstrating
the
fact
that
all
vehicles
under
8500
16
pounds
can
meet
the
same
standards
in
2004,
and
we
think
17
that
should
be
the
driving
principal.

18
CHAIRMAN
DUNLAP:
Okay.
All
right.
19
Mr.
Caves.

20
MR.
CAVES:
I'm
not
quite
sure
how
I
ended
21
up
last.
I'm
going
to
try
and
be
very
brief.
I
know
you
22
want
to
get
out
of
here
as
much
as
I
do.
I
did
want
to
23
stand
up
here,
Mr.
Chairman
­­

24
My
name
is
Joe
Caves
representing
the
Union
25
of
Concerned
Scientists.
I
did
want
an
opportunity
to
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commend
this
Board
and
particularly
you,
Mr.
Chairman,
for
2
your
leadership,
particularly
this
year
you
have
set
3
yourselves
a
very
challenging
task
and
a
very
aggressive
4
schedule
of
trying
to
adopt
regulations
to
address
a
number
5
of
the
really
critical,
outstanding
issues,
and
I
think
6
this
is
well
within
the
tradition
of
the
leadership
of
CARB
7
and
I
think
CARB's
distributed
leadership
has
been
8
demonstrated
by
being
here
today.

9
The
reason
we
can
have
these
debates
is
10
because
in
1990
that
Board
was
willing
to
take
a
very
bold,

11
even
historic
move
and
try
to
establish
a
new
standard
to
12
push
automotive
technology
way
beyond
where
anyone
thought
13
it
could
be.
They
were
willing
to
take
that
chance
based
14
on
really
three
things
­­
a
technical
staff
that
was
able
15
to
identify
the
possibilities
and
develop
a
program
of
16
periodic
review
and
lead
time
that
enabled
them
to
identify
17
a
standard,
to
set
a
goal,
and
then
to
follow
it
up
along
a
18
reasonable
path
that
made
sure
that
their
efforts
were
19
going
to
be
successful.
Everything
we're
talking
about
20
today
is
built
on
that
foundation.
21
I
think
what
you
have
before
you
is
the
22
chance
to
make
the
next
step,
to
set
the
new
foundation
for
23
the
future
Boards
to
address
the
air
quality
needs
of
the
24
state.
We
want
to
urge
you
to
take
a
very
close
look
at
25
that
challenge,
to
think
about
what
the
problems
are
going
263
BARNEY,
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to
be
for
the
next
Boards.

2
They're
going
to
have
to
deal
with
the
3
additional
emissions
reductions
that
are
necessary
to
close
4
the
black
box,
but
even
more
than
that,
they
are
going
to
5
face
a
much
greater
challenge
of
dealing
with
new
national
6
air
quality
standards
that
are
setting
very,
very
difficult
7
challenges
on
ozone
and
PM2.5
that
are
going
to
press
in
8
every
one
of
our
sectors,
press
us
to
the
limits.

9
We
need
to
find
every
emission
reduction
we
10
can,
and
the
decisions
you
make
today
are
in
many
ways
11
going
to
determine
whether
they
are
going
to
be
able
to
be
12
successful
to
meet
the
air
quality
needs
for
California's
13
future.

14
The
second
thing
they're
going
to
have
to
15
deal
with
is
they're
going
to
have
to
deal
with
the
problem
16
of
air
toxics.
This
Board
took
a
very
courageous
action
in
17
designating
diesel
particulate
as
an
air
toxic.
Because
18
our
entire
economy
is
so
dependent
upon
diesel
today,
the
19
challenge
for
the
next
Board
is
going
to
be
tremendous
to
20
try
to
adopt
control
measures
to
help
reduce
the
public
21
health
threat
in
this
very
serious
problem
without
harming
22
our
economy.
This
is
not
going
to
be
an
easy
task.

23
You
have
set
a
very
high
bar
for
the
next
24
Board
they're
going
to
have
to
meet.
So
we
would
ask
25
you
­­
and
my
colleagues
have
expressed
we're
supportive
of
264
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the
plan
here,
what
the
staff
has
set
out,
but
we
have
2
drawn
a
couple
of
exceptions,
a
couple
of
points
that
I
3
want
to
hit
very
lightly.

4
Now,
we've
been
talking
about
them
for
a
5
long
time,
but
please
keep
in
mind
that
because
you're
6
setting
the
next
foundation
you
have
to
look
at
this
plan
7
in
that
context.
Think
back
to
what
happened
in
1990.
One
8
of
the
biggest
errors,
if
you
will,
omissions
in
that
plan
9
was
not
foreseeing
that
sport
utility
vehicles
would
become
10
such
a
significant
component
of
our
inventory.
It's
easy
11
for
us
to
look
back
on
it
now.
At
the
time
they
didn't
12
have
any
way
of
anticipating,
and
yet
the
whole
reason
13
we're
here,
the
whole
reason
we're
trying
to
address
these
14
issues
is
because
they
have
become
such
a
large
part
of
the
15
inventory.
So
we
would
ask
you
to
take
a
look
at
this
16
proposal
and
just
keep
in
mind
those
factors.

17
Please
reject
the
AAMA
proposal.
We
need
18
those
tons.
Not
only
do
we
need
them
now,
but
we
19
desperately
need
them
for
the
future.

20
Two,
with
respect
to
the
TLEV
proposal,
I
21
just
want
to
reiterate
what
my
colleagues
have
said.
Our
22
fear
is
that
this
will
become
a
gamble
that
goes
against
23
us,
this
will
become
a
loophole
in
this
plan
that
future
24
Boards
will
look
back
on
and
say
this
was
a
mistake.

25
You've
set
the
challenge
for
future
Boards
265
BARNEY,
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ASSOCIATES
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1
to
go
up
here
and
address
diesel
as
a
toxic
air
2
contaminant.
I
just
don't
think
we
want
to
go
down
this
3
path
now
of
encouraging
the
introduction
of
a
larger
number
4
of
diesels
into
another
sector.
I
think
this
is
a
mistake.

5
Finally
I
want
to
mention
we're
concerned
6
about
a
final
mistake,
and
that
is
providing
ZEV
credit
for
7
SULEVs.
Mr.
Chairman,
you
raised
a
very
legitimate
issue
8
of
fuel
neutrality.
If
something
provides
the
same
9
emission
benefits,
shouldn't
we
give
it
the
same
credit?

10
The
ZEV
mandate
has
been
a
separate
component
in
the
LEV
11
program
for
a
good
reason.
Its
purpose
was
to
give
this
12
Board
and
future
Boards
other
alternatives,
alternatives
13
that
would
otherwise
not
be
available,
and
I
just
contend
14
future
Boards
will
need
that
even
more
with
increased
VMT
15
and
increased
population
growth.
One
thing
we're
going
to
16
need
are
true
zero
emission
alternatives
in
transportation.

17
While
you
may
not
need
it
immediately,
you
may
be
able
to
18
make
the
rationale
that
using
gasoline
powered
vehicles,

19
even
though
there
are
upstream
emissions,
even
though
you
20
have
potential
for
deterioration,
even
though
some
of
them
21
when
those
warranties
are
over
may
be
gross
polluters
and
22
contributing
to
the
overrule
inventory.
Even
though
we
may
23
be
able
to
deal
with
that
now,
in
the
future
we
will
need
24
those
alternatives.

25
Our
concern
is
giving
SULEV's
credit
moves
266
BARNEY,
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ASSOCIATES
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1
you
down
a
slippery
slope
that
can
undermine
the
2
technology­
forcing
aspects
in
a
way
that
we
will
truly
3
regret
in
10
or
15
years.

4
With
that
I
would
just
say,
Mr.
Chairman,

5
best
wishes.
I
want
to
thank
all
the
Board
members
for
the
6
fine
work
this
year.
I
would
urge
you
to
make
the
same
7
kind
of
courageous
action
today
the
Board
took
in
1990
by
8
passing
this
program.
Thank
you.

9
CHAIRMAN
DUNLAP:
Thank
you.
Okay.
That
10
will
conclude
the
public
testimony
on
this
Board
item.

11
For
the
record,
I
would
like
to
have
staff
12
summarize
the
4500
letters
in
all
their
diversity
that
the
13
Board
has
received.

14
MR.
CARLSON:
I
raised
my
hand.
I
think
I
15
can
do
it
fairly
expeditiously.

16
Mr.
Schoning
I
think
summarized
probably
­­

17
MS.
SHELBY:
Please
identify
yourself
for
18
the
record.

19
MR.
CARLSON:
Bob
Carlson.
As
I
said,

20
Mr.
Schoning
summarized
most
of
the
letters
in
his
comments
21
this
morning,
and
I
think
that
the
ones
that
I
have
here
22
are
subsets
of
those
letters.

23
I
have
letters
from
the
Olive
Growers
24
Council,
Stock
and
District
Kidney
Bean,
California
25
Business
Properties
Association,
California
Association
of
267
BARNEY,
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1
Nurserymen,
Connection
Catering
and
California
Poultry
2
Industry
Federation,
California
Building
Industry
3
Association,
and
all
of
them
expressed
the
same
concern
4
which
is
related
to
the
medium­
duty
part
of
the
proposal.

5
And
they're
concerned
about
work
trucks
and
I
think
the
6
Board
has
had
ample
dialogue
on
that.
Not
much
more
needs
7
to
be
said.

8
Also
we
have
a
couple
of
letters
from
9
Bicycle
Coalition
and
California
Humane
Society,
supporting
10
the
option
of
the
proposed
amendments.

11
I
have
a
couple
of
other
quick
12
administrative
details
here.
On
the
15­
day
changes
that
13
were
put
on
the
back
table
this
morning,
on
page
6
there
is
14
a
minor
change
which
we
need
to
make
at
the
bottom.
It's
15
section
B24,
it's
­­
first,
second
third
line
strike
out
16
the
first
"
4",
2004
through,
and
put
in
"
prior
to
the",
and
17
"
model
years"
becomes
"
year",
and
essentially
then
there's
18
language
at
the
end,
and
basically
all
these
changes
do
is
19
change
it
from
a
three­
year
fixed
period
of
the
­­
for
the
20
in­
use
compliance
allowance
of
1.75
on
down,
through
a
21
rolling
three
years.
This
starts
when
an
engine
family
is
22
certified,
so
in
the
time
that
engine
family
is
certified
23
it
has
three
years
whether
it
be
in
the
first,
second
or
24
third
year.

25
CHAIRMAN
DUNLAP:
Can
you
say
the
page
268
BARNEY,
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ASSOCIATES
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1
again?

2
MR.
CARLSON:
I
didn't
finish
reading
the
3
language,
but
that's
what
the
language
does
is
changes
a
4
static
three­
year
to
a
running
three­
year.
It's
page
6
of
5
the
15­
day
changes
at
the
bottom.

6
CHAIRMAN
DUNLAP:
Your
job
is
to
comfort
us,

7
not
confuse
us.

8
MS.
SHELBY:
I
think
the
changes
he
is
9
announcing
are
for
those
in
the
audience
that
have
the
10
first
version
and
you
have
the
most
recent
version.

11
MR.
CARLSON:
Does
your
recent
version
have
12
handwriting
on
the
bottom?

13
CHAIRMAN
DUNLAP:
Whatever
he's
talking
14
about,
we
have
copies
for
the
audience.
Does
the
audience
15
have
copies
of
the
material?
Where
do
they
get
it
if
they
16
don't
have
it?

17
MS.
SHELBY:
It's
at
the
back
table,
but
18
there
are
people
who
picked
ones
up
earlier.

19
CHAIRMAN
DUNLAP:
Three
people
with
the
20
different
rows,
have
them
walk
back
so
people.

21
MR.
SCHONING:
Chairman,
this
is
the
same
22
language
that
was
released
this
morning
on
the
back
table
23
on
the
15­
day
changes,
so
what
Bob
is
doing
is
identifying
24
one
change
orally
to
the
language
that
was
put
on
the
back
25
table
and
one
of
the
things
­­
269
BARNEY,
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ASSOCIATES
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1
CHAIRMAN
DUNLAP:
Does
everybody
in
the
2
audience
know
what
they're
talking
about?
If
you
don't
3
know,
raise
your
hand.
Okay.
Hi.
Counsel
will
come
find
4
and
you
explain
it.
This
is
serious.
We've
got
200
people
5
or
whatever
it
is
that
stayed
the
whole
time
and
we
want
6
you
to
know
what
we're
talking
about.
Mike,
handle
this.

7
MR.
SCHONING:
Very
simply
what
it
does
is
8
treats
the
in­
use
compliance
stays
in
for
EVAP
the
exactly
9
the
same
as
we
were
doing
it
for
costs.

10
CHAIRMAN
DUNLAP:
That's
fine.
I
want
them
11
to
have
the
exact
language.
Okay.

12
MR.
CARLSON:
One
more.
Hopefully
this
will
13
be
easier.
This
is
in
the
proposed
resolution
and
it's
on
14
page
number
7
in
the
"
whereas".
You
see
"
whereas
the
Board
15
further
finds"?
That
first,
second,
third,
the
projected
16
costs
to
comply
with
the
amendments
provided
here
and
are
17
expected
to
range
from
$
100
to
$
200
per
vehicle
with
an
18
average
of
about
$
100
and
that's
it.
$
100
to
$
200
and
then
19
instead
of
$
200
­­

20
MR.
CALHOUN:
That's
as
cockeyed
as
it
was
21
before.
If
the
range
is
$
100
to
$
200,
the
average
is
going
22
to
be
somewhere
between
­­

23
MR.
CACKETTE:
$
107.

24
DR.
FRIEDMAN:
Okay.

25
CHAIRMAN
DUNLAP:
Say
it
so
everyone
hears
270
BARNEY,
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&
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1
it.

2
MR.
CACKETTE:
We
did
rounding
there.
The
3
lower
numbers
are
$
40­
some
I
think,
but
I
understand
the
4
confusion.

5
CHAIRMAN
DUNLAP:
All
right.
So
we've
6
summarized
the
written
comments.
I'm
going
to
officially
7
close
the
record
now.
We'll
come
back.

8
The
record
will
be
reopened
when
15­
day
9
notice
of
public
availability
is
issued.
Written
and
oral
10
comments
received
after
this
hearing
date
before
the
15­
day
11
notice
is
issued
will
not
be
accepted
as
part
of
the
12
official
record
on
this
agenda
either.
When
the
record
is
13
reopened
for
15­
day
comment
period,
the
public
may
submit
14
written
comments
on
the
proposed
changes
which
may
submit
15
written
comments
on
the
proposed
changes
which
will
be
16
considered
and
responded
to
in
the
final
statement
of
17
reasons
for
regulation.

18
We're
going
to
go
through
ex
parte
19
communications.
Just
a
reminder
to
the
Board
members
of
20
our
policy
concerning
ex
parte,
how
we
may
communicate
off
21
the
record
with
outside
persons
regarding
rulemaking,
we
22
must
disclose
the
names
of
the
contacts
and
the
nature
of
23
contacts
on
the
record.
This
requirement
applies
24
specifically
to
communications
which
take
place
after
the
25
notice
of
the
Board
hearing
has
been
published.
271
BARNEY,
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1
Are
there
any
communications
which
we
need
2
to
disclose?
We'll
start
with
Supervisor
Roberts.

3
SUPERVISOR
ROBERTS:
I
haven't
had
any.

4
CHAIRMAN
DUNLAP:
Supervisor
Patrick.

5
SUPERVISOR
PATRICK:
Yes.
I
had
three
6
meetings
one
on
October
8th
with
Pat
Charboneau,
Brian
7
Whalen,
Tom
Trueblood
and
Warren
Slodowski
of
Navistar;
on
8
October
14th
with
Reginald
Modelin
of
Chrysler
and
Richard
9
Bell
of
Ford;
and
on
October
22nd
with
Joe
Caves
of
the
10
Union
of
Concerned
Scientists,
Roland
Hwang,
Union
of
11
Concerned
Scientists
and
Robert
Lucas
of
CCEEB,
and
the
12
information
that
we
discussed
is
essentially
what's
part
of
13
the
public
record
today.

14
CHAIRMAN
DUNLAP:
Thank
you.
Dr.
Friedman.

15
DR.
FRIEDMAN:
I
had
a
brief
conversation
16
this
morning
with
Mr.
Rosenberg
in
which
he
presented
some
17
of
the
same
information
that
Mr.
Poles
presented
to
us
this
18
afternoon.

19
CHAIRMAN
DUNLAP:
Very
good.
Mr.
Calhoun.

20
MR.
CALHOUN:
I
had
conversation
with
21
representatives
from
Navistar
on
October
18th,
Pat
22
Charboneau,
Mr.
Slodowski,
and
their
testimony,
their
23
discussion
or
our
discussion
was
essentially
as
to
their
24
testimony
here
today.

25
CHAIRMAN
DUNLAP:
Okay.
272
BARNEY,
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1
MR.
CALHOUN:
On
October
the
13th
I
had
a
2
meeting
with
Sam
Leonard
and
his
testimony
concerned
the
3
proposal.
October
13th
I
met
with
­­
I
had
a
conversation
4
with
Mr.
Steve
Douglas
relative
to
the
vehicles,
that
heavy
5
duty
category
ordered
with
the
towing
package.
October
the
6
25th
I
talked
to
Mr.
Sam
Leonard
again
about
the
standards,

7
and
Roland
Hwang
on
the
4th,
which
was
yesterday,
and
8
Mr.
Brown,
Kelly
Brown
from
Forth
Motor
Company.

9
CHAIRMAN
DUNLAP:
Okay.
On
the
13th
of
10
October
I
spoke
with
Jed
Mandel
and
Bob
Johannsen
of
EMA;

11
Thomas
Trueblood,
Manager
Public
Affairs
International;
Don
12
Ustien,
Group
VP
General
Manager,
Engine
and
Foundry
13
Division;
Pat
Charboneau,
Vice
President,
Engine
14
Engineering;
Warren
Slodowski,
Manager
Environmental
Staff;

15
Brian
Whalen,
VP
Public
Affairs
Navistar.
That's
the
13th.

16
On
the
16th,
Alan
Zamberg,
California
17
Chamber
of
Commerce;
19th
Phil
Rosenberg
and
Bob
Teeter
of
18
Ford.
On
the
2nd
of
November
I
spoke
with
Melanie
Wagner
19
of
Ford,
Kelly
Brown
and
Sam
Leonard,
also
Bob
Teeter
via
20
conference
call;
on
the
2nd
of
November
Chris
Walker,
Tom
21
Riley
and
John
Valencia;
on
the
3rd,
Ford
Motor
Company,

22
Melanie
Wagner,
Kelly
Brown
and
Sam
Leonard
from
GM
as
well
23
as
Peter
Welch
from
the
California
Motor
Car
Dealers
24
Association,
and
I
also
spoke
with
Alan
Zamberg
of
the
25
Chamber
and
that
is
it.
All
consistent
with
the
testimony
273
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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5900
1
and
commentary
today.

2
MS.
RIORDAN:
Mr.
Chairman,
those
that
I
met
3
were
also
are
consistent
with
the
testimony
that
was
4
provided
today.

5
On
the
14th
of
October
I
met
with
Warren
6
Slodowski,
Brian
Whalen
and
Tom
Trueblood
from
Navistar;
on
7
October
13th
I
met
with
Steven
Douglas,
AAMA,
Mr.
Modelin
8
from
Chrysler,
Mr.
McCann
from
General
Motors,
Mr.
Leonard
9
from
General
Motors,
Mr.
Bell
from
Ford.

10
I
met
very
briefly
this
morning
with
11
Mr.
Rosenberg,
and
then
on
October
26th
I
met
with
Mr.

12
Hwang
from
the
Union
of
Concerned
Scientists
and
Mr.
Tim
13
Carmichael
from
the
Coalition
for
Clean
Air.

14
CHAIRMAN
DUNLAP:
Mr.
Parnell.

15
MR.
PARNELL:
Mr.
Chairman,
I
met
with
16
several,
and
each
of
those
conferences
were
via
telephone
17
conference
with
the
exception
of
one.
The
contents
of
18
those
conversation
was
consistent
with
the
testimony
that
19
we
heard
today.

20
I've
met
with
Sam
Leonard
from
GM;
Kelly
21
Brown,
Ford;
Gene
Kelly
and
Roland
Hwang
of
the
Union
of
22
Concerned
Scientists;
Jed
Mandel,
Engine
Manufacturers
23
Association;
Navistar,
Pat
Charboneau,
and
Bill
Rosenberg
24
personally
this
morning.
We
talked
about
the
catalyst
25
issue.
274
BARNEY,
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ASSOCIATES
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1
CHAIRMAN
DUNLAP:
Thank
you.
Ms.
Edgerton.

2
MS.
EDGERTON:
I
met
Barbara
Wood­
Davis
and
3
Sam
Leonard
and
Steve
Douglas,
and
I
think
it
was
the
13th
4
of
October
that
I
met
with
Mr.
Leonard,
Mr.
Douglas,

5
Mr.
Bell,
that
same
group;
October
22nd
I
met
with
Roland
6
Hwang,
Joe
Caves
and
Bob
Lucas
from
CCEEB.
Sally
was
7
there.
October
13th
I
met
with
Navistar
representatives
8
Brian
Whalen,
Warren
Sodowski,
Tom
Trueblood,
Patrick
9
Charboneau,
and
outside
today
I
talked
a
little
bit
more
10
with
Mr.
Leonard
and
Mr.
Kitz.

11
CHAIRMAN
DUNLAP:
Mrs.
Rakow.

12
MRS.
RAKOW:
Yes.
On
October
14th
I
met
13
with
Warren
Sodowski,
Thomas
Trueblood
and
Brian
Whalen
14
from
Navistar;
on
the
8th
of
October
I
met
with
Steve
15
Douglas,
AAMA,
Kelly
Brown
from
Ford,
and
Charlie
Kitz
from
16
Chrysler.
On
the
22nd
of
October
I
met
with
the
Union
of
17
Concerned
Scientists,
Roland
Hwang
and
Joseph
Caves,
and
18
the
CCEEB
representative
Bob
Lucas.
On
the
20th
I
had
a
19
telephone
conversation
with
Christopher
Walker,
California
20
Service
Station
and
Auto
Repair
Association.
On
the
30th
I
21
met
with
Dennis
Dakota,
Executive
Director
of
the
22
California
Service
Station
and
Automotive
Repair
23
Association,
and
today
I
had
a
brief
conversation
with
24
Christopher
Walker
during
the
meeting,
and
this
morning
a
25
brief
conversation
with
Mr.
Rosenberg,
all
of
which
were
275
BARNEY,
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1
consistent
with
what
we've
heard
today.

2
CHAIRMAN
DUNLAP:
Mark
DeSaulnier.

3
SUPERVISOR
DE
SAULNIER:
Mr.
Chairman,
I
was
4
visited
by
Kelly
M.
Brown
of
Ford
Motor
Company,
Charlie
5
Kitz
of
Chrysler
and
Steve
Douglas
of
the
AAMA
on
October
6
8th,
and
also
I
had
a
brief
phone
conversation
with
Don
7
Slolem
representing
the
Citizens
for
Automotive
Choice.
If
8
I
didn't
say
it,
November
3rd.

9
All
of
the
communications
were
consistent
10
with
the
testimony
today
and
a
letter
submitted
by
Citizens
11
for
Automotive
Choice.

12
MS.
EDGERTON:
I
forgot
one
person.
I
13
received
a
call
from
Peter
Hunter
from
Sempra
indicating
to
14
me
that
he
thought
that
the
Engelhard
technology
was
15
excellent.
He
was
very
glad
it
was
included
in
the
­­

16
CHAIRMAN
DUNLAP:
Do
you
remember
the
date?

17
MS.
EDGERTON:
The
day
before
yesterday.

18
CHAIRMAN
DUNLAP:
It
would
be
the
2nd.

19
MS.
EDGERTON:
November
2nd.

20
CHAIRMAN
DUNLAP:
Mr.
Calhoun,
I
also
was
21
remiss
and
was
reached
by
Joseph
Caves
and
Roland
Hwang
in
22
late
October.
My
apologies
for
not
remembering
that
date.

23
MR.
CALHOUN:
I
was
only
brief.
I
had
a
24
discussion
with
Roland
Hwang
on
November
the
2nd,
and
that
25
testimony
was
consistent
with
what
he
presented
today.
276
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1
CHAIRMAN
DUNLAP:
All
right.
Did
we
capture
2
it?
All
right.
Very
good.

3
Now
for
the
moment
we've
all
been
waiting
4
for.
I
want
to
try
to
do
this
in
a
manner
that
is
5
recognizable
to
the
group
here.
Mrs.
Rakow,
I'm
going
to
6
ask
you
to
talk
about
the
Service
Station
group's
concerns
7
and
how
that
was
accommodated
in
the
resolution.
That's
an
8
easy
one.

9
MRS.
RAKOW:
Yes.

10
CHAIRMAN
DUNLAP:
That
is
an
easy
one.

11
MRS.
RAKOW:
That
is
an
easy
one
because
12
everybody
is
in
agreement
that
there
should
be
some
13
accommodation
to
look
into
their
concerns,
and
I
thought
14
that
we
had
to
look,
to
see
what
we
would
do
to
provide
15
some
flexibility
and
options
to
the
independent
automobile
16
owner
in
this
state.
We
wish
to
do
something
about
the
17
150,000­
mile
warranty
that
wasn't
directly
with
the
18
dealership,
and
we
don't
know
really
whether
there
is
or
is
19
not
a
real
adverse
effect
on
the
independent
repair
20
station.

21
So
the
language
that
both
the
22
representatives
of
the
different
independent
repair
23
associations,
the
staff
and
our
legal
office
has
agreed
to
24
is
the
first
draft
on
the
last
page,
page
8,
which
says,

25
"
That
be
it
further
resolved
that
the
ARB
staff
shall
work
277
BARNEY,
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1
with
representatives
of
the
independent
automobile
service
2
and
aftermarket
parts
industry
and
other
interested
parties
3
to
assess
the
degree
to
which
this
industry
may
be
4
adversely
impacted
by
the
extended
warranties
and
to
report
5
back
to
the
Board
within
18
months
with
its
findings
and
6
proposal,
and
if
appropriate
to
mitigate
any
adverse
7
impacts
so
the
independent
automotive
service
and
8
aftermarket
parts
industry
may
continue
to
contribute
to
9
the
State's
efforts
to
reduce
smog
and
to
continue
to
10
provide
our
state's
26
million
vehicle
owners
with
a
11
competitive
automotive
repair
marketplace
for
their
service
12
related
needs,"
so
that
is
an
amendment
that
I
strongly
13
suggest.

14
CHAIRMAN
DUNLAP:
All
right.
Does
this
15
Board
seem
comfortable
with
that?
I
am.
One
of
the
things
16
I'm
going
to
bring
up
and
ask
Mr.
Kenny
or
the
lawyers,
Sam
17
and
Kelly
in
particular
made
some
very
good
points.
One
of
18
them
was
about
­­
I
offered
it
up
as
a
response
to
some
of
19
that
review.
Tom,
you
guys
have
become
masters
of
doing
20
technology
reviews.
Is
that
built
into
this
package,
this
21
resolution?

22
MR.
CACKETTE:
Yes,
it
is.

23
CHAIRMAN
DUNLAP:
Okay.

24
MR.
SCHONING:
The
last
"
whereas"
on
page
7.

25
CHAIRMAN
DUNLAP:
Okay.
Now,
what
we're
278
BARNEY,
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1
going
to
do
­­
when
will
we
do
this,
Tom?
When
will
staff
2
come
back
and
do
the
collaborative
review?

3
MR.
CACKETTE:
Well,
we
promised
to
do
that
4
review
biannually
or
we
can
come
back
at
any
frequency
you
5
want,
but
that
would
be
roughly
the
beginning
of
the
year
6
2001.

7
CHAIRMAN
DUNLAP:
Okay.
Which
gives
them
8
three
more
years,
two
and
a
half
more
years;
correct?

9
MR.
CACKETTE:
Right.

10
CHAIRMAN
DUNLAP:
Is
there
any
hesitation
­­

11
I'm
talking
technical
staff
now
­­
if
you
guys
find
the
12
progress
hasn't
been
made,
that
it
truly
is
taking
more
13
time,
is
there
anybody
here
that
has
any
hesitation
about
14
being
truthful
to
the
Board
about
that
and
telling
them
we
15
need
to
make
changes?
Is
there
anybody
here
that
feels
16
they
can't
do
that?

17
Okay.
That's
a
very
important
thing.
It's
18
important
to
the
Board.
Not
just
the
Board
itself,
but
the
19
staff
to
have
credibility.
All
right?
So
I'm
seeing
heads
20
bobbing
and
people
are
willing
to
do
that
in
good
21
conscience.

22
MR.
KENNY:
Mr.
Chairman,
I
think
what
23
you're
seeing
from
the
staff
is
essentially
a
willingness
24
to
always
be
very
truthful
and
we'll
be
very
factual.

25
CHAIRMAN
DUNLAP:
Okay.
So
we
get
the
279
BARNEY,
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&
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1
two­
year
review
or
two
years
from
now.
All
right.

2
There's
been
some
concerns
about
­­
Joe
had
3
an
issue
or
two.
Take
the
easy
one.

4
MR.
CALHOUN:
Mr.
Chairman
of
the
Board
and
5
the
audience,
I
have
discussed
the
concern
that
I
have
6
relative
to
the
difference
between
the
ozone
levels
during
7
the
week,
weekdays
and
weekends,
and
I've
talked
to
8
Dr.
Holmes,
I've
talked
to
Mr.
Kent,
I've
talked
to
Mike
9
Kenny,
and
I
still
­­
recently
I
received
several
papers
10
regarding
this,
so
I've
suggested
that
there
be
a
meeting
11
of
the
stakeholders
and
an
investigation.
I
don't
want
to
12
just
see
a
written
memo
that's
disposing
of
the
issue.

13
I
would
like
to
see
us
get
together
with
the
14
other
stakeholders
and
decide
if
we
are
headed
down
the
15
right
road.
I
recognize
that
we
need
NOx
control
for
16
particulates
and
we
need
NOx
control
for
ozone
because
of
17
the
end
game
somewhere.
I'm
not
sure
what
that
is
going
to
18
look
like,
and
I
guess
I'm
suggesting
that
we,
with
the
19
other
stakeholders,
look
into
this.
I'd
like
to
get
a
20
commitment
from
this
Board,
from
the
staff
today
to
do
21
that.

22
MR.
KENNY:
I
think
what
you're
seeing
from
23
the
staff
with
regard
to
the
issues,
that
this
staff
does
24
at
least
believe
NOx
control
is
important
to
control
25
strategies.
We
are
willing
to
sit
down
with
people
and
280
BARNEY,
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1
listen
to
any
evidence
or
any
information
that
they
have
2
and
go
through
that
with
them,
and
try
to
understand
what
3
they're
saying
and
why
they're
saying
it
so
we
can
provide
4
you
with
that
commitment.
In
terms
of
a
report
back
to
the
5
Board,
we
can
do
that
even.

6
CHAIRMAN
DUNLAP:
Okay.
What
form
would
you
7
like
it,
Mr.
Calhoun,
back
to
the
Board?
You
said
you
want
8
a
little
memo.

9
MR.
CALHOUN:
I
guess
I
would
like
to
have
10
them
have
some
discussion
with
the
stakeholders
first
and
11
then
have
something
in
writing
back.

12
CHAIRMAN
DUNLAP:
Okay.

13
MR.
KENNY:
We'd
be
happy
to
have
a
workshop
14
where
we
basically
talk
about
this.

15
CHAIRMAN
DUNLAP:
Is
the
Board
comfortable
16
with
that?
Okay.
Let's
­­
you
had
another
one,
didn't
17
you.

18
MR.
CALHOUN:
I'm
through.

19
CHAIRMAN
DUNLAP:
Premiere.
There
was
some
20
environmentalists
named
who
made
a
consistent
plea
that
we
21
make
sure
that
credit
is
given
for
performance
and
not
for
22
something
else.
To
my
satisfaction
staff
answered
the
23
concern
that
I
think
we
all
should
have,
which
is
does
it
24
work
and
does
the
credit
we're
talking
about
in
this
25
proposal
reflect
that
and
no
more.
And
the
response
I
got
281
BARNEY,
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1
back
was
yes,
Chairman,
it's
reflective
of
that.
I
think
2
we
heard
from
Engelhard
in
testimony
today
they're
willing
3
to
work
with
us
and
studies,
you
know,
Joe
had
an
issue
he
4
heard
about,
that
there's
going
to
be
some
collaboration
5
and
we're
going
to
have
some
continued
monitoring
and
6
durability
assurance;
correct?

7
MR.
KENNY:
Correct.

8
CHAIRMAN
DUNLAP:
Is
Engelhard
here?

9
Mr.
Rosenberg,
that's
your
understanding?

10
MR.
ROSENBERG:
Yes.

11
CHAIRMAN
DUNLAP:
Okay.
So
with
that
12
covered,
the
Chair
feels
comfortable
with
supporting
the
13
Premiere
credit.
Anybody?

14
MR.
CALHOUN:
On
the
part
of
the
actions
by
15
the
staff
­­

16
CHAIRMAN
DUNLAP:
Understood,
but
I'm
just
17
trying
to
disect
the
points
at
issue.
People
are
18
comfortable
with
that.
Okay.

19
The
diesel
issue,
and
again
the
20
environmentalists
made
a
very
consistent
argument
there
21
about
the
fact
we
identified
diesel
particulate
as
a
toxic
22
air
contaminant.
They
don't
want
to
see
any
kind
of
23
reversal,
et
cetera,
or
lose
ground
in
any
way.

24
One
of
the
things
that
carried
some
weight
25
with
me,
despite
Ms.
Edgerton's
concerns
which
I
respect,
282
BARNEY,
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1
just
relative
to
the
engine
manufacturers,
the
concern
2
there
is
that
we
feel
staff
feels
and
is
recommending
that
3
we
go
forward
with
this
element
in
the
program,
largely
4
because
we
think
that
we
can
learn
some
things
that
will
be
5
applicable,
that
provides
for
that
duty
cycle
element
that
6
people
have
clammered
for.
People
have
concerns,
people
7
are
worried
­­
Mr.
Parnell
for
one,
who
has
been
paying
8
close
attention
to
that.
What's
the
Board's
feeling
about
9
the
diesel
element?

10
Yes,
Ms.
Edgerton.

11
MS.
EDGERTON:
Mr.
Chairman,
I'm
going
to
12
ask
it
be
withdrawn
from
the
proposal
and
I'm
going
to
ask
13
for
a
second.
I'll
just
make
a
couple
of
comments
about
­­

14
CHAIRMAN
DUNLAP:
You
can
do
that.
I
just
15
want
to
have
kind
of
a
discussion
ourselves
before
we
get
16
to
that.

17
MS.
EDGERTON:
I
think
­­

18
CHAIRMAN
DUNLAP:
I
want
to
get
out
the
19
issues
that
people
have
reservations
about.

20
MS.
EDGERTON:
I
think
this
part
is
fraught
21
with
downside,
and
I
think
this
special
lower
standard
for
22
diesel
vehicles
into
the
next
century
is
a
mistake.
I
23
think
it's
well
intentioned,
but
I
do
not
believe
that
it's
24
appropriate
in
view
of
our
having
listed
the
toxic
air
25
contaminant.
I
do
not
believe
it's
necessary.
I
don't
283
BARNEY,
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1
believe
it's
fuel
neutral,
and
I
would
propose
instead
of
2
that,
because
I
do
respect
the
intentions
of
the
staff
and
3
the
purpose
behind
the
proposal,
I
would
suggest
that
we
4
leave
it
to
the
next
Board
to
consider.
There
may
be
other
5
ways
to
incentivize
that
by
having
a
program
to
spend
$
10
6
million
to
provide
one
which
would
be
a
direct
way
of
doing
7
it,
and
I
think
the
people
of
California
would
understand
8
that
better
and
it
would
make
more
sense
than
loading
such
9
an
inconsistent,
public
health
damaging
measure
into
this
10
superb
proposal.

11
CHAIRMAN
DUNLAP:
Okay.

12
MS.
EDGERTON:
Also
one
other
thing,
sir.

13
What
I
would
like
to
be
able
to
do,
if
I
could
impose
on
14
you
when
we
do
come
up
for
a
vote,
I
would
like
to
ask
you
15
to
­­
let's
set
it
out
of
the
way
so
I
can
have
the
16
privilege
of
voting
for
LEV
II
but
do
not
have
to
vote
for
17
the
two
measures
I
cannot
support.
I
would
like
those
to
18
be
separated
out
if
we
can.

19
CHAIRMAN
DUNLAP:
What's
the
other
element
20
you
can't
support?

21
MS.
EDGERTON:
The
gasoline,
the
.2
credit
22
for
­­
the
partial
ZEV
credit
for
gasoline
vehicles.
I
23
believe
that
is
a
rear
guard
defensive
measure
to
protect
24
the
ZEV
mandate,
and
I
believe
the
next
Board
can
handle
it
25
very
well
if
that's
how
they
think
that's
the
best
way
to
284
BARNEY,
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1
protect
it.
That's
my
opinion.

2
CHAIRMAN
DUNLAP:
Okay.
All
right.
Does
3
the
diesel
argument
as
it's
outlined
resonate
with
any
4
other
Board
members?

5
SUPERVISOR
ROBERTS:
Mr.
Chairman,
I
was
6
impressed
by
Mr.
Cackette's
explanation,
but
I
wasn't
7
persuaded
by
it.
I
think
I
would
associate
myself
very
8
strongly
with
the
comments
she's
made
on
both
ZEV
and
9
gasoline.

10
CHAIRMAN
DUNLAP:
Anyone
else?
Mark.
11
SUPERVISOR
DE
SAULNIER:
I
have
the
same
12
concern,
although
I
appreciate
what
Tom
said.
As
Lynne
13
said,
the
intention
is
good,
but
I'm
not
sure
as
a
lay
14
person
sitting
here
that
I'm
wholly
comforted
even
though
15
it
came
from
you,
Tom.

16
CHAIRMAN
DUNLAP:
Okay.
So
we
have
three,

17
four
Board
members
that
have
concerns
there.
Lynne,
we'll
18
get
to
that
in
the
form
of
a
motion.

19
Trucks.
Help
me
out
here,
Joe.
He
was
20
doing
so
well
with
that
one.
What
else
is
left
on
the
21
table?

22
MS.
RIORDAN:
Mr.
Chairman,
I
think
there's
23
a
side
bar
which
is
not
necessarily
in
the
body
of
this
but
24
is
extremely
important,
and
I
don't
believe
it
is.
And
I
25
don't
recall
each
and
every
word,
but
that
was
the
285
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1
testimony
that
we've
really
seriously
got
to
undertake
an
2
effort
to
clean
diesel
fuel,
and
it
really
isn't
just
3
California
that
needs
to
do
this.
This
needs
to
be
4
something
that's
done
nationwide,
and
I
think
that's
one
of
5
the
compelling
things
that
this
Board,
constituted
as
we
6
are
today
or
another
Board
in
years
to
come,
just
really
7
needs
to
concentrate
on.

8
I
believe
that
very
strongly
because
I
know
9
as
we
watch
the
movement
of
freight
through
our
state,
much
10
of
the
fuel
that's
put
into
those
big
rigs
that
come
across
11
our
state,
it's
often
bought
outside
of
the
state
and
they
12
can
run
it
through
and
out
again
before
we
have
an
13
opportunity
to
really
benefit
from
our
requirements
versus
14
the
requirements
of
other
areas.
It
really
needs
to
be
a
15
nationwide
effort,
and
I
think
that
was
something
I
keyed
16
in
on
and
something
that
has
been
of
concern
to
me
and
we
17
really
need
to
work
on
this.

18
MS.
EDGERTON:
Mr.
Chairman,
I
would
like
to
19
make
another
comment
about
the
.2
­­

20
CHAIRMAN
DUNLAP:
One
second.
Does
the
21
court
reporter
need
a
minute
to
change
the
paper?

22
(
Interruption
in
the
proceedings.)

23
CHAIRMAN
DUNLAP:
What
other
new
issues
are
24
left?
What
about
it,
Joe?

25
MR.
CALHOUN:
Mr.
Chairman
and
members
of
286
BARNEY,
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1
the
Board
and
audience,
my
big
concern
is
the
testimony
2
we've
heard
from
industry
and
the
staff
today
about
the
3
truck,
and
particularly
the
truck
between
6,000
and
8,500.

4
Now,
California
has
been
in
this
emission
5
game
since
1966,
and
I
believe
the
first
truck
standards
6
that
were
required
started
with
1970
with
the
'
70
model
7
year,
and
since
that
time
to
this
day
the
trucks
have
8
always
had
different
standards
from
passenger
cars,
and
the
9
reason
for
it
is
because
the
duty
cycle
is
different,
and
I
10
don't
think
that
has
changed.

11
Now,
admitted
people
use
them
for
other
12
reasons
other
than
they
were
intended,
but
the
13
manufacturers
have
to
certify
the
vehicle
with
this
­­
I'll
14
call
it
adverse
equipment
on
­­
the
manufacturers
have
to
15
meet
the
vehicle
and
test
protocol
is
somewhat
different,
16
and
they
have
to
­­
these
trucks
have
to
work
harder
in
17
order
to
meet
the
standard,
so
it's
difficult
for
me,

18
knowing
what
I
know
about
it
and
knowing
all
these
years
it
19
hasn't
been
changed,
my
preference
would
have
been
that
if
20
we
want
to
get
more
emissions,
tighten
up
on
the
car
21
standard,
but
that's
not
the
issue
before
this
Board
today.

22
So
I
have
trouble
supporting
the
staff
proposal
for
light
23
duty
trucks
or
these
trucks,
and
I
would
propose
we
24
substitute
the
industry
proposal
for
it.

25
CHAIRMAN
DUNLAP:
Okay.
All
right.
Is
287
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1
there
anybody
on
the
Board
that
we
ought
to
bump
from
the
4
2
percent
to
the
15,
that
that
resonates
with
them
other
than
3
Mr.
Calhoun?

4
MR.
PARNELL:
John,
I
don't
want
to
elongate
5
this
meeting,
but
it
is
somewhat
concerning
to
me,
although
6
I
heard
the
staff
briefing.
They
were
very
articulate.
I
7
heard
what
we
heard
from
General
Motors
and
Ford,
and
for
8
me
there
is
a
total
disconnect
in
the
information
that
you
9
say
that
we
have
off­
the­
shelf
technology
that
was
aged
10
that
put
on
the
cars
and
we
can
meet
the
standards,
and
11
they
said
they
can't
meet
the
standards.
I
understand
12
headroom
and
I
understand
their
concerns,
but
I
also
13
understand
that
the
appearance
here
is
the
total
disconnect
14
between
what
you're
saying.

15
Normally
we
get
closer
on
these
issues,
but
16
having
said
that,
I
have
to
say
that
I'm
compelled
by
the
17
argument
that
if
we
do
biannual
reviews,
that
the
industry
18
has
time
to
come
in
and
make
­­
if
in
fact
what
they're
19
saying
is
absolutely
true,
that
they
can't
meet
these
20
emission
standards
­­
that
they'll
have
an
opportunity
to
21
talk
to
some
other
Board
some
other
day
and
to
the
staff
to
22
make
that
point.
You
know,
I've
never
been
as
probably
23
confused
in
the
past
as
I
am
today
just
because
of
that
one
24
serious,
serious
disconnect,
and
I
don't
know
if
anyone
can
25
shed
any
light
on
it.
Perhaps
there
is
no
light
to
be
288
BARNEY,
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shed.

2
CHAIRMAN
DUNLAP:
That's
the
troubling
part
3
of
this.
I
think
we
kind
of
crossed
a
threshold
a
few
4
years
ago
with
that
issue
relative
to
the
industry.
We
5
worked
with
them.
We
have
a
process
whereby
with
this
MOA
6
we're
working
with
them,
and
I
know
that
staff's
done
that
7
well
and
I
know
the
relationship
has
been
good,
but
I
would
8
agree
with
Mr.
Parnell.

9
In
the
four
years
I've
been
here,
I've
not
10
seen
this
effort
going
into
finding
a
common
ground
and
11
people
still
not
being
there.
I've
told
the
industry
and
12
I'll
say
again,
the
staff,
while
not
perfect,
has
been
13
right
more
often
than
not,
and
when
I
have
the
staff
14
telling
me
that
this
can
be
done,
they're
showing
the
data
15
and
they're
willing
to
go
toe­
to­
toe
on
some
of
these
16
arguments,
it's
difficult
for
me
to
say
no,
I'm
going
to
17
disregard
all
that
and
I'm
going
to
go
with
some
industry
18
points
of
view,
because
that
leaves
me
nowhere,
and
so
I'm
19
troubled
by
that
too.
I
am
comforted
by
the
two­
year
20
review.
Okay.
21
Why
don't
we
get
down
to
the
business
of
22
moving
this
item.
Has
it
been
fair
thus
far
that
we've
got
23
the
most
support
things
out
there?

24
So
the
primary,
there
seems
to
be
consensus
25
on
all
issues
save
the
diesel
issue,
and
what
else
am
I
289
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missing?

2
MS.
EDGERTON:
The
.2
partial
credit.

3
CHAIRMAN
DUNLAP:
Again
the
hybrid
issue.

4
What
do
we
call
it?

5
MR.
CACKETTE:
Partial
ZEV
credit
for
6
gasoline.

7
MS.
EDGERTON:
I
wanted
to
again
articulate
8
my
concern.

9
CHAIRMAN
DUNLAP:
I
want
to
find
out
if
10
there's
anybody
else
on
the
Board
that
feels
that
way
so
we
11
can
get
a
flavor
for
it.
Anybody
else
concerned
about
the
12
partial
ZEV
credit?

13
SUPERVISOR
ROBERTS:
You're
talking
about
14
the
gasoline,
.2
or
whatever?

15
CHAIRMAN
DUNLAP:
Yes.

16
SUPERVISOR
ROBERTS:
Yes.
Both
of
those.

17
CHAIRMAN
DUNLAP:
So
we
have
a
couple
other
18
members
concerned
about
that.
Okay.
Why
don't
we
­­
well,

19
I
think
I'm
willing
to
put
that
to
a
vote,
so
what
I'm
20
going
to
try
to
do,
Kathleen,
if
I
can
is
isolate
that
21
component
and
see
if
the
Board
wants
to
not
give
the
22
partial
ZEV
credit
on
gasoline
vehicles.
Can
we
do
that?

23
MS.
WALSH:
What
you
might
want
to
do
is
ask
24
if
you
have
a
motion
for
the
revised
resolution,
second.

25
You
can
then
take
amendments,
proposed
amendments
to
the
290
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resolution.

2
CHAIRMAN
DUNLAP:
Fine.
Okay.
I'm
going
to
3
take
a
motion
on
the
resolution,
so
I'm
going
to
look
to
4
Mrs.
Rakow
who
has
clear
thinking
on
this
thing
and
put
it
5
on
your
shoulders
to
capture
as
much
of
this
as
you
can.

6
She's
been
keeping
a
list.

7
MRS.
RAKOW:
I
was
going
to
make
it
very
8
simple
and
say
that
I
move
that
the
Board
accept
the
staff
9
proposal
on
California's
Low
Emission
Vehicle
program
and
10
include
the
eight
pages
of
the
revised
proposed
amendments.

11
CHAIRMAN
DUNLAP:
Resolution.

12
MRS.
RAKOW:
Resolution.

13
CHAIRMAN
DUNLAP:
Okay.

14
MS.
RIORDAN:
I'll
second
the
motion.

15
CHAIRMAN
DUNLAP:
We
have
a
motion
and
a
16
second.
Now,
there
­­

17
MS.
WALSH:
Might
I
just
inquire?

18
So
we
don't
have
any
confusion,
there
are
19
two
proposed
resolutions
out.
The
one
that
includes
the
20
language
that
Mrs.
Rakow
proposed
earlier,
that
is
the
21
resolution
the
motion
refers
to,
says
revised
proposed
22
resolution?

23
MRS.
RAKOW:
Right.

24
CHAIRMAN
DUNLAP:
The
second
would
agree?

25
MS.
RIORDAN:
I
would
agree.
291
BARNEY,
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CHAIRMAN
DUNLAP:
Now,
amendments
to
that
2
motion,
Ms.
Edgerton,
would
be
what?

3
MS.
EDGERTON:
Yes.
I
would
like
to
do
the
4
seriatim.
I
would
like
to
first
propose
that
the
.2
5
partial
ZEV
credit
for
gasoline
vehicles
be
deleted
from
6
the
partial
ZEV
credit.

7
CHAIRMAN
DUNLAP:
There's
a
motion
to
that
8
amendment.
Is
there
a
second?

9
SUPERVISOR
ROBERTS:
I'll
second
that,
John.

10
CHAIRMAN
DUNLAP:
Any
discussion
we
need
to
11
have
on
that?

12
MS.
EDGERTON:
Yes.
I
would
like
to
discuss
13
it
as
the
maker
of
the
motion.

14
CHAIRMAN
DUNLAP:
Okay.

15
MS.
EDGERTON:
I
think
what
we've
seen,
and
16
this
whole
hearing
began
with
the
presentation
from
17
Ballard.
I
think
what
we've
seen
are
enormous
advances
in
18
the
fuel
cell
area,
and
we've
also
seen
tremendous
advances
19
with
battery
powered
electric
vehicles
that
we've
all
been
20
driving.

21
I
think
that
those
advances
are
very
22
exciting
and
we
don't
know
whether
in
this
next
time
frame
23
of
2004
to
2010
whether
it
might
not
be
possible
for
that
24
10
percent
to
be
filled
up
with
hybrid
vehicles,
hybrid
25
electric
vehicles
and
more
ZEVs
if
there
are
breakthroughs
292
BARNEY,
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in
that
technology.
So
my
argument
here
is
that
are
we
2
shooting
ourselves
in
the
foot?
I
do
certainly
respond
3
enthusiastically
to
Honda's
and
others'
super
ULEVs.
I
4
think
that's
great.

5
However,
I
think
we
want
to
be
sure
that
we
6
keep
this
category
open
to
further
those
technologies
that
7
are
making
so
much
progress
and
which
are
the
silver
bullet
8
or
silver
bullets
for
southern
California,
for
your
9
children,
my
children
and
our
grandchildren,
and
so
with
10
respect,
though
I
think
­­
and
the
second
thing
I
think
11
that
it
is
not
clear.
I
believe
the
gasoline
vehicles
do
12
not
belong
here
because
part
of
the
reason,
I
distinctly
13
recall
the
major
part
of
the
reason
was
to
try
to
provide
14
for
the
upstream
emissions
measures,
so
I
think
that
also
15
it
torments
the
category.

16
CHAIRMAN
DUNLAP:
Mrs.
Rakow,
you're
welcome
17
to
say
something.

18
MRS.
RAKOW:
Thank
you.
I'm
very
19
understanding
of
your
viewpoint
because
I'm
very,

20
extremely,
completely
supportive
of
fuel
cells
and
electric
21
vehicles.
However,
I
looked
on
this
as
the
ZEV
credit,

22
where
I
normally
would
have
been
completely
­­
I
look
on
it
23
as
a
building
block
to
get
to
where
we
ultimately
want
to
24
be
with
electric
vehicles
in
California,
and
so
I
think
25
this
is
part
of
building
the
support
to
get
there,
so
­­
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CHAIRMAN
DUNLAP:
One
of
the
things
that
2
Lynne
not
so
much
surprised
me
about
your
position
is
this.

3
I
just
remember
you
being
very
enthusiastic
about
hybrid
4
technology,
about
finding
some
way
to
get
them
into
the
5
program,
about
getting
them
some
credit.
I
remember
you
6
encouraging
me
early
in
my
tenure
to
come
clean
with
what
7
was
going
on,
and
I
remember
us
having
some
conversations
8
with
staff
about
some
exciting
technology
developments
that
9
use
the
best
of
both
kinds
of
elements
of
clean
gasoline
10
engines
and
electric
powered
zero
emission,
so
­­
I
think
11
we've
put
this
issue
off
for
a
long
time.

12
Tom,
you
and
I
have
talked
about
this
for
13
about
two
and
a
half,
three
years,
so
I
don't
see
this
so
14
much
as
a
give­
away
or
a
bad
thing
on
ZEVs,
but
I
view
it,

15
as
Mrs.
Rakow
does,
as
kind
of
a
step
to
recognize
people
16
for
coming
up
with
a
cleaner
car
and
giving
proportional
17
credit.

18
Now,
I'll
say
­­
and
I
think
I've
said
it
19
before
­­
I
support
zero
emission
vehicles.
I
want
them
to
20
be
successful.
I
want
Sam
to
move
that
EV­
1.
I
want
21
harmony.
I
want
all
these
things
out
there,
but
we
can
22
want
it
all
day
long,
but
if
they're
not
getting
out
there,

23
A,
the
only
benefits
we're
going
to
see
is
only
going
to
be
24
on
paper
and
expectation.
So
I
think
what
we
want
to
do
is
25
nurture
and
support
some
things
getting
out
there
that
294
BARNEY,
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1
maybe
don't
do
everything
we
like,
but
are
certainly
making
2
progress
and
are
attractive
to
consumers,
and
if
people
are
3
perceiving
it
as
a
walk­
away
from
the
gold
standard
of
4
ZEVs,
I
think
that's
a
false
assumption,
and
I
think
we've
5
got
a
ways
to
go
to
get
the
consumers
there.
There's
6
pricing
issues,
there's
performance
issues,
there's
7
technology
barriers,
so
I'm
not
afraid
either
of
the
8
symbolism
or
kind
of
where
that
leaves
us
consistently.

9
I'm
just
not
worried
about
it
that
much
yet.
I
think
we
10
need
this
technology.

11
Supervisor
Patrick,
you're
welcome
to
say
12
anything
if
you
like.

13
SUPERVISOR
PATRICK:
Thank
you,

14
Mr.
Chairman.
I
would
like
to
just
say
how
much
I
agree
15
with
your
position
on
this.
I
think
that
the
environmental
16
community
has
made
some
very
compelling
arguments
for
why
17
they
want
us
to
go
in
another
direction,
and
we
have
heard
18
them
and
I
think
they
are
very
compelling.

19
On
the
other
hand,
I
think
the
industry
20
needs
more
flexibility,
and
I
think
this
helps
to
encourage
21
the
kind
of
commitment
that
we
need
to
move
towards
22
complete
zero
emission
vehicles
in
the
future,
and
I
think
23
that
we
need
to
support
that
flexibility
for
industry.
It
24
helps
us
get
there,
I
think.

25
CHAIRMAN
DUNLAP:
Thank
you.
Ron,
did
you
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want
to
­­
and
Ron,
I
know
you've
been
a
big
booster
of
2
this
technology
from
the
get­
go.

3
SUPERVISOR
ROBERTS:
Yeah.
And
I
guess
I'm
4
not
as
convinced
as
you
are
­­

5
CHAIRMAN
DUNLAP:
Right.
6
SUPERVISOR
ROBERTS:
­­
that
this
is
moving
7
in
a
direction
that
­­
I
think
we
just
have
a
strong
8
difference
of
opinion,
John,
and
I
was
also
persuaded
by
9
the
comments
that
I
heard
about
looking
at
this
as
a
10
system,
and
it's
not
just
the
car
and
it's
not
just
what's
11
coming
out
of
the
tailpipe,
but
it's
a
whole
system
of
12
things
contributing
to
a
problem.
That
by
allowing
this
13
option
we're
losing
sight
of
a
good
portion
of
this,
and
I
14
just
­­
I
don't
feel
comfortable,
and
I
think
it's
15
inappropriate
and
I
don't
see
it
as
helping
in
the
way
that
16
you
feel
confident.

17
CHAIRMAN
DUNLAP:
Okay.
All
right.
If
18
there's
no
other
discussion,
we'll
vote
on
the
amendment.

19
Lynne,
would
you
restate
it?

20
MS.
EDGERTON:
To
delete
from
the
partial
21
ZEV
credit
measure
only
the
credit
provision
for
gasoline
22
vehicles,
which
is
the
credit
of
.2.

23
CHAIRMAN
DUNLAP:
Okay.

24
MR.
CACKETTE:
I
would
like
to
clarify
that
25
gasoline­
only
vehicles,
because
there
are
credits
in
there
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for
gasoline
hybrid
electric
vehicles,
for
example.

2
MS.
EDGERTON:
I
think
gasoline­
only,
that
3
they
only
have
gasoline,
not
for
hybrids
that
have
gasoline
4
and
­­

5
SUPERVISOR
ROBERTS:
That's
the
.2?

6
MS.
EDGERTON:
Yes.

7
CHAIRMAN
DUNLAP:
All
right.
We'll
proceed
8
with
a
voice
vote,
and
we
have
a
motion
and
second
relative
9
to
this
amendment
as
it
relates
to
gasoline­
only
hybrids
10
and
SULEVs.
All
those
in
favor
of
the
motion
say
"
aye."

11
okay.
Raise
your
hand.
We
have
one,
two,
three,
four.

12
Opposed?
Raise
your
hand.
Okay.

13
It
appears
that
that
motion,
that
amendment
14
is
not
made.
Okay.
What's
the
other
amendment
we
have?

15
MS.
EDGERTON:
Mr.
Roberts,
do
you
want
to
16
make
it
or
do
you
want
me
to
make
it?

17
SUPERVISOR
ROBERTS:
Well,
this
would
be
18
that
as
it
pertains
to
the
diesel
­­

19
CHAIRMAN
DUNLAP:
Okay.

20
SUPERVISOR
ROBERTS:
­­
exemption.

21
CHAIRMAN
DUNLAP:
Okay.

22
SUPERVISOR
ROBERTS:
I
would
move
that
we
23
would
delete
that.

24
DR.
FRIEDMAN:
Second.

25
CHAIRMAN
DUNLAP:
Okay.
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MS.
EDGERTON:
Second.
Who's
the
second?

2
CHAIRMAN
DUNLAP:
Okay.
There's
a
motion
by
3
Supervisor
Roberts
­­

4
MS.
EDGERTON:
I
second.

5
CHAIRMAN
DUNLAP:
­­
and
a
second
by
6
Dr.
Friedman.
All
right.
Let's
­­

7
MR.
KENNY:
Actually,
I
want
­­
for
8
clarification
purposes,
I
think
we
need
to
make
sure
we
9
understand
what
the
motion
is.

10
CHAIRMAN
DUNLAP:
Okay.
Very
good.
Ron,
11
restate
it,
and
Tom,
you're
welcome
to
assist
him
to
make
12
sure
we
cover
what
the
intent
is.

13
MR.
KENNY:
Is
the
motion
to
delete
the
TLEV
14
standard
and
the
alt
TLEV
standard
as
proposed
by
staff?

15
And
that
is
essentially
the
on­
trade
we
discussed
for
16
diesels.

17
SUPERVISOR
ROBERTS:
That's
correct.

18
CHAIRMAN
DUNLAP:
Okay.
We
have
a
motion
19
and
a
second.

20
MR.
CACKETTE:
There
was
also
a
nuance
item.

21
I'm
not
sure
this
came
out,
but
we
have
a
standard
in
2004
22
which
is
a
TLEV
standard
available
to
gasoline
or
diesel.

23
There's
an
optional
standard
as
well
for
that,
and
in
2007
24
the
staff
proposed
to
tighten
the
standard
down,
so
I
just
25
want
to
point
out
there's
a
couple
of
time
windows
and
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obviously
the
motion
could
be
to
eliminate
all
2
TLEVs
from
day
one
in
the
LEV
II
program
or
only
after
3
2007.
There's
various
­­

4
MS.
EDGERTON:
My
motion
is
to
eliminate
all
5
TLEVs
­­

6
MR.
CACKETTE:
From
the
LEV
II
program.

7
MS.
EDGERTON:
­­
from
2004
on.

8
CHAIRMAN
DUNLAP:
Okay.
Is
that
okay
with
9
­­
Ron,
you
made
that
motion?

10
SUPERVISOR
ROBERTS:
Yes.

11
MS.
EDGERTON:
Oh,
wait.

12
CHAIRMAN
DUNLAP:
Is
that
okay
with
the
13
second
from
Dr.
Friedman?
14
DR.
FRIEDMAN:
Yes.

15
CHAIRMAN
DUNLAP:
Okay.

16
MS.
EDGERTON:
Is
that
wrong?

17
MR.
KENNY:
That's
correct.

18
There
are
two
TLEVs
in
2004.
There's
the
19
standard
TLEV
which
is
essentially
the
carryover
from
LEV
20
I.
There
is
an
alt
TLEV
which
is
the
proposal
by
the
21
staff,
and
there's
an
alternative
to
the
LEV
I,
TLEV
22
proposal,
and
then
there
is
a
2007
TLEV
proposal.
So
as
I
23
understand
what
the
motion
is,
you're
proposing
to
24
eliminate
TLEVs
from
2004
on,
so
what
would
happen
is
that
25
there
would
not
be
any
TLEVs
in
either
2004,
there
would
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not
be
any
alt
TLEVs
in
2004,
and
there
would
not
be
any
2
TLEVs
in
2007,
so
all
the
TLEV
references
would
be
deleted.

3
CHAIRMAN
DUNLAP:
Okay.

4
MR.
SCHONING:
Mr.
Chairman,
if
you
look
at
5
page
2
of
the
15­
day
handout,
you
can
see
the
standard
6
table
and
the
four
places
where
there
are
TLEV
standards.

7
CHAIRMAN
DUNLAP:
Okay.
Page
2?
Okay.

8
We
have
a
motion
and
a
second
to
delete
the
9
TLEV
elements
as
outlined
by
our
executive
officer.

10
MS.
EDGERTON:
Point
of
information,
I'd
11
like
to
ask
the
staff.
Alternatively
we
could
keep
the
12
TLEV
but
at
the
lower
level
which
you
indicated
to
me
it
13
could
be
made
to
gasoline
and
so
it
wouldn't
be
especially
14
for
diesel;
right?

15
MR.
KENNY:
It's
not
especially
for
diesel.
16
The
TLEV
standard
as
part
of
LEV
I
is
the
original
TLEV
17
standard
that
is
being
utilized
by
both
gasoline
and
18
diesel.
It
does
have
a
NOx
standard
which
is
more
lenient,

19
diesel
is
able
to
take
advantage
of,
so
that
TLEV
standard
20
as
part
of
LEV
I
would
essentially
on
its
own
disappear
by
21
2007
as
part
of
LEV
I.

22
What
we're
really
talking
about
here
is
do
23
we
have
the
original
TLEV
standard
which
the
Board
adopted
24
back
in
1990
as
part
of
LEV
I
continue
out
and
run
its
25
course
or
do
we
take
that
TLEV
standard
out
beginning
in
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2004,
then
what
the
staff
has
proposed
as
part
of
LEV
II
as
2
an
alternative
to
the
TLEV
standard
in
2004,
and
then
the
3
tighter
TLEV
standard
in
2007.

4
MR.
CACKETTE:
If
I
could,
maybe
this
might
5
help
a
little
bit.
I
don't
want
to
add
confusion
here.

6
CHAIRMAN
DUNLAP:
I
forbid
you
to
confuse
7
anyone.

8
(
Laughter.)

9
MR.
CACKETTE:
Let
me
just
say
that
the
TLEV
10
standard
was
there
for
two
purposes.
It's
been
in
there
11
LEV
I
and
LEV
II
because
we
thought
having
a
menu
of
12
different
standards
from
dirtier
to
super
clean
was
a
way
13
of
providing
flexibility
to
the
auto
industry.
They
make
14
some
TLEVs,
some
super
ULEVs,
mostly
LEVs
and
ULEVs.

15
That's
kind
of
the
way
it's
gone.
Where
the
diesel
aspect
16
comes
in
is
it
happens
to
be
that
the
only
standard
is
the
17
TLEV
standard,
so
that's
why
you're
focusing
on
TLEV.
But
18
it
was
there
for
another
purpose
which
is
to
provide
some
19
flexibility
for
even
gasoline
powered
cars,
and
obviously
20
we
called
it
transitional
because
we
had
a
vision
of
it
21
going
away
eventually.
And
the
way
it
goes
away
is
we
have
22
this
fleet
average
standard
and
it
just
cranks
down
and
you
23
just
can't
make
measure
of
these
dirtier
vehicles,
gas
or
24
diesel,
so
that's
what
its
two
purposes
were.
I
just
25
wanted
to
tell
you.
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CHAIRMAN
DUNLAP:
Okay.

2
MS.
EDGERTON:
My
understanding
is
that
­­

3
CHAIRMAN
DUNLAP:
I
want
to
call
the
4
question.
We
think
we
know
what
we
want
here.
How
is
it
5
­­
the
only
clarification
I
think
at
this
point
is
how
is
6
it
going
to
disadvantage
or
impact
gasoline
powered
7
vehicles,
Tom?

8
MR.
CACKETTE:
The
TLEV
I,
the
current
9
standard,
can
be
used
to
a
limited
extent
to
the
year
2006,

10
then
that
program
goes
away
in
2007.
It's
not
available.

11
If
you
make
this
motion,
it's
not
available
to
anybody.
I
12
don't
think
it
creates
an
impossible
situation
anywhere,

13
but
it
clearly
takes
away
flexibility
and
it
does
in
our
14
mind
prevent
any
diesel
vehicle
we
are
aware
of
or
can
see
15
in
the
future
from
complying
with
the
LEV
standards.

16
MS.
EDGERTON:
So
we'll
just
stay
with
17
taking
it
out.

18
CHAIRMAN
DUNLAP:
Well,
we
have
a
motion
and
19
a
second.
Any
discussion
we
need
to
have?

20
I'm
going
to
do
a
voice
vote.
Okay?
So,
21
Ms.
Shelby,
why
don't
you
call
the
question.

22
MS.
SHELBY:
Calhoun.

23
MR.
CALHOUN:
No.

24
MS.
SHELBY:
DeSaulnier.

25
SUPERVISOR
DE
SAULNIER:
Aye.
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MS.
SHELBY:
Is
that
yes?

2
SUPERVISOR
DE
SAULNIER:
Yes.

3
MS.
SHELBY:
Edgerton.

4
MS.
EDGERTON:
Yes.

5
MS.
SHELBY:
Friedman.

6
DR.
FRIEDMAN:
Yes.

7
MS.
SHELBY:
Parnell.

8
MR.
PARNELL:
No.

9
MS.
SHELBY:
Patrick.

10
SUPERVISOR
PATRICK:
Yes.

11
MS.
SHELBY:
Rakow.

12
MRS.
RAKOW:
Yes.

13
MS.
SHELBY:
Riordan.

14
MS.
RIORDAN:
No.

15
MS.
SHELBY:
Roberts.

16
SUPERVISOR
ROBERTS:
Yes.

17
MS.
SHELBY:
Silva.

18
SUPERVISOR
SILVA:
Yes.

19
MS.
SHELBY:
Chairman
Dunlap.

20
(
Laughter.)

21
CHAIRMAN
DUNLAP:
Do
I
really
have
any
power
22
to
effect
that
one?
I'll
abstain
on
that
one.
I
don't
see
23
any
purpose.
24
All
right.
That
motion
carries.
TLEVs
are
25
gone.
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MS.
SHELBY:
Seven
to
three
with
the
2
Chairman
abstaining.

3
CHAIRMAN
DUNLAP:
Okay.
Now
the
whole
4
motion.
What
else
do
we
have?
We
have
the
rest
­­
well,

5
unless
I
have
an
amendment,
Joe.
Do
we
have
somebody
that
6
wants
to
offer
an
amendment
other
than
the
one
we
just
7
voted
on?

8
MR.
CALHOUN:
Yes.

9
CHAIRMAN
DUNLAP:
Okay.
What's
your
10
amendment?

11
MR.
CALHOUN:
Mr.
Chairman
of
the
Board,
I
12
propose
that
we
amend
the
resolution
so
far
as
it
pertains
13
to
the
LEV
II
exhaust
emission
standards
for
new
2004
and
14
subsequent
model
years,
LEVs,
ULEVs
and
sub
ULEVs,
and
15
passenger
car,
light
duty
truck
and
medium
duty
vehicles
­­

16
we've
already
eliminated
TLEVs
­­
amended
to
accept
the
17
industry
proposal
in
lieu
of
the
­­

18
CHAIRMAN
DUNLAP:
Okay.
We
kind
of
talked
19
about
it.
I
was
looking
for
consensus
to
that,
Joe,
and
I
20
couldn't
find
any.
Does
anybody
want
to
second
that
21
motion?
Okay.
Joe,
the
motion
dies.
I
appreciate
the
22
effort.

23
Let's
go
to
the
main
motion
which
we
have
24
before
us
which
proved
the
resolution,
the
revised
25
resolution
with
exception
of
the
TLEV
elements
that
have
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been
stripped
out.
Do
we
need
to
have
any
discussion
on
2
that?
Okay.

3
We'll
proceed
with
a
voice
vote.
All
those
4
in
favor
say
"
aye".

5
ARB
BOARD:
Aye.

6
CHAIRMAN
DUNLAP:
Any
opposed?
Very
good.

7
Thank
you.
It
looks
like
we're
done
with
LEV
II.

8
What
we're
going
to
do
­­
first
of
all,
I
9
want
to
thank
everybody
who
participated
and
testified
10
today.
It
was
a
long
day.

11
We
have
an
open
comment
period.
I'm
going
12
to
ask
Supervisor
Riordan
to
open
up
the
open
comment
13
period.
We
have
five
witnesses
who
have
signed
up.
I'm
14
going
to
ask
Supervisor
Riordan
to
proceed
to
do
that.

15
MS.
RIORDAN:
Thank
you,
Mr.
Chairman.

16
Mr.
Parnell,
did
you
want
to
make
a
comment?

17
MR.
PARNELL:
I
only
wanted
to
take
the
18
opportunity
to
say
this,
and
I've
worked
at
the
highest
19
levels
of
federal
government,
the
highest
levels
of
state
20
government,
and
I
have
never
in
my
whole
experience
ever
21
had
the
opportunity
to
work
with
a
brighter,
more
diligent
22
young
man
that
has
probably
one
of
the
great
futures
ahead
23
of
him.

24
I've
never
worked
with
anyone
with
more
25
integrity,
anyone
with
more
strength
of
character,
anyone
305
BARNEY,
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1
with
more
singleness
of
purpose.
This
clean
air
is
his
2
agenda
and
has
been,
so
I
just
wanted
to
say
publicly
in
3
all
of
my
experience
across
the
board
in
government,
this
4
man
has
meant
an
awful
lot
to
me
and
will
continue
to
meet
5
an
awful
lot
to
me
because
I
think
he
is
the
absolute
6
epitome
of
leadership
in
America
today,
so
thank
you,
John.

7
(
Applause.)

8
CHAIRMAN
DUNLAP:
You
guys
have
been
hearing
9
from
me
all
day,
so
I'll
make
it
brief.

10
Jack,
it's
very
kind.
I've
really,
really
11
enjoyed
my
time
with
the
Air
Resources
Board.
It
was
a
12
great
honor
for
the
Governor
to
ask
me
to
serve
in
this
13
way.
I
not
only
come
to
enjoy
the
work,
which
I
kind
of
14
was
trained
to
do
earlier
in
my
career
because
I
knew
air
15
pollution,
but
I've
really
come
to
have
great
fondness
and
16
affection
not
only
of
the
members
of
this
Board,
but
to
the
17
staff.

18
Mike
Kenny
has
just
been
terrific
and
the
19
staff
is
supremely
competent
and
committed,
and
any
way
20
that
it
looked
favorably
upon
me
or
us
is
because
of
them
21
and
you,
and
so
I'll
be
always
grateful
for
that
and
also
22
the
stakeholders.
You
guys
have
kept
everybody
honest,
and
23
I
think
that's
important
in
the
process,
so
thank
you.
I'm
24
embarrassed
by
the
attention
and
we'll
proceed
with
the
25
open
comment
period.
Thank
you.
306
BARNEY,
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1
MS.
RIORDAN:
And
thank
you,
Mr.
Chairman.

2
And
we'll
have
another
opportunity
to
honor
our
Chairman
3
and
we
look
forward
to
that
a
little
bit
later
in
this
4
month.

5
This
is
an
open
comment
period.
Although
6
the
Board
can't
take
formal
action,
we
are
open
to
hearing
7
items
that
are
in
our
jurisdiction,
and
so
let
me
call
on
8
Bob
Warden
from
Western
States
Petroleum
Association.

9
MR.
WARDEN:
Pass.

10
MS.
RIORDAN:
Pardon
me?

11
MR.
WARDEN:
I'll
pass.

12
MS.
RIORDAN:
You'll
pass.

13
Don
Gilson
from
Western
States
Petroleum
14
Association.

15
MR.
GILSON:
I'll
pass,
too.

16
MS.
RIORDAN:
You
know
we
have
a
lot
of
work
17
to
do,
gentlemen,
so
we're
delighted
you're
here,
and
I
18
think
you
heard
the
comments
about
partnership
and
working
19
with
cleaner
fuels.

20
Wolfgang
Groth
from
Volkswagen
of
America.

21
Mr.
Groth?

22
MR.
GROTH:
Pass.

23
MS.
RIORDAN:
Passing?
You're
saying
24
goodbye.
Patrick
Kudell
from
the
American
Lung
25
Association,
are
you
still
here?
Mike
McCormach
from
EEC,
307
BARNEY,
UNGERMANN
&
ASSOCIATES
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1
pardon
me,
CEC,
California
Energy
Commission.
I
guess
they
2
left.

3
And
so
with
that
in
mind,
I
am
going
to
4
adjourn
the
meeting
and
thank
you
all
very
much
for
coming.

5
*
*
*

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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BARNEY,
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1
STATE
OF
CALIFORNIA
)

2
)
ss.

3
COUNTY
OF
SAN
BERNARDINO
)

4
5
I,
Terri
L.
Emery,
CSR
11598,
a
Certified
6
Shorthand
Reporter
in
and
for
the
State
of
California,
do
7
hereby
certify:

8
That
the
foregoing
proceeding
was
taken
down
9
by
me
in
shorthand
at
the
time
and
place
named
therein
and
10
was
thereafter
reduced
to
typewriting
under
my
supervision;

11
that
this
transcript
is
a
true
record
of
the
testimony
12
given
by
the
witnesses
and
contains
a
full,
true
and
13
correct
record
of
the
proceedings
which
took
place
at
the
14
time
and
place
set
forth
in
the
caption
hereto
as
shown
by
15
my
original
stenographic
notes.

16
I
further
certify
that
I
have
no
interest
in
17
the
event
of
the
action.

18
EXECUTED
this
20th
day
of
November,
1998.

19
20
21
22
______________________________

23
Terri
L.
Emery,
CSR
#
11598
24
25
309
BARNEY,
UNGERMANN
&
ASSOCIATES
1­
888­
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5900
