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3 - The Bowery_PUBLIC COMMENT_RAMSEY
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16 <br /> <br />reductions can be achieved, depending on the newer engine and the vehicle or machine’s ability to <br />accept a more modern engine and emission control system. It should be noted, however, that newer <br />engines or higher tier engines are not necessarily cleaner engines, so it is important that the Project <br />Applicant check the actual emission standard level of the current (existing) and new engines to ensure <br />the repower product is reducing emissions for DPM.34 <br />• Replacement of older equipment with equipment meeting the latest emission standards. <br />Engine replacement can include substituting a cleaner highway engine for a nonroad engine. Diesel <br />equipment may also be replaced with other technologies or fuels. Examples include hybrid switcher <br />locomotives, electric cranes, LNG, CNG, LPG or propane yard tractors, forklifts or loaders. <br />Replacements using natural gas may require changes to fueling infrastructure.35 Replacements often <br />require some re-engineering work due to differences in size and configuration. Typically, there are <br />benefits in fuel efficiency, reliability, warranty, and maintenance costs.36 <br />Install Retrofit Devices on Existing Construction Equipment <br />PM emissions from alternatively-fueled construction equipment can be further reduced by installing <br />retrofit devices on existing and/or new equipment. The most common retrofit technologies are retrofit <br />devices for engine exhaust after-treatment. These devices are installed in the exhaust system to reduce <br />emissions and should not impact engine or vehicle operation. 37 It should be noted that actual emissions <br />reductions and costs will depend on specific manufacturers, technologies and applications. <br />Use Electric and Hybrid Construction Equipment <br />CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures38 report also proposes the use of electric <br />and/or hybrid construction equipment as a way to mitigate DPM emissions. When construction <br />equipment is powered by grid electricity rather than fossil fuel, direct emissions from fuel combustion <br />are replaced with indirect emissions associated with the electricity used to power the equipment. <br />Furthermore, when construction equipment is powered by hybrid-electric drives, emissions from fuel <br />combustion are also greatly reduced. Electric construction equipment is available commercially from <br />companies such as Peterson Pacific Corporation,39 which specialize in the mechanical processing <br />equipment like grinders and shredders. Construction equipment powered by hybrid-electric drives is <br />also commercially available from companies such as Caterpillar.40 For example, Caterpillar reports that <br /> <br />34 Diesel Emissions Reduction Program (DERA): Technologies, Fleets and Projects Information, available <br />at:http://www2.epa.gov/sites/production/files/2015-09/documents/420p11001.pdf <br />35 Alternative Fuel Conversion, EPA, available at: <br />https://www3.epa.gov/otaq/consumer/fuels/altfuels/altfuels.htm#fact <br />36 Cleaner Fuels, EPA, available at:https://www.epa.gov/verified-diesel-tech/learn-about-verified-technologies- <br />clean-diesel#cleaner <br />37 Retrofit Technologies, EPA, available at:https://www.epa.gov/verified-diesel-tech/learn-about-verified- <br />technologies-clean-diesel#retrofit <br />38http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf <br />39 Peterson Electric Grinders Brochure, available at:http://www.petersoncorp.com/wp- <br />content/uploads/peterson_electric_grinders1.pdf <br />40 Electric Power Products, available at:http://www.cat.com/en_US/products/new/power-systems/electric-power- <br />generation.html
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