Ryan Scott-Loki opposes 561-A and disputes regeneration claims

How's that?

Yep.

Wonderful.

Good afternoon, Chairman Gennaro and members of the committee.

My name is Ryan Scott-Loki.

I'm a former delivery driver with more than 17 years of firsthand experience in the operation and management of commercial motor vehicle fleets.

Today, I work as an environmental consultant.

I help small businesses understand city, state, and federal environmental regulations.

Learn how to comply with these regulations, and how to resolve outstanding violations.

I am also an active and regular participant in the city's civilian air, noise, and sanitation enforcement programs.

I have submitted and documented over 5,000 complaints in my experience.

These experiences give me a unique perspective.

I see firsthand how these enforcement programs affect the small businesses, commercial drivers, civilian enforcers, and the environment.

Based on that experience, I oppose Intros 11A, 561A, 562, and 869A.

I support Intros 48 and Resolution T2026-2662.

I did want to speak about Intro 11A, but we're very limited on time.

So let me just focus on 561A and most importantly, the regeneration arguments made by the prior panel.

For starters, in 561A, the most problematic provision proposed is the proposed exemption for diesel vehicles undergoing diesel particulate filter regeneration.

That's also known as a DPF regeneration.

The statements of fact, or sorry, the misstatements of fact in the last panel are abhorrent.

I assume the provision is well-intentioned, but it's simply unworkable in reality.

With my extensive experience, over 17 years of firsthand experience, I can only estimate whether a diesel vehicle is undergoing regeneration while outside the vehicle at maybe a 70% accuracy rate,

at least while observing it outside the vehicle.

The smaller and newer the vehicle, the more difficult that determination becomes.

If someone with my level of experience cannot reliably identify regeneration from outside a vehicle, I have no idea how we could reasonably inspect an oath hearing officer who may have little or no comparable experience with diesel engines to make that determination.

I'm happy to answer questions on how the actual process for generation works, but vehicles are absolutely able to regenerate in both an active and a passive method.

They do not have to pull over in most cases to be able to regenerate.

They are able to continue doing it while they drive.

The statement that they have to pull over because there's a magical light or something like that is asinine.

It is true that vehicles and diesel vehicles may have to have regeneration done at a particular time, but not in the manner that they described.

Yeah, you made that point.

I appreciate you being here.

I appreciate all of your years of experience and the experience that you bring to bear on this panel.

With that, I'll...

Call the next witness.

Both witnesses.