Submitted Comment Name Stefan Bokaemper Affiliation Sensirion Connected Solutions, Inc. Subject Alternatives to the Discussion Draft EDS Performance Standards (17 CCR §§ 93500–93506) — Sensirion Connected Solutions Message Sensirion Connected Solutions, Inc. (SCS) respectfully submits the attached comment letter in response to CARB's solicitation of alternatives to the Discussion Draft Performance Standards for Continuously Operating Emissions Detection Systems (proposed 17 CCR §§ 93500–93506, dated January 5, 2026). The attached letter contains 16 comments addressing the monitoring process - covering standardized dispersion modeling and sensor siting, within-hour plume variability, near-source applicability, condition-responsive alert thresholds, contemporaneous background determination, sensitive-receptor coverage, detection frequency, technology-neutral sensor qualification, meteorological measurement, the response and leak-identification sequence, corrective action and disposition, data storage and availability, quality assurance and audits, plan updates and reporting, plan format and review, and scope and definitions. Each comment identifies the relevant provision, explains the issue, recommends an alternative, evaluates its protection and cost effects, and proposes regulatory language. Appendix A provides the consolidated clean and redline regulatory text against the January 5, 2026 Discussion Draft. These alternatives are intended to provide the same or greater health protection at lower cost. We would welcome the opportunity to discuss the supporting technical analysis with CARB staff. File Upload (i.e., Attachments): scs_sb1137_comment-final.pdf N/A
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