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Comment 1 for In-Use Off-Road Diesel-Fueled Fleets (inuse2010) - Non-Reg.

First NameSteve
Last NameMcDonald
Email Addresssmcdonald@papemachinery.com
Affiliation
SubjectOff-Road Regulation
Comment
All,
I believe we can all agree on the fact that the air quality in
California (particularly the central valley and the L.A. basin) is
of great concern to everyone living in the state. However, what we
find ourselves disagreeing on is the time frame required to clean
up the air quality in the state and the economical feasibility of
the clean up. 
The fact is that we as a state and a country have been polluting
our air since the turn of the century (at the beginning of the
industrial revolution) and for anyone to think that reversing 100
years of disregard for air quality can be economically achieved in
a span of  15 years is simply absurd. 
I understand that there is a blatant disregard for accountability
at the state level and there has been for decades. After all you
have a job. Legislators must become responsible for their actions.
When we allow Mary Nichols to infer that the construction industry
was the cause of the economic down turn of California. There is
something wrong with the system. Biases have no place in our
legislature. Legislators need to look past the end of their noses
and their personal opinions and make an attempt to understand the
impact that their decisions will have on all of the people,
economics, and industries of this great state. Your decisions
affect all of us and you can not make it better for one group
without an impact on another group. 
Every home, business, piece of infrastructure (including the
building you are sitting in) and individual in this state relies on
the diesel industry in one form or another. By crippling the diesel
industry you cripple the ability for the state to grow and growth
equates into economic prosperity. With out economic prosperity and
growth our state can not meet its fiscal responsibilities and this
is why we find ourselves in a state budget crisis. With out the
diesel powered equipment to build infrastructure there would be no
hospitals, roads, or food on the shelves. Even the State Capital
Building and Mary Nichols relies on the services provided by the
diesel industry. 
Regardless of the science involved to determine how much of an
impact PM10 has on the respiratory health of a smoker or non-smoker
in Sacramento vs. in Orange CA. We have a real problem with the air
quality in specific areas of the state and it needs to be corrected
for the overall health benefit to everyone. However, you as
legislator also have a fiscal responsibility to stay within
budgetary constraints while insuring the health, safety and
prosperity for all of the states inhabitants. The state requires
taxes as a source of income and without jobs; growth and prosperity
the tax base that the state relies on, will and has diminished. 
There has been a tremendous reduction in the construction industry
as a whole and that reduction equate to a loss in tax revenues. As
anyone with a high school education can tell you; when your income
drops, so too must your spending. So, why is it that our
legislators are having such a difficult time grasping the basics of
economics and how it affects business?
The answer is simple. There are two completely different economic
thought processes at work. The contractor will not spend money that
he does not have or can not foresee earning based on his business
plan and forecasting. On the other hand, just look at the budgetary
mess created by the irresponsible individuals that run our state
legislature. CARB and all of our state legislators must begin to
run the state like a business and come to the realization that
their way of doing business just does not work for the industries
that they rely on for their income and which they are attempting to
control. Why is it that most people can all run their households on
a budget but, when it comes to our governmental entities those same
people can’t seem to apply the most basic of economic standards
that they use every day at home?
I ask you. Does anyone really need to prove that they have had a
reduction in hours on their equipment or production? Look at your
state tax revenues. Take a drive through one of the many
developments that are half finished. Check the statistics on
California housing starts. Call a local building permit office. It
should be obvious!
There are several very intelligent people in the construction
industry and many of them have some very good ideas as to how to
overcome our air quality problems while continuing to grow our
economy (the AGC and the EUCA are great source). I would suggest
that you begin looking for solutions to the economic side of the
issue or you won’t need to focus on a solution to air quality.
One idea is to make the CARB emissions regulation a living
document that fluctuates requirements based on the Off-Road
Emissions Model. This would allow the industry to contract and
expand in step with economy while keeping PM, NOx and CO in check
with Federal EPA requirements. Also, CARB has spent a tremendous
amount of time and tax payer money to create a data base that can
supply factual data (fleet sizes and make up, PM, NOx and CO
certified emission output) that the Off-Road Model can use to make
accurate calculations rather than estimates and EPA standard limits
that end up producing results that can be argued by anyone on
either side of the issue. A living document will also allow for
changes in our environment for both things that we can control (ie.
PM, NOx, and CO out put) and things that we can not control (ie.
wild fires, rain fall, winds and even off-shore flow). 
We need to come to a logical solution on those things that we can
control while taking into account those which we can not and make
the solution viable for everyone concerned. The current regulation
does not accomplish this. It is base on assumptions and out dated
criteria and it does not account for fiscal changes in our economy
from year to year.
Thank you,
Steve McDonald

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Date and Time Comment Was Submitted 2010-03-05 13:49:32

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