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Comment 22 for In-Use Off-Road Diesel-Fueled Fleets (inuse2010) - Non-Reg.

First Namerobert
Last Namedorazio
Email Addressmarym911@aol.com
Affiliationbusiness owner off road
Subjectcomments on off road rule
Comment
The proposed revision is insufficient to address the horrid
economic condition.
a.  One suggestion is to integrate the various rule making
categories - please.  To comply with the truck rule and the offroad
rule as separate entities does not allow the business owner to
select and prioritize the most economically viable technology.  
b.  Use of level 2 devices for 'some period of time' in lieu of
administratively rejecting these devices shows no regard for
existing technology which can reduce the amount 60% for far less
cost and effect on the engine than the 85% regulatory mandate. 
This proposal would be in keeping with the theme of the proposed
revision.  This technology was in fact allowed for solid waste
haulers but is not allowed for any other category.  This technology
would allow older machines to have some value which could be used
to climb the ladder to the newer technology.
*
The consideration of any of these items is kindly appreciated to
encourage the future use of the new technology mandated for new
equipment.
Sincerely,
Robert Dorazio

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Date and Time Comment Was Submitted 2010-03-18 16:32:46

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