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As a member of ORAIG I have watched this regulation become more and
more complicated with more and more loopholes for national
companies. 

The legislature complicated the process by putting our emissions
on a "credit card" with emissions come due in a couple years.
The 2005 data used was extremely off the mark as far as emissions
and fleet sizes and how diesel in ambient air acts in California. 


Bay Cities Paving and Grading is fleet #68.  One of the first
private fleets and the first fleet to install EIN on our equipment.
 

I have been very active with the Off-road group over the last two
years.

Our company has spent $250,000 without government assistance to be
in compliant by March 1, 2010.  By giving taxpayer money to my
competition or using fines on companies that are in California
trying to survive, you are not helping the private sector in any
fashion.

We have 104 pieces of construction equipment.  38 of those pieces
we keep 6 years or less and trade in on new.  27 of them are
vibration compaction machines that no DPF manufacturer will or can
make a unit that will survive the vibrations these machines create
under daily work loads.

We have only 8 older large hp machines left in our fleet now.  We
use them more than 100 hours a year but less than 500.  In good
times we might have traded the 1990 machine in for a 2003 machine
and upgrade.  With the new regulations this does not work
financially and new sure does not work.

My fleet is 7 years old with a 7.1 average age engine. There is
14,277 horsepower in our fleet.

for 2010 our PM number is .40 regulations said it had to be .34
for 2014 the PM number is .16 per the regulation.  I will be lucky
to be at .25 by then.

Along with the in-use on road rules, where three of my twenty
three trucks could be fitted with a DPF, we are going to be either
out of compliance with CARB or out of business by 2015.
Our truck fleet average age is 9-years-old.

On my own, using my own funds, I am going to Europe to investigate
emission solutions. While doing my research for the trip, I have
found NO COUNTRY is using DPFs as a solution except in the mining
and tunneling industry.  SCR and NOx filters are common. 

Two weeks talking to contractors, equipment dealers and rental
companies in Germany, Switzerland and England should give me a good
feel for how Europeans are dealing with air quality regarding
diesel PM and NOx along with ozone.  We won't get into CO2 as that
is beyond my understanding of atmospheric science. 

I have promised the Off-road department a report upon my return on
May 3rd, 2010.

As a Heavy-Civil Engineering equipment manager for 24 years I can
help CARB to come to a workable solution for California air quality
and the survival of family owned construction companies in the
state.

As the rules are now, there is no survival method available for
companies that are made up of common construction equipment.

I have a whole file cabinet of data on emissions at my office.

To the EO: I will work with any member of your choice except Eric
White.  

Eric, if you read this, I truly believe you are the political type
individual that is using your unmoveable position regarding these
regulations to try and move yourself up the ranks at CARB. 

I don't trust you to be open-minded to the California contractor
who is trying to compete in the marketplace without all the
handouts your department are giving my competition.

We can build California and keep the air clean. We need to do it
in a better way.  There are several of us in California that can
help if politics and special interests don't get in the way.

At the Citizens of California's service.

Rod Michaelson