First Name | Ernest |
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Last Name | Wipf |
Email Address | wipf@pacbell.net |
Affiliation | |
Subject | Proposed Regulations by the ARB |
Comment | WIPF CONSTRUCTION 1300 HASTINGS RD./P.O. BOX 234 UKIAH, CA 95482 PHONE (707)462-8741 FAX (707)462-5409 DECEMBER 11, 2008 AIR RESOURCES BOARD MEMBERS WE ARE WRITING YOU IN REGARDS TO THE OFF ROAD AND ON ROAD HEAVY DUTY DIESEL ENGINE REGULATIONS THAT ARE PRESENTLY BEING PROPOSED FOR ADOPTION. AS A SMALL EXCAVATION AND TRUCKING CONTRACTOR, WE WILL BE HEAVILY IMPACTED BY THESE REGULATIONS. THE CAPITAL INVESTMENT REQUIRED TO MEET THOSE REGULATIONS, WITHIN THE TIME FRAMES OUTLINED, CANNOT BE SUPPORTED BY MOST COMPANIES. ONLY THE LARGE MULTI-STATE OR MULTI-NATIONAL COMPANIES WILL BE ABLE TO SURVIVE. THEY WILL BE ABLE TO ACCOMPLISH COMPLIANCE, ONLY BY SHIPPING THEIR OLDER TRUCKS AND EQUIPMENT TO OTHER STATES TO WORK, REPLACING THIS EQUIPMENT WITH NEW IN CALIFORNIA. SMALLER CONTRACTORS WILL NOT HAVE THE ABILITY OF HAVING THEIR OLDER EQUIPMENT SUPPORT THEIR NEW EQUIPMENT AS WE HAVE IN THE PAST. THIS WILL CREATE A LARGE COMPETITIVE ADVANTAGE FOR THE VERY LARGE CONTRACTORS, PUTTING MOST SMALLER CONTRACTORS OUT OF BUSINESS. WE HAVE BEEN IN BUSINESS FOR 20 YEARS, AND BY BEST CALCULATIONS, WE WOULD HAVE TO PUT 100% OF OUR NET PROFITS INTO RETROFITTING OR REPLACING OUR EQUIPMENT FOR THE NEXT 20 YEARS TO BECOME COMPLIANT. THE REGULATIONS, AS PROPOSED, WILL REQUIRE US TO BE COMPLIANT IN LESS THAN 7 YEARS. HOW CAN WE BE EXPECTED TO REMAIN IN BUSINESS WHEN OUR RATES WOULD NEED TO TRIPLE IN ORDER TO PAY OFF THE CAPITAL INVESTMENT THAT WOULD BE REQUIRED, WHILE THE VERY LARGE CONTRACTORS WILL BE MOSTLY REPLACING THEIR EQUIPMENT AS USUAL, MOVING OLD PIECES OUT OF STATE. COMPANIES SUCH AS OURS REQUIRE OUR OLDER EQUIPMENT TO SUPPORT THE NEW PIECES WE PURCHASE, IT IS THE ONLY WAY WE CAN COMPETE AND SURVIVE. PAGE 1 OF 2 IN THE HANDOUT THE CARB HAS BEEN DISTRIBUTING AT THEIR PUBLIC MEETINGS, THERE IS A PIE-CHART THAT SHOWS WHERE THEY BELIEVE OUR EMISSIONS FROM VEHICLES COME FROM. THIS CHART SHOWS THAT 20% COMES FROM HEAVY DUTY, WHICH INCLUDES GAS ENGINES AND MOTOR HOMES WHICH ARE NOT IN THESE REGULATIONS. IN THEIR STATISTICS THE BEST IMPROVEMENT IN EMISSIONS FROM VEHICLES THAT MAY BE ATTAINED THROUGH THESE REGULATIONS MAY BE 10 – 15% REDUCTION. ANOTHER PIE CHART SHOWS THAT OF ALL OPERATIONS IN CALIFORNIA, TRANSPORTATION CREATES ONLY 38% OF ALL GREENHOUSE GAS EMISSIONS. SO, BY ENACTING THESE REGULATIONS YOU WILL BE REMOVING 10 TO 15% OF 38% OF ALL GREENHOUSE GAS EMISSIONS. THIS MAY BE A MONUMENTAL REDUCTION OF MAYBE 3.8 TO 5.7 PERCENT. WE DON’T BELIEVE THIS IS A PERCENTAGE REDUCTION THAT WOULD WARRANT PUTTING MOST SMALL CONTRACTORS OUT OF BUSINESS, PUTTING THEIR EMPLOYEES OUT OF A JOB AND CREATING ECONOMIC CHAOS IN CALIFORNIA. WE WOULD PROPOSE A PLAN TO BUILD MORE MASS TRANSIT, GIVE PEOPLE TAX CREDITS FOR UTILIZING MASS TRANSIT, REMOVING MAYBE 10 TO 25% OF THE CARS OFF THE ROAD. THIS WOULD YIELD A 7.4 TO 18.5 PERCENT NET BENEFIT IN GREENHOUSE GAS EMISSIONS. THIS PLAN WOULD ALSO GENERATE CONSTRUCTION JOBS IN OUR SAGGING STATE ECONOMY, INJECTING CAPITAL HELPING US TO UPDATE OUR FLEETS. IN CLOSING, WE HAVE BEEN RESEARCHING RETRO-FIT DEVICES. THE DEVICES THAT ARE PRESENTLY AVAILABLE ARE NOT ABLE IN MOST CASES TO NOT COMPLICATE THE OPERATION OF MOST EQUIPMENT THAT THEY WILL BE PLACED ON. WHY DON’T WE ATTACK OUR GREENHOUSE GASES FROM ANOTHER ANGLE, AND ALLOW OUR TRUCKS AND EQUIPMENT TO CYCLE OUT AS AGE AND WEAR REQUIRE THEIR REPLACEMENT AS IT WAS DONE WITH PASSENGER VEHICLES. IT SEEMS TO US THAT BETTER PLANS CAN BE FORMULATED, ALLOWING SMALL CONTRACTORS AND THEIR EMPLOYEES TO CONTINUE WORKING, WHICH IS WHAT WE BELIEVE PAY YOUR SALARY. THANK YOU FOR YOUR CONSIDERATION IN THIS MATTER, HOPEFULLY IT IS NOT TOO LATE TO SAVE US FROM THE ECONOMIC DEVASTATION THESE CARB REGULATIONS WILL LEAD TO. SINCERELY, ERNIE WIPF WIPF CONSTRUCTION PAGE 2 OF 2 |
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Date and Time Comment Was Submitted | 2008-12-11 09:43:17 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.