Comment Log Display

Clarity and Comprehensibility: The regulation is too complex and
lengthy: we do not fully understand it or its effect on our fleet.
Before this regulation, we bought equipment based on what we needed
to do our work. We will have to hire consultants to tell us what we
can and must buy and when we will need to replace, retrofit, or
repower what have. 
Capital-Intensive Industry: The value of our business is tied up
in our fleet of construction equipment. To meet ARB’s requirements
for newer equipment, we will have sell existing equipment. 
Rule Forces Downsizing of Capability: Because newer equipment
costs more than our older equipment, ARB’s rule will force us to
downsize our operations. Downsizing will limit our ability to
perform on contracts and require us to take longer on the projects
that we win. 
Unfair Retroactive Requirements: When we made our purchasing
decisions and other investments, we relied on the standards that
applied to us at the time. It is unfair to require us to retrofit
or replace equipment that was legal when we bought it. ARB should
regulate the manufacturers, not consumers. 
Cost Pass-Through: For us to win contracts, we cannot simply pass
on the costs of equipment purchases to our customers. We have to
absorb a significant portion of our own expenses. Increasing our
expenses will overwhelm our narrow profit margin.