First Name | Jerry |
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Last Name | Ferdun |
Email Address | jerry@brockconstruction.com |
Affiliation | G & L Brock Construction. Inc |
Subject | On-Off Road and PERP PM compliance kills business |
Comment | The cost and scope of these regulations will strangle small businesses and put thousands of California workers out of jobs in an already collapsing economy where jobs are hard enough to get, let alone keep. Because: 1. To force a confiscatory and extreme registration cost to portable diesel powered equipment built in 1997 or older, regardless of horsepower, will remove the machines from service as the state wants but will force small family owned businesses into severe financial hardship in order to comply or worse yet out of business completely. 2. This retroactive regulation/taxation of assets by the CARB upon equipment owned by California businesses is nothing more than extortion. Instead of company owners growing their businesses we are being forced to eliminate good operational equipment and shrink the size of our fleet/company which in turn eliminates more jobs and taxpayers. 3. The details of CARB’s plan to regulate and retroactively tax and control fleets is obviously not well known or understood by the general public. The proof is here, notice the small number of comments posted and the number of attendees to the seminars. 4. Complexity of compliance. The voluminous complexity of the details of how CARB plans to regulate PM is impossible for the lay person to comprehend. If a plan is implemented it MUST be simplified and it MUST be oriented more directly if favor of and structured to the owners of the equipment. After all we are the ones paying for this. 5. Forcing costly regulations and expensive un proven cutting edge PM technology is as if the entire state government was standing in front of all us business owners with a loaded machine gun and an endless supply of ammo and saying comply or close! This plan is essentially killing businesses and families statewide. We all know specialized technology in its infancy is expensive in acquisition, maintenance, training of technicians and repairs. This technology is not exempt from this rule. Manufacturers of the PM reduction technology should be treated just like a drug company and forced to bear the expense of R & D and proving its safe and reliable performance. We contractors should not be the financiers or lab rats to the State or manufacturers. Once the technology is tested, examined and proven reliable we, as the end user can choose to purchase what fits our needs, not what is forced upon us. Until a broad based and reliable PM exhaust retrofit is shown and proven to achieve the Tier 4 or higher desires of the state, there cannot be any forced compliance. |
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Date and Time Comment Was Submitted | 2008-01-23 09:13:48 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.