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Comment 19 for Verification Warranty In-Use Compliance (verdev2008) - 45 Day.

First NameJerry
Last NameFerdun
Email Addressjerry@brockconstruction.com
AffiliationG & L Brock Construction. Inc
SubjectOn-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.

Attachment
Original File Name
Date and Time Comment Was Submitted 2008-01-23 09:13:48

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