Comment Log Display

As a small business owner, and employer of 25 people, this ruling
while well intended will wreak havoc on our construction industry.
 In order for this ruling to be effective, the following items need
to be addressed and answered prior to the implementation of the
laws:

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. 

Cordially,

Mark Garrison
MG Constructors & Engineers Inc.
15650 Vineyard Blvd., Suite A, #232
Morgan Hill, CA 95037