First Name | Joyce |
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Last Name | Waters |
Email Address | wci@willitsonline.com |
Affiliation | Waters Construction, Inc. |
Subject | Proposed Regulation for In-Use Off-Road Diesel Vehicles |
Comment | • The value of our business is tied up in our fleet of construction equipment. To meet CARB’s requirements for newer equipment, we will have to sell existing equipment which, with the new regulation, has lost most of its value. • The engines we need to purchase to be in ultimate compliance with this rule do not exist in the market today and won’t for at least another six years. Due to this, we will be forced to spend hundreds of thousands of dollars to retrofit equipment that in less than ten years we will have to turn around and replace. • 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. With this rule CARB, for the first time, is regulating the consumer of equipment rather than the manufacturers. What makes more sense, as with the auto industry, the new equipment should be phased in with the manufacture of said equipment. • Basically these requirements will put us out of business and our investments, some of which were made with our retirements in mind, will be worthless. |
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Original File Name | |
Date and Time Comment Was Submitted | 2008-01-02 13:40:36 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.