First Name | Robert |
---|---|
Last Name | Valentine |
Email Address | bvalentine@valentinecorp.com |
Affiliation | Valentine Corporation |
Subject | Off-Road Diesel Regulations |
Comment | Valentine Corporation is a General Engineering Contractor which has been performing public works infrastructure construction in California since 1964. We have the following comments concerning your proposed off road equipment regulation: 1) The regulations is onerous and burdensome to the constructions industry and will cost us a ton of money in equipment retrofitting and liquidation. This is plainly unfair and punitive -- we purchased our fleet in full compliance with the law at the date of purchase. DO NOT change the rules after the fact unless you (the State)are willing to foot the bill! 2)CARB SHOULD BE REGULATING THE EQUIPMENT MANUFACTURERS AND NOT THE END USERS WHO BOUGHT THEIR EQUIPMENT LEGALLY!!! Standards should be established for new equipment and existing old equipment should be grandfathered in so that it can be used without retrofitting for its useful life. Eventually, all equipment will be compliant as older equipment expires. Regulate the manufacturers and the soon enough california contractors will own and operate compliant equipment. This seems logical, which is something that can not be said of your prosed regulation. 3) Small contractors will be adversely impacted by the proposed regulation -- we rely on used equipment and are the ones who will be likely stuck with the retrofit bills for our older fleets. Why is CARB penalizing small business? 4) We have read your proposed regulation and it is lengthy,and unnecessarily confusing. If you are going to implement a new regulation, please keep it concise and simple. Dumb it down if you have to, but we don't need more confusing technicalties placed upon our business, nor do we think it money well spent to have to hire a consultant to interpret your regulations. Sincerely, Robert O. Valentine, P.E. President |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2008-01-03 16:09:53 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.