First Name | Nicholas |
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Last Name | Pinette |
Email Address | nicholas@offshorekayak.com |
Affiliation | |
Subject | off road diesel equipment |
Comment | People, I fully appreciate the efforts of the State of California to improve air quality, especially in those areas where pollution tends to concentrate. Requiring smog control devices on automobiles with gas engines was a positive move that set the standard for the entire country. Diesel engines have long been exempt for all the wrong reasons. Diesel engines should also have clean air engineering from cradle to grave and I support legislation that will make it so. I do not, however, support diesel engine retrofit requirements that adversely effect small business. These requirements end up being draconian and are designed to force older equipment out of use. I especially find the proposed off road diesel requirements far too broad and a significant hardship for small farmers, contractors and business people. After too many years letting the manufactures get by without significant compliance, the State is now picking on the small man because it thinks it can. Just as the smog control regulations exempt older cars, the diesel regulation rules should take into consideration the difficulties of compliance for owners of older equipment. The rules, as proposed, would force the retirement of many pieces of equipment that get limited use, but otherwise are extremely important for their owners when they are needed. The fact of the matter is, that most any machine eventually it breaks down, and the economics of the situation leaves it rusting in the field or dragged off to the metal scrapper. Old tractors and equipment are just too expensive to repair and their age often does not justify the costs. Businesses and farmers who use diesel equipment every day, renew their equipment for the associated dependability, improved performance and comfort the new units offer. The used equipment market is for those who can’t afford the new technology and can get by with the limited service of an older machine. Businesses that put a lot of hours on their equipment, typically run newer machines because they cannot afford the down time associated with older units. Granted, the air quality in metropolitan areas and parts of the central valley cannot bear the added pollution from any source, let alone diesel equipment. In other rural areas of California, there is no need to require any measures. In areas where the pollution levels are significant, I believe there is a limit to how far government should go and who should be impacted. Criminalizing activity that is necessary to continue to operate a small farm or business enterprise profitably is counter productive, if not onerous. Costly retrofits, the design of which is intended to retire older equipment would make for extreme hardship for those already challenged to make a living in this economy. If the technology existed for a simple bolt-on tailpipe solution similar to a spark arrestor or muffler, there might be a way for some to comply, but requiring a complex and expensive retrofit to equipment that has little resale value is ridiculous and leaves small operators with no choice except to become scofflaws. Before any punitive regulations are put into place, other measures should be promoted. Perhaps making biodiesel more readily available and requiring its use on older equipment would be another option. But in the end, the improvements in technology should be required at the manufacture of equipment, whether it is a lawn mower or a back hoe. The older equipment will fall out of use as time goes by. -Nicholas Pinette 454 McAuley Street Oakland, Calif. 94609 |
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Original File Name | |
Date and Time Comment Was Submitted | 2008-01-07 18:55:35 |
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