First Name | Erbie |
---|---|
Last Name | Daw Jr. |
Email Address | eddamar@sbcglobal.net |
Affiliation | |
Subject | OFF ROAD DIESEL REGULATION |
Comment | Dear Members of the California Air Resources Board: The California Air Resources Board (CARB) adopted a flawed off-road diesel regulation this summer that will have a profound, negative impact on California's infrastructure rebuilding efforts, the health of the state's construction industry and its overall economy. Construction contractors and workers want these regulations to work for everyone, however this rule lacks clarity, does not take into account the availability of capital in the industry or the advancement of engine technology, will result in a downsizing of construction firms and loss of construction jobs, contains unfair retroactive requirements and does not accurately reflect the economics of our business. More specifically, this regulation is flawed for the following reasons: 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 CARB's requirements for newer equipment, we will have to sell existing equipment. This is like a retailer being forced to sell its building and buy a new one. If this law is passed I estimate the size of my company will be reduced by 70%. This will create a loss of jobs and reduce my bonding capacity in the process which in turn limits the jobs I am able to bid on. The snow ball effect could possibly put me out of business. Example of the way this has worked for me so far: A few years back I purchased (4) four 637 scrapers for $60,000 each a total of $240,000 dollars. I created 4 jobs in the process with earnings between 50 to 70 thousand dollars each. Due to the possibility of this law going in effect I sold (2) two of these machines and figured to up grade the other (2) two machines. The first machine I received a grant for $150,000 to replace (2) two engines that was in the machine. The total cost ended up being $350,000 to rebuild a machine I payed $60,000 for. The hourly rate for this machine stays the same as the second 637 that I decided not to upgrade, it's just not cost effective. I can not sell this machine out of Ventura County which strategically reduces its value. If I sold this machine today I would be lucky to get $100,000 for it. So just to recap I went from 4 machines to 2 machines soon to be down to one machine, 2 jobs lost at $50,000 each. $200,000 out of my pocket with no way to recover before the law changes again. THIS LAW IS TOTAL MADNESS. Erbie Daw Jr. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2008-01-08 13:28:24 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.