First Name | Weldon |
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Last Name | Birch |
Email Address | mwelb@calwestcci.com |
Affiliation | CSDA, CMCA, EUCA |
Subject | Off Road Equipment Diesel Regulations |
Comment | I received your notice regarding the additional 15 day notice for public comment about the proposed regulation. I went through the entire 65 pages and then took 4 aspirin to get rid of the headache! These rules are so complicated that no one will go along with this because it is almost impossible to understand. These were not written by someone at CARB and no one in the private sector is going to be able to negotiate through all of this without hiring outside help! There in itself is your first point of failure! You have written requirements that will take a genius to interpret so that means most will not comply! As it stands, you are still targeting the highest wage earners in this State and those most affected by the regulations will be most affected by the loss of jobs. The tricle down effect will be felt all all levels with the decline in sales of new equipment, the loss of tax revenues for same, the loss of construciton jobs and the loss of tax revenue from same and lastly, the high cost of complying will force many jobs to go underground, done by fly-by-night contractors who hire illegals to do their work! I just recently came back from a week at the World of Concrete Show in Las Vegas. The main topic of discussion with almost every equipment manufacturer or dealer there was this regulation and how it was going to hurt or put them out of business. Many of the manufacturers are simply not going to sell equipment in California and your used equipment will become worthless on the resale market! In other words, you are going to put those dealers, their sales staff, mechanics & truck drivers out of work. In turn, you will lose sale tax revenue abound, un-secured property taxes for new equipment that won't be purchased and have to deal with growing unemployment in the construciton field! Not a very pretty picture for those who work for a State Government that is 14 billion dollars in the red this year and will be for the forseeable future! You need to get away from making retro-active requirements on used equipment and focus on what we can do with the new technology coming out, not crucify what was acceptable just a few years or months ago. Working to improve the quality of emission standards over the next 15 years in new equipoment will go a long way in cleaning up our already, very clean air! That will also preserve the jobs and tax base that you so badly need. If you go ahead with this as planned, you can kiss those jobs goodby and probably many State level jobs too because you won't be able to pay for them. As a contractor with 32 years of business building experience and with 70 employees, I cannot afford to reconstruct our equipment and trucks to meet your standards without accruing enormous debt. So if they are inacted as you propose them, I will just start shutting down our company and let those jobs and quipment just go away. I cannot afford to stay in business just to work to pay for senseless over-regulation! Weldon Birch, Pres. |
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Date and Time Comment Was Submitted | 2008-02-11 14:30:06 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.