First Name | Gary |
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Last Name | Miles |
Email Address | gmiles@albay.com |
Affiliation | Albay Construction Co. |
Subject | Off road Diesel vehicles |
Comment | I have a number of problems with the SOON program, the biggest of which are: 1. The definition of a small fleet should not include any dollar volume limits. Contratactors vary greatly in how they do work. One contractor could do a huge dollar volume but own no equipment. Another contractor might not do much dollar volume but does operate many thousands of HP in old, dirty equipment. 2. Because small companies tend to own the older equipment, you are discriminating against the small business owner. At least give him a chance to slowly replace old equipment with newer equipment over a period of 10 years. 3. Right now you are requiring us to repower or replace equipment with engines that won't comply with your regulation's pollution requirements because compliant engines are not yet available. As I said, contractors expect to get 20 years out of a piece of equipment, You are making us spend money on equipment that will become noncompliant in less than 10 years. It is a waste of money. Do not penalize us until we have a way to satisfy your requirments. |
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Date and Time Comment Was Submitted | 2008-03-04 08:34:37 |
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