First Name | Thomas |
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Last Name | Thornton |
Email Address | thorn@undergrnd.com |
Affiliation | Underground Construction Co., Inc. |
Subject | PERP Registration Requirements |
Comment | The PERP program is both confusing and cumbersome. I have tried to register 4 pieces of equipment with the ARB,and after using and following the online instructions, all four applications were returned with multiple additional requests for information. Those who are employed full time by the ARB may know and understand the confusing acronyms and rules, but those of us that are affected by them rarely have a lot of available time that it takes to read and hopefully understand them. I suggest that a much simpler approach be implemented; that all machines have a phase out from the date of manufacture. In our company, much of our equipment is depreciated over a period of 15 years. I would suggest that equipment be allowed use for 15 years or 7,500 hours (which ever occurs first), after which it must either be re-powered with a compliant power source or scrapped. I would also suggest that any rule be implemented state wide, avoiding special rules from the 35 air districts. Having individual Air Districts and thier rules only adds to the chaotic state we must operate in. We all want clean air and a healthy environment, but we also need to have a healthy economic state. We must work towards crafting rules that encourage willing participation and the success of our businesses that drive our State's economy. After submitting message (Comment 12) minutes ago, I realized that I should have shared some data with you. Our company has 51 air compressors in our fleet, powered by diesel engines of up to 80 hp. Of these compressors, 23 are powered by Tier 0 engines that can not be registered (6 have 51 hp engines, the rest have 80 hp). These compressors have 500 to 3,000 hours of use recorded on their hour meters, with many years of usefull life remaining. Since we can no longer lawfully use these compressors in this state, the cost of replacement will be $11,811 each, for a total of $271,657.00. Obviously, this is a significant financial burden placed on our company. |
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Date and Time Comment Was Submitted | 2007-03-19 14:19:09 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.