First Name | Cash |
---|---|
Last Name | Benton |
Email Address | cashscca@sbcglobal.net |
Affiliation | SCCA |
Subject | Re: Changes to the portable engine registration program |
Comment | March 20, 2007 Dr. Robert Sawyer, Chairman California Air Resources Board 1001 "I" Street Sacramento, CA 95812 Re: Changes to the portable engine registration program Dear Dr. Sawyer: The Southern California Contractors Association (SCCA) represents the interests of union-signatory heavy construction contractors in the 12 southern-most counties in our state. We have been actively involved in air quality issues on behalf of our members throughout our 34-year history and are a founding member of the Construction Industry Air Quality Coalition (CIAQC). Among our concerns is the current state of the portable engine regulations. While most of our members have complied with the portable engine registration program (PERP) requirements, we have new companies who joined our association specifically to get our assistance in dealing with your regulations. To that end, we are requesting three specific changes to the proposed amendments to the regulations: 1. Reopen the PERP to allow registration of equipment with Tier 0 engines. This category of equipment makes up the majority share of portable equipment in our region and the state. While your agency has enrolled some 25,000 engines in the PERP, this represents less than 15 percent of the total universe of this equipment class. 2. End the resident engine requirements established in December 2006. This was an ill-conceived notion when introduced. One of the goals of the portable regulations is the elimination of Tier 0 engines by December 31, 2009. This goal will go unrealized unless contractors can bring used certified engines into the state. 3. Lower the punitive fees for registering older equipment. Our reading of the legislative intent of this program gives you authority to establish fees for the operation of the program, but there is no authorization for punitive financial acts. If your goal is voluntary compliance with the regulations, these outrageous fees will inhibit otherwise willing participants from enrolling in the PERP. SCCA is a willing participant in the effort to clean California’s air, but we recognize that our contractors are not responsible for the engines that power their equipment—that honor goes to the federal Environmental Protection Agency and the equipment manufacturers. The current state of the portable regulations is a clear-cut case of punishing the innocent. We ask that the Board enact the changes we have requested. Respectfully Submitted D. Cash Benton Executive Vice President, SCCA |
Attachment | www.arb.ca.gov/lists/perp07/18-letterto_arb.doc |
Original File Name | Letterto ARB.doc |
Date and Time Comment Was Submitted | 2007-03-20 15:13:21 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.