First Name | Jeb |
---|---|
Last Name | Stuart |
Email Address | jebstuart@sbcglobal.net |
Affiliation | CIAQC |
Subject | CIAQC Comments to ARB on Amendments to PERP |
Comment | March 19, 2007 Dr. Robert Sawyer, Chairman California Air Resources Board 1001 “I” Street Sacramento, CA 95812 Dear Dr. Sawyer: A great deal has been written concerning the Air Resources Board’s portable equipment program and the recently adopted emergency regulation disallowing registration of the 6,000 to 10,000 Tier 0 engines after the effective date of that regulation. As a former Executive Officer of the South Coast Air Quality Management District, I can appreciate the frustration regulators felt trying to persuade owners for several years to register their portable equipment so it could be operated legally, and I can understand their compelling desire to punish those owners for failing to comply by permanently prohibiting their registration even though previously registered Tier 0 engines can continue to operate until 2010. ARB needs to remember that over 80% of portable equipment owners have never been exposed to ARB, district regulations or their web sites and, therefore, are totally unaware of their powers and jurisdiction. After all, this is the first time ARB has regulated the equipment of small private owners. So their lack of response to the ARB registration edict is not surprising. ARB and the air districts must consider that, unless their annual operating budgets are increased dramatically, their enforcement personnel will probably not be able to enforce a statewide prohibition on that many engines with the limited number of inspectors available and their other higher priority responsibilities. Also, as I recall, CAPCOA did indicate when the ARB adopted its emergency regulation in December 2006 prohibiting the operation of unregistered Tier 0 portable engines, the California Air Pollution Control Officers Association (CAPCOA) offered to allow Tier 0 engines to be registered in some of its districts. Consequently, ARB should weigh the merits of offering a compromise to portable equipment owners by allowing them to register their Tier 0 engines until 2009, when they would be required to be replaced with certified engines. In my judgment, registering those engines now would in the long run be in the best interests of air quality. Respectfully, Jeb Stuart Construction Industry Air Quality Coalition |
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Date and Time Comment Was Submitted | 2007-03-21 08:24:40 |
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