First Name | Tara |
---|---|
Last Name | Haas |
Email Address | thaas@euca.com |
Affiliation | Engineering & Utility Contractors Assn. |
Subject | Tier 0 Equipment Must be Included in PERP |
Comment | California Air Resources Board 1001 "I" Street Sacramento, CA 95814 Dear Board Members: While we all want to do our part in reducing air pollutants, the PERP regulation disproportionately impacts the construction industry's contribution to better air quality (much like your pending regulation on off-road diesel equipment). Specifically, not allowing the registration of Tier 0 portable engines in the PERP places significant financial impacts on users to replace their Tier 0 engines, or face significant penalties and fines. The natural attrition for these older engines being replaced with newer, cleaner engines will already improve air quality in the coming years. Forcing the "replacement or penalty" provisions of the PERP rule on Tier 0 engines will only create evaders who simply cannot afford to replace their engines and remain competitive in an industry which operates on tight profit margins (a concept those drafting the off-road diesel engine rule should familiarize themselves with). The ARB seems to think that the construction industry is responsible and can afford to bear the cost to replace all their older equipment. Both are not true. Additionally, the PERP regulation impacts small and minority owned companies that operate on even slimmer profit margins. Those that you refer to as "scofflaw's" are simply trying to stay in business, or have difficulty in navigating this complex and combursome regulation. EUCA members have voiced to me that they have tried to register eligible equipment in the PERP, but have had application after revised application returned. As we look forward to the coming years of our industry following the intent of the Governor to rebuild California's aging infrastructure, we must consider the impacts of these rules on the workforce and companies who will be expected to perform the work that the public is overwhelming supportive of. Companies currently operating in California will be forced to spend extraordinary amounts of capital to meet the requirements of the CARB, or become "scofflaws". Larger companies performing work in multiple states may simply choose to bid elsewhere, thus reducing the competition and increasing project costs to our state, reducing the amount of projects that can be built with the available funds. I strongly suggest that the Board again carefully consider the broad impacts of the PERP regulation on the construction industry. As a member of CIAQC, the members of EUCA also urge you to adopt CIAQC's recommendations and continue to work with this group towards regulations that will result in economically balanced clean air regulations. Sincerely, Tara Haas Director of Government Relations Engineering & Utility Contractors Association |
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Date and Time Comment Was Submitted | 2007-03-21 09:28:46 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.