First Name | James |
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Last Name | McNally |
Email Address | JMcNally@mansonconstruction.com |
Affiliation | Manson Construction |
Subject | Marine Engines - Dredging Industry Regulatory Overlap |
Comment | Manson Construction is the largest dredging contractor on the West Coast. Our industry plays a vital role in maintaining shipping lanes, providing coastal protection and restoring coastal habitat up and down the state of California. We also employ many californians with high paying, union craft jobs. Manson has a long history of complying with local district as well as statewide air regulation. We have invested in SCR systems and repowered very large specialized marine equipment with costs in the millions of dollars. The current changes to the PERP regulation are another example of a patchwork approach to regulation impacting our industry that has had significant detrimental effect on our business and competitive postion relative to less informed contractors from out of state. While we don't necessaryily disagree with the inclusion of marine engines in the PERP, we wish to point out to the board that there is a significant industry out here employing people and in some cases working hard to comply that finds itself in the very difficult position of having the very same engines included in no less than three regulatory regimes. All of our dredge engines are registered under the PERP, but because we work in state territorial waters, we also are forced into local district permits and often district offsets. In addtion, the ARB has proposed to extend the harbor craft rule to dredges. The ATCM applies to use (and we are repowering a 10,000hp vessel at the moment to comply), yet with this change, we should have installed higher emitting marine engines and would have been exempt from the ATCM. We implore the board to direct staff to recognize the overlaps and work with industry to come up with one regulatory regime for dredges. We would be happy to comply and stop wasting money that is ultimately our clients (the taxpayers). Thank You. that has had an Unfortunately, we have found ourselves |
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Date and Time Comment Was Submitted | 2010-01-27 11:44:08 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.