First Name | Michael |
---|---|
Last Name | Turner |
Email Address | michael_turner_1@yahoo.com |
Affiliation | |
Subject | Proposed Off-Road Diesel Emission Regulations Being Considered by the CARB |
Comment | California Air Resources Board Submitted via webform located on the Air Resources Board website at: http://www.arb.ca.gov/lispub/comm/bcsubform.php?listname=oridesl07&comm_period=A Dear Members of the California Air Resources Board: I am writing to you as a fourth generation Californian who cares deeply about the quality of the air that my parents, my wife, my daughter, and the rest of my family breathe in this state everyday. I applaud you each in your efforts to improve the air quality in California and thereby protect the health of my family and neighbors, as well as myself. I understand that you are each currently considering the adoption of new off-road diesel regulations in your pursuit to improve the state's air quality. The goal of this proposed regulation is to reduce PM and NOx emissions. This goal is laudable. However, I cannot support the proposed regulation due to the language and specific requirements which are contained therein. In fact, I am greatly disturbed by this proposed regulation. Why? Read on... I am acutely aware of the impact that this regulation will have on California. As a graduate of the business administration program at California State University, Northridge, I know that the burdens of all government regulations are most visibly borne by a particular group of individuals - in the case of the proposed regulation, that group will be the owners and employees of small to medium-sized heavy construction contractors and the allied businesses that serve them. As a graduate of the Master of Construction Management Program at the University of Southern California, I know that small to medium-sized contractors in California are overwhelmingly made up of "mom-and-pop" and family businesses that have a dramatically large impact on the health of the state's economy when considered in aggregate. As a third generation California contractor, I know that the vast majority of small construction businesses "do not make a killing", but do provide good-paying jobs through which an untold number of Californians enjoy a comfortable living. These jobs are jobs that will not be outsourced. They will not be shipped overseas. These are jobs that, if lost, will greatly hurt many of the citizens of this state and consequently will greatly hurt this state. After reviewing the details of the proposed regulation, I am convinced that many of these jobs will be lost. This includes the jobs of many of my family members and friends, as well as possibly my own. Why do I think this proposed legislation will cause many Californians to lose their jobs? Because the financial burden on small contractors will be too great. It takes many, many years for the owners of a small grading or demolition contracting firm to amass the capital to buy several loaders, excavators, and scrapers. This type of construction is a classic example of a low-margin line of business. If the proposed legislation is adopted and enforced, and this equipment has to be “repowered” at a very high cost (reference the comments already submitted by Mr. Dave Porcher of Camarillo Engineering which are posted at http://www.arb.ca.gov/lispub/comm/bccomdisp.php?listname=ordiesl07&comment_num=3&virt_num=3), then the owners of such a business will likely choose to sell their equipment one piece at a time. Selling equipment or closing shop altogether will be a more financially viable option than “repowering” older smaller fleets. (By the way, your definition of what constitutes a “small fleet” is not at all in line with what really constitutes a small fleet.) This equipment will basically no longer be welcome in California, which means that the jobs of all the equipment operators, dispatchers, mechanics, truck drvers, parts salesman, and affiliated trades will also no longer be welcome in California. This will have the effect of leaving only the largest contractors in the California marketplace, shutting down an untold number of family businesses. At the same time, this regulation will greatly increase the cost paid by California taxpayers and property owners on construction projects as the larger contractors who remain in business will have to submit increasingly higher bids on projects to cover the enormous expenditures they will incur to “repower” their massive fleets. Higher bids will likely result in the cancellation of many planned construction projects, which will result in even more jobs being lost. Am I an alarmist? No, I am afraid that I am not. Am I against clean air? Definitely not! Can I support the claims that this proposed regulation will cost Californians their jobs? Yes. Quite a number of Californians can support the claims I make herein. I am afraid that you, the members of the California Air Resources Board, have not heard from nearly enough of these people simply because they don’t seriously believe there is any chance that such a regulation could ever be adopted at this time. I believe, therefore, that you should give great credence and all-the-more-carefully consider the points raised by Mr. Dave Porcher of Camarillo Engineering and Mr. Bruno Dietl of Vulcan Construction & Maintenance, Inc. (for the record, I have never met either of these individuals, but I find the financial costs they project to be entirely realistic). The majority of the people I have mentioned this proposed legislation to in the construction trades believe that the negative impacts this legislation would have would be so obvious that no one would ever approve its adoption. Therefore, they are remaining quiet at the current time. However, I believe that the members of the CARB, and many other government officials (including state assemblypersons and senators), will hear an overwhelmingly large outcry from the people of this state if this proposed legislation is adopted and enforced. I think this legislation, if adopted, has the potential to embarrass the CARB after the ramifications of this legislation become apparent to rank-and-file Californians. In conclusion, I would like to state that although I support you in your efforts to improve our state's air quality, I cannot support this proposed regulation concerning off-road diesel emissions. I strongly urge the Air Resources Board to develop a committee composed of those Californians who would bear the greatest burden from this proposed regulation - the owners, managers, and rank-and-file employees of small and medium-sized heavy construction companies (including demolition contractors, grading and excavating contractors, shoring contractors, paving contractors, underground utilities contractors, and the like). Many of these individuals, like myself, believe strongly in the importance of improving California’s air quality. At the same time, they know better than anyone else how much financial burden the proposed legislation will place on their businesses, and how this great financial burden can best be mitigated (perhaps through slower implementation or government subsidies or tax credits/offsets). I believe that with much input from this select group of Californians, the proposed regulation can be modified in such a way that meets the goal of improving our state’s air quality while at the same time protecting California’s construction industries. I, for one, would be interested in serving on such a committee and offering my services to the CARB. Please let me know if you are interested in such a proposal. Sincerely, Michael Turner |
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Original File Name | |
Date and Time Comment Was Submitted | 2007-05-15 08:39:25 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.