Comment Log Display

OPEI respectfully submits the attached comments in opposition of
the proposed certification and compliance fees rule.  

Due to ongoing Small Off-Road Engine (SORE) rulemaking activities,
which will have a dramatic impact on the sector as early as model
year 2024, including the number of EOs that will be issued and the
sales volume of product covered by EOs, OPEI requests CARB to
exempt SORE from the proposed certification and compliance rule at
this time.  

Additionally, the rulemaking package incorrectly estimates the
volume of SORE product subject to certification and compliance, and
as a result significantly underestimates the cost-impact to
consumers.