First Name | Larry |
---|---|
Last Name | Ronhaar |
Email Address | LRONHAAR@travelers.com |
Affiliation | EUCA |
Subject | Off-Road Diesel Emissions Rules |
Comment | While I am not a contractor, I am an insurance underwriter who specializes in underwriting contractors. Your proposed rules will have a direct impact on MANY of my customers, some of whom have become good friends. I am very concerned that your proposed rules will drive them out of business. Your rules, as proposed, require the purchase of technology that does not yet exist. Tier 4 engines do not yet exist. CARB VDECS do not yet exist for most equipment. The notion that equipment must be retrofitted with VDECS only a few years before it must be replaced with Tier 4 engines is one of the most ludicrous anti-business proposals ever. The state is not supposed to impose unfunded mandates on local governments. There should at least be some sane limits on unfunded mandates for what are mostly small businesses. It was appropriate for the federal government to impose fuel mileage and emissions requirements on automobile and truck manufacturers. It would be appropriate to impose similar requirements on manufacturers of off-road diesel equipment. Until the equipment that meets your proposed requirements becomes availabe, it is patently absurd to require contractors to buy it. Most contractors operate with profit margins between 2% and 5%. With a profit margin of 4%, it would require them to complete $25,000,000 of work to be able to replace $1,000,000 of equipment. CARB has suggested that contractors should just build the cost of the new equipment into their prices. That might make some sense if everyone used published prices, but is amazingly naive for contractors. The public contract code and other laws and regulations prohibit collusion in bidding public work. Under CARB's proposed regulations, contractors who wait the longest to replace their equipment would be able to underbid the contractors who quickly replace their equipment, driving those who did what you wanted out of business. Your proposals are counterproductive at best. There is no doubt that diesel emissions are bad for the environment, and we all want a cleaner environment. We also want jobs, safe streets, and uncongested highways. The voters of California recently approved the spending of billions of dollars over the next few years to repair California's badly decayed infrastructure. Who is going to do that work if CARB drives the cost of those projects up or drives the contractors out of business. |
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Date and Time Comment Was Submitted | 2007-05-18 16:19:28 |
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