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Comment 32 for Regulation for the Reporting of Criteria Air Pollutants and Toxic Air Contaminants (ctr2018) - 15-1.

First NameGeorge
Last NameOsborne
Email Addressgosborne@duningercorp.com
Affiliation
SubjectChanges in reporting
Comment
Thank you for taking comments. I have worked closely with the
Monterey Bay Air Resource Board helping clients come into and stay
in compliance to operate both diesel and natural gas power
generators. None of these clients want to operate generators and to
do the work to comply and the high expense. I do not like the term
victim, however in a sense the inability of PG&E to in any
reasonable time frame supply power has forced them to spend money
labor resources and hire people like me to navigate the paper work
when they would prefer to write a check and have clean reaiable
power.

What I believe needs to be considered when you consider more
regulation, which you may have the right, however it may not be the
right thing to do.  

1. Jobs have already been lost because the cost to operate on
generators is so high. Many of our clients grow cannabis which has
seen a steady decline in the price of product as a result of supply
and demand. Fees and taxes however are fixed.

2. Publishing this data adds to a very high security risk for these
business as they operate on cash,not because of choice, but federal
banking laws.When the state publishes these locations it is an open
invitation for these business to have greater security issues both
for product theft and the cash needed to operate.

I sincerely believe that no ill will is involved, however
unintended consequences are added cost to business that provide
many agricultural jobs and related services will cut back as
margins are already tight. The added risk of inviting crime to a
pinpoint location with the potential for property loss,injury or
death seems unnecessary, when the goal is to be on the grid, once 
the utility can add resources.

Thank you for reading,for understanding this is not a situation
that anybody forsaw and all are working hard to resolve.

Best regards,

George Osborne
2-6 484 8538    

Attachment
Original File Name
Date and Time Comment Was Submitted 2019-06-07 22:25:19

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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