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Comment 7 for In-Use Off-Road Diesel Vehicles and the In-Use On-Road Diesel Vehicle Regulation (onoffroad10) - Non-Reg.

First NameRalph
Last NameMcIntosh
Email Addressralphmcintosh@rmwd.org
AffiliationRamona Municipal Water District
SubjectARB On/Off Road Diesel Regulations
Comment
To Whom it may concern:

I am sending this short email to express my concern over the ARB
On/Off Road Diesel Regulations.

Currently we are in what I believe to be the  perfect storm. 
Drought, declining water sales, declining property tax revenues,
increasing water costs, a bad economy and the ever increasing
amount of new regulations is hamstringing all public agencies.
Asking us to conform to these standards with all of the above
mentioned issues just makes a bad situation worse.

The state and federal government are not the only beneficiaries of
the bad times.  Every branch of government is impacted in the same
manner.  No one is immune.  To keep passing this type of thing on
to us will only worsen the situation.  This is the trickle down
theory at its worse.

Although we are a small agency staff wise, we serve a farily large
community of about 45,000 people and basically provide city
services such as water, parks & recreation, sewer, recycled water,
fire, paramedic, rescue, etc. Over the last year I have had to
eliminate jobs and cut programs within this organization in an
effort to cut costs and lessen the burden of the rate payer. 

To date this regulation is taking up the time of one employee full
time.  We can't afford that being we have such a small staff.

Don't get me wrong, we are all very concerned about environment
and our childrens and grandchildrens future.

This plan should have been implemented much in the same manner as
are passenger vehicles and light trucks.  Make the industry comply
with the new regulations by a certain time period to meet certain
regulatory requirements. Don't just take a vehicle and say that it
doesn't comply so if you can't get it into compliance you must
replace it.  This has been done in our case.

We have a 1987 International 10 yard dumptruck with approximately
70K miles on it.  There is nothing wrong with this vehicle other
than the fact that it doesn't meet your standards when it comes to
diesel particulate requirements.  We have tried to retrofit it at
an enormous cost but we still can't meet your regulation
standards.

These regulations will hit us hard in the next few years as well
with our off road fleet.

So now I am forced to expend $150K of taxpayer/ratepayer funds to
purchase a replacement vehicle.  This alone will cause a 1-2%
increase in our water rates.  Water rates are skyrocketing at
historical paces.  With rates projected to incease by 20-30% in the
next year I don't know how much more I can ask of our customers.  I
have no more positions I can cut.  The only thing I guess to look
at would be to consider closing fire stations, or cutting safety
personnel.

These regulations are also very complicated and hard to figure out
due to the differring deadlines.  I believe that if you want a
certain vehicle off the road then state the date that it is
required to be off the road.  Don't just string along dates that
are all over the place to meet a requirement for one vehicle vs.
another.

I would very much like to be in attendance for this weeks public
meeting, but I don't even have the funds to fly to Sacramento to
attend.

I believe these regulations will drive the states economy further
into the tank.  I personally know of five local construction
businesses that have gone belly up due to the economy, but mostly
because they know they can't afford to comply with these
regulations and stay in business.  I feel that this will drive
private business to leave this state, further compounding our
economic crises.

So I emplor you to look at for this requlation a little harder so
that government agencies and private companies can stay in
business, and keep this state the greatest state in the union.

Ralph McIntosh
General Manager 
Ramona Municipal Water District

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Date and Time Comment Was Submitted 2010-04-19 09:02:27

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


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