First Name | Michael |
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Last Name | Key |
Email Address | keyturf@sbcglobal.net |
Affiliation | Contractor |
Subject | Regulation for In-Use Off-Road Diesel-Fueled Fleets |
Comment | I am a contractor with approximately 30 Diesel Engines in my spread of equipment. My equipment ranges in HP from less than 10 HP to 100 HP. It also ranges in age from 1972 to 2006. The majority is within 15 years old. A majority of the equipment is on stand-by for when I may have a need for it. Many pieces only work 300 to 400 hours a year. This represents approximately 2 months out of a year. I have been working the past 35 years to get to the point that most of my equipment is paid for and now I am being told that I must Retro-fit my equipment to meet or exceed the ARB (and Federal) Regulations. It would cost me MANY years PROFITS to retro-fit all my equipment. I have attended the recient program presented by the ARB in Diamond Bar on Retro-Fitting Diesel Engines & Reduction of Particulate Emissions. I attended for several reasons. The first was because of my equipment and I was interested in the technoligy. I wanted to find out what I could do, what it is going to cost and how to prepare for the upcoming requirements. Secondly, I am interested in the technology to reduce the air I breath and wanted to know more about the existing and upcoming technology. Most importantly, I hoped to find out what the financial impact on my "Small Business" would be. With that said, my comment would be to consider the usage of the equipment before mandating what an individual "MUST" do to comply to the requlations. I do not disagree that "WE" must continue to resolve these issues, but if a piece of equipment is minimaly used, it should be considered for minimal consideration to be retro-fitted. The requirements should fit the out-put of the equipment on a yearly basis or some other consideration. It should not require the "Small Business Owners" to go out of business to comply with the regulations. |
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Date and Time Comment Was Submitted | 2008-12-05 17:40:47 |
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