First Name | Charles |
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Last Name | Boyd |
Email Address | chuck35@cinerepamps.com |
Affiliation | Cinerep International, Inc. |
Subject | PERP diesel engine replacement extension |
Comment | Due to current extrememy difficult economic conditions, I strongly urge approval of ARB Staff recommendation to extend replacement deadline for currently registered non-certified diesel engines until December 31, 2010. In addition to this extension, I want to suggest a minor change to regulations which will have negligible impact on the environment while helping many small businesses and individuals in the Film Industry. This change would simply allow an existing compliance deadline for one category to also apply to a similar category of equipment used in the motion picture industry which utilizes the IDENTICAL off-road diesel engines. In the category identified as "OFF-HIGHWAY VEHICLES" non-certified diesel engines operated as part of small or medium size fleets are allowed more lenient compliance deadlines of 2015 for small fleets and 2013 for medium fleets. The category of equipment identified as "PORTABLE GENERATORS", which is so prevalent in the film industry, use the same off-road engines as are used in "OFF-HIGHWAY VEHICLES", however are not allowed the same, more lenient deadlines for small or medium size fleets. Considering that the identical engines are used in both categories and utilization hours as rental equipment should be very similar, I believe compliance deadlines should be the same for "PORTABLE GENERATORS" and "OFF-HIGHWAY VEHICLES" based on fleet size. This minor change would greatly assist small businesses such as mine in the current bad economy and would correct an apparent inequity in CARB regulations. |
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Original File Name | |
Date and Time Comment Was Submitted | 2010-01-05 15:42:55 |
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