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Comment 1 for Portable Diesel Engines (perp2010) - 15-2.

First NameDaniel
Last NameKruger
Email Addressdkruger@soperwheeler.com
Affiliation
SubjectPortable Diesel Rule must parallel Off-Road Rules
Comment
For consistency, clarity in reporting and enforcement, and to aid
economic recovery, it is imperative that the Portable Rule be
reopened and adjusted to be consistent with the OFF-ROAD diesel
engine emission rule and its proposed modifications. 

The Off-Road Rule proposes delaying performance requirements by 4
years for large fleets and 2 years for medium and small fleets. To
be consistent with the Off-Road Rule, The Portable Rule must do the
same, and must include the same exemptions for
Agricultural/Forestry equipment. 

Doing so will standardize and streamline both the reporting and
enforcement burdens the State has to bear in its implementation,
and create clear standards across categories to diesel equipment
owners.

As currently written, the December 31, 2010 deadline for taking
pre-1996 Portable diesel engine equipment out of service will be
devastating to agriculture, forestry, and construction contractors
struggling to support working families through ongoing tough times.

Attachment
Original File Name
Date and Time Comment Was Submitted 2010-11-17 13:00:35

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