Comment Log Display

December 5, 2006


Clerk of the Board
California Air Resources Board
1001 I Street, 23rd Floor
Sacramento, California 95814


Subject:	Comments Regarding the Proposed Emergency Amendments to
the Statewide Portable Equipment Registration Program (PERP)
Regulation and the Airborne Toxic Control Measure (ATCM) for
Diesel-Fueled Portable Engines and the ATCM for
Compression-Ignition Engines

Dear Clerk of the Board:

The Antelope Valley Air Quality Management District (AVAQMD) wants
to acknowledge your staff for the preparation of the “Draft
Concepts for emergency amendments to PERP and the ATCMs for
Portable and Stationary Diesel Engines”.  The AVAQMD wishes to
provide the following comments:

1.	The ‘Draft Concepts’ look fair but detailed comments cannot be
made without a thorough review the actual language changes that
will be made to the PERP and the 2 ATCMs.

2.	The AVAQMD has recently received a number of inquires from
small business that have a single portable engine subject to this
ATCM.  These small operators have only recently become aware
(within the last week or so) about these Emergency Amendments. 
The universally expressed concerns that ‘late penalties’ could
bankrupt their business.  Many of these small businesses provide
support to the agriculture and construction industries.  Therefore
the AVAQMD recommends that ‘late penalties’ be restructured for a
small business.  The late penalties could be $100 for calendar
year 2007 and then raising to $200, and then $400 for year 2008
and 2009.  A good definition for a small business is the one used
in the Air Toxics “Hot Spots” Fee Program (AB2588), as follows:

A)	The business is independently owned and operated and has met
all of the following

i)	The business has 10 or fewer (annual full-time equivalence)
employees; and

ii)	The business's total annual gross receipts are less than
$1,000,000.

The AVAQMD also thanks the Board for giving us this opportunity to
comment of these proposed emergency amendments.  Should you have
any questions, please contact Mr. Richard Wales of the my staff at
(760) 245-1661 extension 1803.

Sincerely,




Alan J. De Salvio
Supervising Air Quality Engineer
Antelope Valley Air Quality Management District