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I would like consideration to extend the 7 year life for TRU's. We
have well over 100 units that compliance will expire 12-31-2015.
These units will have used less the 50% of their useful lifecycle.
The only viable option for the future is complete unit replacement.
Replacement engines no longer qualify, Exhaust retrofits have
performance issues and Tier 4 final engines do not fit in older
units. The new unit cost will be between $24,000-$25,000 per unit.
This means a minimum of 2.5 million dollars to replace 7 year old
engines that have not utilized half their life cycle. Because we
set our TRU's to operate only when necessary, we have effectively
reduced the emissions much below most other users. i would like to
see considerstion to extend the 7 year compliance deadline so it is
relative to the emissions we have been able to reduce through smart
operation.