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I understand the driving force behind the new regulations.  Time
and money are the two major factors that make it impractical to
comly even for companies like ours that has made every effort
possible to comply.  With all the economic slowdown and increased
regulation coming from business owners form every angle, the
financial resources are not there to do what is being asked.
My recommendation is more time than what is even being proposed.
This will get the filter manufactures more time to continue to
debug their products, and truck owners to more time to integrate
their fleets financially.

The current generation of filters are not reliable and our burning
more full as well as reducing engine power.  The down time and shop
time is crazy.  The manufactures are not ready no matter what they
say.  

We run a very clean operation with 12 trucks currently. We have
gotten rid of all the trucks and off-road tractors we possible can
to still function, but there is just no way we can spend 14k to 20k
per truck to get a few more years.  We have used Moyer $ and have
purchased as late a model trucks as we can financially pencil out.
Replacing trucks at a minimum of 200k/truck is just not in
financial cards ether. 

There is a lot of unintended consequences with these regulations
being so aggressive.