Comment Log Display

CALIFORNIA FARM BUREAU FEDERATIONGOVERNMENTAL AFFAIRS DIVISION1127
- 11th Street, Suite 626, Sacramento, CA  95814 Phone (916)
446-4647	

November 10, 2006

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

RE: AGENDA ITEM 06-10-5 – PROPOSED AMENDMENTS TO THE STATIONARY
DIESEL ENGINE CONTROL MEASURE

The California Farm Bureau Federation would like to submit the
following comments regarding the Stationary Diesel Engine ATCM.
The agricultural community is willing to reduce air emissions from
our farms and ranches when the reductions are meaningful and
necessary; there is sufficient time to comply; and incentives are
available to make the changes in a cost-effective manner.
Unfortunately, the compliance schedule currently proposed does not
provide adequate time for complete and measured implementation of
this rule. 

1.	We request that an additional year (at minimum) be added to all
compliance dates for meeting emission standards for stationary
diesel-fueled engines used in agricultural operations.  This is
especially important for Tier 0 (pre-1996) engines, which
according to the September 2006 staff report represents 3,600
(42%) of the total engines affected by this proposed rule. The
report concludes that the average size of diesel agricultural pump
engines is approximately 200 hp. This means the majority of these
engines will need to be replaced by December 31, 2010. 

ARB staff has indicated following their current schedule they plan
on this rule being finalized in July 2007. To be eligible for the
Carl Moyer Program there must be a full 3 years of reductions
before the compliance date. The timeline proposed in this rule
would only leave five months for outreach and application of Carl
Moyer funding for Tier 0 engines. This is not a sufficient time
period for growers to become aware of the program and apply for
incentive funding from various state or federal programs,
including the USDA Environmental Quality Incentives Program (EQIP)
that can have a limited application window early in a given year. 

2.	CARB should provide local air districts with additional
financial support to enable them to recover the cost of
implementation, including outreach and compliance assistance and
extend the registration deadline by a year. Many districts do not
have available funding to properly implement this rule. If
districts 

are not given adequate funding from CARB they will have to recover
the many implementation costs by raising the registration and
inspection costs which is not 
fair to the agricultural community that are bearing many new
regulatory costs in a very short period of time since enactment of
Senate Bill 700 (2004). 

Without adequate funding they will not be able to do the outreach
and compliance assistance that will be crucial to implement this
rule. CFBF is very supportive of growers being able to use
alternative fuels as a compliance method. How this will be put
into practice needs to be available to the growers early in the
process so they can weigh this option in deciding how to best
comply with the engine rule. CFBF and other agricultural
associations will be providing outreach to their members, but the
state must step up to the plate and support outreach efforts if
they are going to impose such a significant regulatory requirement
on growers. Private entities and local air districts should not
have to bear the entire burden of this new regulatory burden.

3.	CARB needs to insure during their approval of district rules
that discrepancies do not occur between local and state engine
rules. It will be imperative that local districts do not set
different engine standard criteria that could unintentionally
allow a grower to purchase an older engine for a short period of
time. Growers could purchase an older engine assuming they are in
long-term compliance, only to have to replace the engine well
before the useful life of the engine has occurred. The districts
and state must be sending a consistent message to the agricultural
community statewide so growers can make lasting and educated engine
purchases. 

Historically, agricultural engines have not been subject to local
air district permitting or registration programs. This rule will
have significant impact on agricultural community. CFBF asks that
you take our points into consideration and make the suggested
changes prior to rule approval. 

Respectfully submitted by:

 
Cynthia L. Cory
Director, Environmental Affairs

cc: 	Robert Fletcher, CARB
	Barbara Cook, CARB