Comment Log Display

ARB Staff has indicated that the directive from the state board to
provide an extra two years for Carl Moyer eligibility for growers
needing to comply with the Stationary Diesel Engine ATCM Carl
Moyer funding will be included in their Final Statement of
Reasons. It will be important for ARB Staff to provide outreach to
the local air districts and agricultural community so they are
aware of this available funding. This ability to get Carl Moyer
funding is imperative since the rule will go into effect before
growers had three years previous notice and could apply to fit the
current time limitations. 

California Farm Bureau Federation is extremely concerned about the
cumulative impact to the agricultural community of this ATCM in
combination with upcoming diesel regulations. We are willing to
work with ARB and the local districts to educate growers about
these new engine requirements but there needs to be a concerted
effort by ARB to insure sufficient outreach occurs statewide. The
current fact sheet needs to be updated to clearly lay out the key
ATCM requirements of this 60 page rule in a succinct manner and be
easily available to find on the ARB website. 

As stated in our November 2006 ATCM comments, CFBF is very
supportive of growers being able to use alternative fuels as an
alternative compliance mechanism as stated in the ARB workshops
regarding this ATCM. State ARB staff need to take the lead in
helping provide districts with direction on how this could be put
into practice as they often have limited staff and would not be
able to provide the necessary structure for this new effort. Even
if complete compliance is not achievable, since ARB offered this
as an option, ARB needs to provide information and guidance that
could truly make this a viable choice and not just a good idea
that is nothing more than wishful thinking. 

Thank you for the opportunity to comment. We look forward to
working with ARB to insure that adequate outreach and financial
incentive occurs along with alternative fuel guidance that
provides a feasible compliance mechanism.

Sincerely, 

Cynthia L. Cory
Director, Environmental Affairs
California Farm Bureau Federation