Comment Log Display

Dear Honorable Board Members,

Kings Oil Tools (KOT) is struggling with the proposed GHG
regulation.  KOT has 31 trucks in its fleet.  Since 2008, KOT has
upgraded 70% of its 31 truck fleet at a cost of approximately 2.48
million dollars.  In addition, KOT has invested about 4.3 million
dollars upgrading its off-road fleet.  All of this capital was
invested in an effort to comply with the Truck Regs and the
Off-Road Regs.  KOT is a small part of the total oilfield service
industry with a total fleet of over 3,000 on-road vehicles
operating in California. 

KOT and the oilfield service industry is with complying with the
requirements of the Truck Regs as well as with the requirements of
the Off-Road Regs and the Portable Equipment Registration Program. 
All of these regulations require the installation of PM filters and
the replacement of engines to the 2010 standard or a Tier 4
standard for off-road engines.  This is an enormous capital
investment by the stakeholders in the oilfield service industry. 
This kind of cash drain will impact the economics in the California
oil industry and could cost jobs.

Lastly, it should be noted that in 2011 there were approximately
250 businesses that left California and now (2013) there have been
158 businesses leave California due to regulations.  In fact Intel
and McAfee will be leaving California this December due to
regulations.  

We need to slow down on regulation development and see what the net
result will be on our current emission reductions. 

Sincerely,

Jim Zaben

Environmental Manager
Kings Oil Tools