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Comment 10 for In-Use Off-Road Diesel-Fueled Fleets and Off-Road Large Spark Ignition Engine Fleet Requirements (on-offroad10) - 45 Day.

First NameJeff
Last NameWood
Email Addressjwood@hawthornecat.com
Affiliation
SubjectEarly retrofit credits compliance efforts lost to light duty fleet
Comment
Our organization made the mistake of trying to pay for compliance
early.  Our mistake was retrofitting early some of our important
trucks that are below 26,001 GVWR.  Then the rules were changed. 
We would like to ask the Staff to propose that a fleet be allowed
to pair a heavy fleet truck over 26,000 GVWR with a early
retrofitted light fleet truck below 26,001 GVWR for exemption until
2017 for at least the first year of BACT requirements in 2012 to
allow relief so a fleet can benefit from its early compliance
spending efforts.  The economy is still very tough and this would
help us and some other  fleets through 2012.

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Date and Time Comment Was Submitted 2010-11-15 10:53:08

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