Comment Log Display

To the Board,

As the need to control emissions for Street Sweepers and other
in-use diesel on-road vehicles has evolved, we feel (NAPSA) that
the vital remediation role Street Sweepers play has been
overlooked. Under the National Pollutant Discharge Elimination
System (NPDES) Street Sweepers play the most important role under
Best Management Practices  (BMPs) to remove pollutants from streets
and roadways that otherwise would enter our storm water systems,
streams and rivers. Even with concessions and extensions given to
our industry during the proposed changes there will be a large
number of Sweepers removed from service and not replaced. In fact
because of economic conditions cities and counties have cut back on
their Sweeping Programs which will directly lead to more pollutants
entering our water systems. Private sweeping fleets will be
downsized to meet the regulations and in many cases will not be
able to retrofit or replace because of the high cost of replacement
now nearing $250,000.00 each. Private fleets play a critical role
to supplement sweeping operations not carried out by state, county,
city and other government agencies. This will lead to additional
pollutants entering our water systems.

To summarize this issue the CAL/EPA departments of AIR and WATER
need to collaborate to maintain an adequate number of Street
Sweepers needed to remediate the streets and roadways to protect
Air Quality and Water Quality under the (NPDES) storm water
system.

Jay S Wells, Chairman, Ca. Chapter, NAPSA