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Comment 22 for In-Use Off-Road Diesel-Fueled Fleets and Off-Road Large Spark Ignition Engine Fleet Requirements (on-offroad10) - 15-1.

First NameBill & Jo Ann
Last NameBawks
Email Addressjoann@centralvalleysweeping.com
Affiliation
SubjectComments on changes to the On Road Bus & Truck Rule
Comment
We have been involved in the on going discussion with CARB Staff,
regarding the On Road Bus & Truck Rule and developing a solution
that would allow the sweeping industry to survive through this
process.  We appreciate their willingness to hear our concerns and
make some changes that are positive.  The following are still
concerns that we have:

Section 2025 (d) (40) Low mileage Construction Truck - Construction
Sweepers should be included in this definition.  Sweepers remove
many tons of air and water pollution from the environment each
year, much more than they add.  Including the construction sweepers
in this definition would help compliance and reduce overall PM. 
Construction sweepers work a limited number of days per year.

Section 2025 (s)(7)(y)- Compliant fleets without motor carrier
numbers should be posted on the website as well

In addition to these items, the slow economic recovery has resulted
in less work, employees on extended unemployment, and many property
owners and or business owners reducing or canceling sweeping
service.  This only adds to the air pollution problem.
As a service business, people have a choice as to whether or not
they choose to use the service.  Passing on the price increases
that staff has proposed, has not been received well by property
owners. 

Thank you for considering the above suggestions.

Attachment
Original File Name
Date and Time Comment Was Submitted 2011-06-03 15:51:25

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