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Comment 259 for In-Use Off-Road Diesel Fueled Engines (ordiesl07) - 45 Day.

First NameBuck
Last NameKemmis
Email Addressbuck@kemmis.com
AffiliationBuck Kemmis Equipment, Inc.
SubjectProposed Regulation for Off road Diesel Vehicles
Comment
To Who May Help,
    I am the owner of a small General Engineering Company and we
do only grading work.  We own many pieces of equipment used off
road and cover by this new proposed CARB regulations.  We
primarily build residential homes and that work is slowing due to
reduced home sales.  I am in favor of tighter regulatioins
regarding emissions of our equipment, however I am concerned about
how quickly those standards are being implemented.  During a period
of decresing work volumes we also have reduced profits and very
little money to replace equipment or repower equipment so the
transition is most difficult.  We are currently laying off due to
decreasing work loads and then the additional burden of replacing
equipment or repowering equipment would be catistrophic to my
buisness.  We would need to down size our company to the number of
peices of equipment we could replace or repower and then only
employ an equial number of operators for each peice of equipment. 
We currently have only about 30 employees, but if forced to meet
the proposed CARB regulation we would have to reduce our work
force to about 10 to 15 employees including office personel.
    Again I beleive our industry needs to reduce our emmisions,
but I ask that the new regulations be adopted over a longer period
of time.  Time enough to allow us to replace our equipment over a
period of time acheiving the useful life of the equipment and then
replacement would take place with the latest and greatest
technology for reducing emissions.  If allowed to gradually optain
the proposed emmisionis level asked for in the proposed CARB
regulations I don't see a problem.  Again I am for cleaner air
since I too live here, but I only ask for time to replace or
repower our equipment over a few years and not all at once.  I
appreciate your consideration of my concerns.

Buck Kemmis
President
Kemmis Equipment, Inc.
25800 Washington Ave.
Murrieta, CA  92595

Attachment
Original File Name
Date and Time Comment Was Submitted 2007-07-19 11:17:00

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