Comment Log Display

POSTING TO CARB’S WEB SITE IN SUPPORT OF THE 
CBCC ALTERNATIVE

Dear Members of the California Air Resources Board:

The California Air Resources Board (CARB) is currently considering
the adoption of off-road diesel regulations that, if implemented as
presently drafted, would have a profound, negative impact on
California’s infrastructure rebuilding efforts, the health of the
state’s construction industry and its overall economy. 

Construction contractors and workers want these regulations to
work for everyone. That’s why we have proposed an alternative
approach which would clean up the air while keeping the most
number of construction companies in business and workers employed;
the bidding environment at its most competitive; the Rebuild
California bond program on schedule; and construction cost
increases to a minimum.

I am writing to ask you to support this alternative at the CARB
meeting on July 26th  It will give California the cleanest
construction fleet in the world while ensuring construction
contractors and workers are kept on the job. 

The goals of this plan are simple:

1. 	Achieve better emission reduction for 2015 than the CARB
proposal.
2.	Keep the same starting date as the CARB proposal.
3. 	Require annual reporting to demonstrate progress toward the
goal.
4.	Provide maximum flexibility for contractors to reach the
target.
5. 	Allow more time at the back-end for new Tier 4 engines to
enter the fleet (estimated to be approximately 2014/2015)
6. 	Recognize the wide divergence in fleet sizes, emissions and
capabilities.
7. 	Permit each fleet to determine how best to achieve the
reductions.
8.	Give credit to those fleets that provide early emissions of
both NOx and PM.
9. 	Minimize the financial impact to keep the most firms in
business.
10. 	Maintain a highly competitive bidding environment.

The most significant difference between the CARB proposal and the
alternative plan is moving the 2020 goal for large fleets to 2025,
which is necessary in order to allow more time for Tier 4 engines –
which will achieve all the emission targets without any further
retrofitting and will not be available until 2014/2015 – to enter
the market and be acquired by contractors.                        
 

I want to be clear: Cooper Crane & Rigging is very supportive of
reducing particulate matter (PM) and NOx emissions from diesel
engines. There is no disagreement that we need to work
collectively to improve the state’s air quality and all of us want
to provide as healthy an environment as possible for our employees
on our job sites. Please consider adopting this sensible
alternative that accomplishes the same, if not better, emission
reductions while keeping California’s construction industry and
our state moving forward.

Sincerely, 
John Wakeman   Cooper Crane & Rigging