Comment Log Display

While positively appreciating the goal of the Board to reduce
off-road diesel NOx and PM and the efforts of Board Staff to do it
well, I would like to make two statements and submit some
suggestions.

Most effective leaders don't ask their followers to take on a task
unless they have accomplished the same task themselves.  In
addition, most effective leaders spend their own money first on R
& D before demanding sweeping changes from stakeholders to
implement unproven technology.

The State of California, each County in California and each Town
and City in California has a significant fleet of off-road diesel
equipment.  Let us start this project by implementing the
regulations on each piece of this equipment first, instead of
exempting it.  Let them choose their options, keep the required
records and provide the required routine and emergency services
expected of them for the first phase of implementation.  Let them
start immediately if they choose but require them to start in
2009.  This is a captive fleet that should be easy to study and
evaluate and report results from.  In 2012, take a year to prepare
a comprehensive report of regulatory compliance, real, measured
emission reduction, machine productivity changes, manpower
adjustments, compliance costs, unforseen challenges and
workarounds and suggestions for the model of implementation
stratgies.

The rationale is this.  The asset value of off-road diesel
equipment is quite high when purchased and should not be devalued
by premature regulation or retirement.  Nor should its
productivity be compromised.  Routine and emergency work such as 
snow plowing and removal, shoulder reconstruction, pavement
remediation, etc. is no more or less demanding than work that the
California contractor risks his net worth on every time he agrees
to do a job.  No reasonable action of this scope should be
implemented without a controlled trial.

In 2013 require implementation along the lines of the CIAQC
recommendations.

This gets us to 2014.  By this time, responsible manufacturers
will have engineered integrated solutions that can be purchased as
part of the machine design rather than added on in a manner that
compromises visibility, space limitation and safety.  On a recent
visit to a major manufacturer's facilities our firm learned that
they were working on technology to produce exhaust cleaner than
ambient intake air used in creating combustion.  That will be the
solution, not wasted time, effiency and money to place R & D on
the back of users.

California is perceived to have a lot of clout.  That has been
demonstrated where market forces are a significant factor in a
product the Board can regulate.  That is not the case with
off-road diesel equipment.  The California market is a very small
portion of world demand and use for these machines.  The example
this regulation sets will not be followed by premature enactment
in the rest of this nation or the world.  If enacted on the
timetable as porposed, productivity, efficiency, safety and cost
per hour of operation will be needlessly wasted in favor of a
political perception that Californians are leading the way. 
Everyday users of off-road diesel equipment intuitively realize
that.  To lead you must earn respect and prove your concept before
requiring implementaion.  Believe me, you will have a lot of
cooperation along the way, because we all want to get there.  The
manufacturers and other stakeholders will support an effort to
work with a controlled group of government owned equipment on
technology that can be applied to achieve a solution we all want.

To those who say it will take too long, I disagree.  Medical
statistics based on models have little relevance unless genetic
predispositon to a cited illness is taken into consideration. 
Anything less is a scare tactic.  No one can prove or disprove the
4,000 deaths or the cited reduction in hospital admissions, or how
long these factors will be postponed if this regulation is enacted
as written.  Will it be one week, one month or one day?  We don't
know.  We do know we are not immortal and this regulation, as
written, will not change that.

You can and should recast the regulation to obtain more
cooperation and controlled, short-term experimentation, under
California conditions, showing satisfactory results, within a
reasonable timeframe, before requiring industry wide
implementation.