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Comment 283 for In-Use Off-Road Diesel Fueled Engines (ordiesl07) - 45 Day.

First NameBrian
Last NameKline
Email Addressbrian@ghipaving.com
AffiliationOwner
SubjectComment on off-road diesel equipment regulations
Comment
Our company has been operating in the Central Valley for over 50
years. We are a small grading and paving company that employs 25
people. Our rolling stock of equipment varies from new to 30 years
old. If this rule is adopted as is, it will place a burden on this
company that might not be sustainable. Our equipment will be
rendered valueless in California. As you are aware the
construction industry carries virtually no "blue sky" value. The
value of a business like ours is only the equipment value. This
rule would render our company almost worthless if your program is
implemented as is. The cost of retrofitting and/or replacing the
motors or equipment would be devastating to our operation. The
replacement cost of our fleet would be over 5 million dollars. We
don't generate enough revenue to warrant this replacement over a
10 year period. As far as the retrofit, this sounds like a
temporary fix that does not have enough history to be proven out
as worth the install. 

I share your goal in reducing the particulate matter discharged by
these motors. I do hope however that the board can come up with a
solution over a longer time period so as to not put medium and
small businesses out of business. 

Thank you,

Brian Kline
GHI (President)

Attachment
Original File Name
Date and Time Comment Was Submitted 2007-07-24 11:53:58

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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