Comment Log Display

Dear Standards Board members and staff, 

Our association, CALPASC, has 550 members companies performing
construction work in California. Those companies employ
approximately 80,000 persons. Our comments are as follows:

1. We support most of the modifications to the proposed off-road
diesel regulations.
2. We oppose modifications 25 and 26 relative to moving the
reporting years up for medium and small fleets. These regulations
will be very expensive, and time consuming for these smaller
fleets. Moving it forward will make it even more difficult.
Residential construction is the slowest since the early 1990's,
with recovery not expected to start until 2010, much less having
fully recovered until after 2012. This industry will barely be
back to pre 2007 levels, and will not have the resources to add
the burden of these regulations a year early. With such a slowdown
in housing, construction related emissions should be greatly
reduced over the next five years anyway. 
3. We oppose modification 29, extending the reporting years for an
additional year. We see no justification given for all construction
firms to have an additional year of compliance activities. 

4. I know it is not part of the modifications proposed, but it is
still wrong for a regulation to go forward, when the staff has not
reconciled its dramatically different cost estimates versus the
construction industry estimates. Construction is mostly a
competitive bid industry, so companies are very precise in their
numbers. The large discrepancy in cost estimates between those who
have to pay the bills, and the board staff; should be cleared up
before this regulation goes into effect.

Sincerely, 



Bruce Wick