First Name | Jack |
---|---|
Last Name | Goodby |
Email Address | goodbygrading@comcast.net |
Affiliation | Goodby Grading Inc |
Subject | oppose |
Comment | Clarity and Comprehensibility: The regulation is too complex and lengthy: we do not fully understand it or its effect on our fleet. Before this regulation, we bought equipment based on what we needed to do our work. We will have to hire consultants to tell us what we can and must buy and when we will need to replace, retrofit, or repower what have. Capital-Intensive Industry: The value of our business is tied up in our fleet of construction equipment. To meet ARB’s requirements for newer equipment, we will have sell existing equipment. Rule Forces Downsizing of Capability: Because newer equipment costs more than our older equipment, ARB’s rule will force us to downsize our operations. Downsizing will limit our ability to perform on contracts and require us to take longer on the projects that we win. Unfair Retroactive Requirements: When we made our purchasing decisions and other investments, we relied on the standards that applied to us at the time. It is unfair to require us to retrofit or replace equipment that was legal when we bought it. ARB should regulate the manufacturers, not consumers. Cost Pass-Through: For us to win contracts, we cannot simply pass on the costs of equipment purchases to our customers. We have to absorb a significant portion of our own expenses. Increasing our expenses will overwhelm our narrow profit margin. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2007-12-21 17:59:06 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.