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Comment 15 for In-Use Off-Road Diesel Fueled Engines (ordiesl07) - 15-1.

First NameWarren
Last NameSchmidt
Email Addresswschmidt@flatironcorp.com
AffiliationFCI Constructors, Inc. - Equip. Mgr
SubjectOff Road Diesel Rules
Comment
The measeure(s) you propose are very complex, hard to understand
even by your own staff(interpretations differ).
We have strived to start our compliance by selling off nearly all
our TIER 0 equipment which we feel we lost 10 -25% of what value
we expected at this time and age of the equipment sold (oldest
unit 13 years old). At this time with even a downed sized fleet
with nearly no TIER 0 engine, we still are not in compliance. We
see a time when even the newest equipment that we purchased this
year with TIER 3 engines will be obsolete within the next 5 years
unable to meet the standards for the fleet. While our company can
continue to update, the costs of doing so would have to be passed
along to our customers(public works) via higher bid prices. CARB
has taken so much time in deciding how to implement rules and
standards it has left less time for companies to be able to deal
with and plan for the future. The manufactures haven't even
developed the technolgy that you are asking for and given dates
for complaince.The harmful efects of PM and NOX have been
overstated to alarmist degrees. If the PM and NOX have always been
so toxic to the people of this state, why have effects only been
noticed within the last decade? Why aren't more Californians
suffering from respiratory health problems on an epic scale?

Attachment
Original File Name
Date and Time Comment Was Submitted 2007-12-26 07:34:28

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