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This regulation will put small companies out of business.  The
normal process in equipment use is that large (very Large)
construction companies or equipment rental companies are the only
people in construction that buy new equipment.  It is just too
expensive for medium or small construction companies to buy new
equipment.  The equipment is passed down from larger to smaller
companies as it gets older and older.  As a result, the normal
life span for equipment is 20 years, with only small compnies
owning the oldest pieces.

If you make new equipment with better engines, it takes at least
10 years to filter down to the small companies and they have to
get another 10 years of use out if it.  Your regulation has to
give more time for older equipment to be cycled out of use and
then it should not start counting until there is equipment
available with engines that comply.

Also, your definition of a small company is okay for total HP, but
is far too low for dollar volume of work.  Most general contractors
subcontract out most of the dollar volume of work they do in a
year.  So it may look like we are doing a lot of work that might
use equipment, but in reality, a very small portion of our dollar
volume requires the use of equipment.

So the real affect of the regulation as written will be that being
a small contractor will become impossible.  Small contractors are
necessary for a functioning economy.  There is too much work that
is too small to interest large contractors.  Please revise the
regulation to give small companies a chance to plan and survive.