Comment Log Display

•	The value of our business is tied up in our fleet of construction
equipment.  To meet CARB’s requirements for newer equipment, we
will have to sell existing equipment which, with the new
regulation, has lost most of its value. 
•	The engines we need to purchase to be in ultimate compliance
with this rule do not exist in the market today and won’t for at
least another six years. Due to this, we will be forced to spend
hundreds of thousands of dollars to retrofit equipment that in
less than ten years we will have to turn around and replace.    
•	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. With this rule CARB, for the first time,
is regulating the consumer of equipment rather than the
manufacturers.    What makes more sense, as with the auto
industry, the new equipment should be phased in with the
manufacture of said equipment.
•	Basically these requirements will put us out of business and our
investments, some of which were made with our retirements in mind,
will be worthless.