Comment Log Display

Valentine Corporation is a General Engineering Contractor which has
been performing public works infrastructure construction in
California since 1964. We have the following comments concerning
your proposed off road equipment regulation:

1) The regulations is onerous and burdensome to the constructions
industry and will cost us a ton of money in equipment retrofitting
and liquidation. This is plainly unfair and punitive -- we
purchased our fleet in full compliance with the law at the date of
purchase. DO NOT change the rules after the fact unless you (the
State)are willing to foot the bill!

2)CARB SHOULD BE REGULATING THE EQUIPMENT MANUFACTURERS AND NOT
THE END USERS WHO BOUGHT THEIR EQUIPMENT LEGALLY!!! Standards
should be established for new equipment and existing old equipment
should be grandfathered in so that it can be used without
retrofitting for its useful life. Eventually, all equipment will
be compliant as older equipment expires. Regulate the
manufacturers and the soon enough california contractors will own
and operate compliant equipment. This seems logical, which is
something that can not be said of your prosed regulation.

3) Small contractors will be adversely impacted by the proposed
regulation -- we rely on used equipment and are the ones who will
be likely stuck with the retrofit bills for our older fleets. Why
is CARB penalizing small business?

4) We have read your proposed regulation and it is lengthy,and
unnecessarily confusing. If you are going to implement a new
regulation, please keep it concise and simple. Dumb it down if you
have to, but we don't need more confusing technicalties placed upon
our business, nor do we think it money well spent to have to hire a
consultant to interpret your regulations.

Sincerely,
Robert O. Valentine, P.E.
President