Comment Log Display

Dear Members of the California Air Resources Board;

The cost of complying with the proposed regulations for in-use
off-road Diesel Vehicles will force our Precast Coincrete Plant
operation to shut down.

Our plant has 35 to 40 employees that manufacture concrete
products for undergound infrastructure such as sewer manholes,
drainage inlets and invironmental storm water
interceptor/clarifier vaults for street and highway run-off.

The plant is serviced by seven diesel engine forklifts, two diesel
loader/backhoes and a diesel boom crane. Due to the competetive
nature of our business, we cannot afford new equipment and
generally purchase used equipment 3 to 5 years old.

Most of the equiipment is only used a few hours a day during peek
periods transporting concrete from the concrete batch plant to
product forms or loading trucks late in the afternoon for next day
deliveries.  Two of our least used forklifts are over 20 years old
but work efficiently for this low hour use.  We obviously could
not afford to purchase new equipment or replacment engines for
these applications or for all the rest of our rolling stock.  The
cost of replacement engines would far exceed the present value of
most of our forklifts and other equipment.

The type of precast business we are in is low profit margin and
highly competitive. The Boards suggestion that we can pass on this
tremendous cost of compliance to our customers is Unrealistic.
                  PLUS ! !
WE HAVE PRECAST PLANTS IN NEVADA AND OREGON, THAT CAN DELIVER
PRECAST PRODUCTS INTO CALIFORNIA, THAT WONT HAVE TO MEET CARB'S
NEW REQUIREMENTS AND INCUR THE HIGH COST OF COMPLIANCE.  THIS PUTS
OUR COMPANY AT A COST DISADVANTAGE THAT WE DO NOT BELIEVE WE CAN
OVERCOME. 

Some consideration must be given to small operations such as Cook
Concrete Products, that will not survive the high cost of
complying with the proposed regulations as presently written.

Respectfully submitted;
L. Edward Shaw,
President/Owner
Cook Concrete Products, Inc.
5461 Eastside Road
Redding, CA 96001