Comment Log Display

People,

I fully appreciate the efforts of the State of California to
improve air quality, especially in those areas where pollution
tends to concentrate.   Requiring smog control devices on
automobiles with gas engines was a positive move that set the
standard for the entire country.  Diesel engines have long been
exempt for all the wrong reasons.  Diesel engines should also have
clean air engineering from cradle to grave and I support
legislation that will make it so.   I do not, however, support
diesel engine retrofit requirements that adversely effect small
business.  These requirements end up being draconian and are
designed to force older equipment out of use.   I especially find
the proposed off road diesel requirements far too broad and a
significant hardship for small farmers, contractors and business
people.  After too many years letting the manufactures get by
without significant compliance, the State is now picking on the
small man because it thinks it can.

Just as the smog control regulations exempt older cars, the diesel
regulation rules should take into consideration the difficulties of
compliance for owners of older equipment.   The rules, as proposed,
would force the retirement of many pieces of equipment that get
limited use, but otherwise are extremely important for their
owners when they are needed.   The fact of the matter is, that
most any machine eventually it breaks down, and the economics of
the situation leaves it rusting in the field or dragged off to the
metal scrapper.   Old tractors and equipment  are just too
expensive to repair and their age often does not justify the
costs.  Businesses and farmers who use diesel equipment every day,
renew their equipment for the associated dependability, improved
performance and comfort the new units offer.   The used equipment
market is for those who can’t afford the new technology and can
get by with the limited service of an older machine.   Businesses
that put a lot of hours on their equipment, typically run newer
machines because they cannot afford the down time associated with
older units.

Granted, the air quality in metropolitan areas and parts of the
central valley cannot bear the added pollution from any source,
let alone diesel equipment.   In other rural areas of California,
there is no need to require any measures.   In areas where the
pollution levels are significant, I believe there is a limit to
how far government should go and who should be impacted. 
Criminalizing activity that is necessary to continue to operate a
small farm or business enterprise profitably is counter
productive, if not onerous.  Costly retrofits, the design of which
is intended to retire older equipment would make for extreme
hardship for those already challenged to make a living in this
economy.  

If the technology existed for a simple bolt-on tailpipe solution
similar to a spark arrestor or muffler, there might be a way for
some to comply, but requiring a complex and expensive  retrofit to
equipment that has little resale value is ridiculous and leaves
small operators with no choice except to become scofflaws.  Before
any punitive regulations are put into place, other measures should
be promoted.  Perhaps making biodiesel more readily available and
requiring its use on older equipment would be another option.  But
in the end, the improvements in technology should be required at
the manufacture of equipment, whether it is a lawn mower or a back
hoe.   The older equipment will fall out of use as time goes by.  

-Nicholas Pinette
 454 McAuley Street
 Oakland, Calif.  94609