Comment Log Display

Dear Members of the CARB Board,
     The regulations that you passed in 2007 are unfair to the
construction industry.  As a small business owner who maintains a
small fleet of equipment, I will be forced to downsize or
liquidate my entire fleet.  Most of my equipment is five to ten
years old, and even my newest pieces will need to be retrofitted. 
It would be unrealistic to consider raising rates enough to cover
our replacement costs, any more that to raise rates when we
purchase new equipment...it just doesn't happen.
     As a lifelong resident of Los Angeles, I can appreciate the
advances that have taken place in our air quality.  I also worked
in the automobile industry during the 60's and 70's and know that
very little retrofitting was preformed, most advances were
established through attrition and replacement.  I am aware that
heavy equipment and trucks last longer than typical
automobiles...but it seems we are being penalized for the lack of
initiative of the construction equipment industry and those
regulating the industry.  Auto emissions were in the spotlight 40
years ago, that surely would be enough time to phase in new
technology to the construction industry.
     One piece of equipment I own is a excavator mounted drill
rig.  This rig only runs about 200 hours per year, and costs
several hundred thousand dollars to replace...yet I would be
forced to replace or repower, according to your regulations.
     It seems to be an unfair advantage, that we the endusers will
have to pay consultants to help us navigate our way through tese
regulations.  The standing joke in my circle of contractors is:
When are you going to retire? (this is in referece to the
implementation of these regulations).  Except this is not a joke,
it will put many of us out of business...either by choice or
economic hardship.
     Please consider alternative phasing programs to help us help
you clean the environment.
Regards,
Larry Murakami