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Per my previous letter regarding this Standard and its implemation,
this is simply too hard to determine how you are going to comply
with it and who is going to do anything at all?

Off road equipment is being targeted for no apparent reason as far
as most of us are concerned because it is an easy target for
addtional revenues, whether it be fees or fines.  With the weather
we are experiencing now, most all of this type of equipment is
sitting, not working!  As are the men who operate it and the
Contractors who own it.  If you implement this law as written and
backdate compliance standards to include older equipment, many of
thos now working today will not be working in the future!  Plus,
because this equipment sits for many months out of the year
because of weather conditions, it runs overtime during the dry
time of year to catch up.  You are penalizing those who have to
work and live with that type of schedule and cannot do anything
about it at all!

Also, to make equipment meet those standards retroactively, you
are forcing those of us who plan long term on purchasing equipment
with long lift expectations to not do that because of the standards
that are being changed after the fact!  One reason that our
equipment does last for a long period is because it doesn't run
every day of every week.  Just like now, some will sit out the
winter before firing up again next spring or summer.

All of us want cleaner air but you are targeting and will affect
the highest average wage earners in California and also kill sales
of new, big ticket construction equipment tools in this State. 
That too will have far-reaching repercussions as it trickles down
to New & Used Equipment Dealers, Truck Dealers and all those
directly affected by loss of those jobs in the private sector. 
Not to mention, the lost sales & property tax revenues, to go
along with lost Income Taxes!  Add in a 14 Billion dollar deficit
in your State Budget and I can't see why you would want to risk
losing even more revenue and jobs?

This plan will simply not work the way you think it will and for
most of us who will be hit hardest by this you can count on
layoffs and reducttion in our work force.  It will create a
totally unbalanced playing field for our Union Workers trying to
compete with those companies who will simply not comply with your
regulations!  Most of our Union workers, and that excees 60 most
all year long, will be affected and they VOTE!  

Hopefully you will revisit this with a new and better solution to
what most of us don't really see as a problem in this State. There
are plenty of other issues you need to tackle before you start
implementing job killing regulations like these.

Respectfully,
Weldon Birch, Pres. & CEO
Cal West Concrete Cutting, Inc.