Comment Log Display

I received your notice regarding the additional 15 day notice for
public comment about the proposed regulation.  I went through the
entire 65 pages and then took 4 aspirin to get rid of the
headache!  These rules are so complicated that no one will go
along with this because it is almost impossible to understand. 
These were not written by someone at CARB and no one in the
private sector is going to be able to negotiate through all of
this without hiring outside help!

There in itself is your first point of failure!  You have written
requirements that will take a genius to interpret so that means
most will not comply!  As it stands, you are still targeting the
highest wage earners in this State and those most affected by the
regulations will be most affected by the loss of jobs.  The tricle
down effect will be felt all all levels with the decline in sales
of new equipment, the loss of tax revenues for same, the loss of
construciton jobs and the loss of tax revenue from same and
lastly, the high cost of complying will force many jobs to go
underground, done by fly-by-night contractors who hire illegals to
do their work!

I just recently came back from a week at the World of Concrete
Show in Las Vegas.  The main topic of discussion with almost every
equipment manufacturer or dealer there was this regulation and how
it was going to hurt or put them out of business.  Many of the
manufacturers are simply not going to sell equipment in California
and your used equipment will become worthless on the resale market!
 In other words, you are going to put those dealers, their sales
staff, mechanics & truck drivers out of work.  In turn, you will
lose sale tax revenue abound, un-secured property taxes for new
equipment that won't be purchased and have to deal with growing
unemployment in the construciton field!  Not a very pretty picture
for those who work for a State Government that is 14 billion
dollars in the red this year and will be for the forseeable
future!

You need to get away from making retro-active requirements on used
equipment and focus on what we can do with the new technology
coming out, not crucify what was acceptable just a few years or
months ago.  Working to improve the quality of emission standards
over the next 15 years in new equipoment will go a long way in
cleaning up our already, very clean air!  

That will also preserve the jobs and tax base that you so badly
need.  If you go ahead with this as planned, you can kiss those
jobs goodby and probably many State level jobs too because you
won't be able to pay for them.  

As a contractor with 32 years of business building experience and
with 70 employees, I cannot afford to reconstruct our equipment
and trucks to meet your standards without accruing enormous debt. 
So if they are inacted as you propose them, I will just start
shutting down our company and let those jobs and quipment just go
away.  I cannot afford to stay in business just to work to pay for
senseless over-regulation!

Weldon Birch, Pres.