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I have a number of problems with the SOON program, the biggest of
which are:
1.  The definition of a small fleet should not include any dollar
volume limits.  Contratactors vary greatly in how they do work. 
One contractor could do a huge dollar volume but own no equipment.
 Another contractor might not do much dollar volume but does
operate many thousands of HP in old, dirty equipment.
2.  Because small companies tend to own the older equipment, you
are discriminating against the small business owner.  At least
give him a chance to slowly replace old equipment with newer
equipment over a period of 10 years.
3.  Right now you are requiring us to repower or replace equipment
with engines that won't comply with your regulation's pollution
requirements because compliant engines are not yet available.  As
I said, contractors expect to get 20 years out of a piece of
equipment, You are making us spend money on equipment that will
become noncompliant in less than 10 years.  It is a waste of
money.  Do not penalize us until we have a way to satisfy your
requirments.