Comment Log Display

Urke Enterprises Inc.
Al Urke
13924 Day Spring Road
Grass Valley, CA 95945
530 273-1502  Fax: 530 274-1502

										May 10, 2007

Dear CARB Board Members:

My input regarding your retroactive diesel engine retrofitting is,
DON¡¦T DO IT!

We are a small family business with three full time and two part
time employees.  We buy equipment as needed (mostly used).  And we
endeavor to maintain it for the longest possible usage in order to
reduce our overall cost.  This enables us to stay in business and
feed our families.

Here are the reasons I oppose your proposal:
„h I see no documentation as to the additional fuel usage that
will be caused by the reduced power in equipment because of
emission control devices.  I have yet to see emission control that
increases fuel economy.  More fuel burned equals more emissions.  I
doubt the net gain in reduced emissions will be much.
„h Changing engines in trucks is in the realm of possibility
because there is some space in the chassis.  However, changing
engines in tractors, graders and other heavy equipment is another
story.  In heavy equipment, sometimes the engine is integral to
the frame or it is the frame.  You are asking us to throw away
equipment that we have spent years (10-20) acquiring and
maintaining in order to run a profitable business.
„h I don¡¦t think the infrastructure is available to design, build
and install what you are asking for.  There are simply not enough
manufacturers, designers and mechanics to do all this work in the
short timeframe you are outlining.
„h Probably the most onerous aspect to this proposal is who is
going to enforce the mandate.  In my mind I see anarchy happening.
 Sure you can find the Teicherts and Granites of the world, but how
about Joe Blow and his 1975 Case backhoe out on the farm?
„h What you are proposing is a retroactive TAX on businesses to
fund clean air.  I would suggest either that you foot the bill or
I can send the names of past customers and you send them a tax
bill.  Then give us a grant to fix our equipment.  Or perhaps buy
us new equipment.  This sounds absurd, doesn¡¦t it?  Well, your
proposal is just as absurd.

In conclusion, yes, we want clean air.  So take a more sensible
approach and require new equipment to meet some reasonable
standard and phase in cleaner equipment over the years to come. 
This can be budgeted in by the industry and the increased costs
can be passed on to our customers as needed.  

This is a retroactive tax.  Don¡¦t do it!

Al Urke, President
Urke Enterprises, Inc