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    I would like to ask the staff creating this concept to revise
the requirement to retrofit all equipment that does not have a
factory installed exhaust after-treatment device or previously
retrofit with the highest level VDECS at the time of installation
in 2021.
    Over the next 13 years you will be requiring the fleet owners
of California to incur a substantial expense without regard for
economic fluctuations. The regulation will be difficult to comply
with during strong economic years, and nearly impossible in weak
years. Fleet owners will need to change most of there fleet
management procedures to meet Off-Road fleet targets along with
meeting requirments for there On-Road and Portable equipment
fleets. After working hard to meet the 2020 targets fleet owners
are rewarded with another requirment that does not allow for the
useful life of equipment.
    I have modeled all of Knife River Corporation's California
fleets and find the equipment that falls into this portion of the
regulation, is generally small, low horsepower, short life
equipment. Most of which will be purchased in 2009 to 2012 to
replace existing equipment early in order to meet early targets.
Now it will be necessary to replace it early (again) or retrofit
without the ability to spread the cost of retrofit due to its
expected useful life.
    I would like to ask that the 2021 requirment be move to 2025
to allow fleet owners to get back to a normal turn over cycle. The
PM and NOx reductions will be greater in 2025 with new equipment
than that of older retrofit equipment forced to run longer.