Comment Log Display

I have followed the development of the in-use off-road diesel rule
for the last couple of years.  ARB staff has attempted to assist
fleet owners to measure their fleets with an Excel based
spreadsheet tool.

More than once there have been announcements that the calculator
was available for use, and there was no link to locate it on the
ARB web site.  In the latest version, it was announced on 9 May
the revised calculator was ready.

I found myself spending time simply trying to find it . . . a
search of the web site did not help.  It simply was not available
for public use.

After contacting the staff, they gave me directions of where it
was located for download, but after reviewing the spreadsheet, I
needed to expand it to take the number of engines in our company's
fleet.  There were no explanations on how to do this.

Again, I wasted time attempting to make necessary changes. I was
told by the developer there would be update instructions
published, however, almost a week later, I have seen nothing.  It
is now about 10 days until the Board meeting, and I would be
willing to bet, most construction companies do not know what the
effects of the pending rule would cost in terms of updating their
fleets.

The complexity of the rule necessitates the use of a tool like
this, however, when it hits the street just a couple of weeks
prior to the Board's meeting, construction industry fleet owners
are not able to generate data from which they can make informed
decisions.

I would recommend that the development and roll-out process be
reviewed and changed to include better quality control.  You can
multiply the number of hours I wasted trying to use the tool by
thousands when the public is forced to use it.  Time is money in
the private sector, and issues like this would be deemed
unacceptable by industry.

This is another reason more time needs to be allowed between the
rollout of a tool like this and the Board's decision.  The time
crunch is simply unacceptable for most in the construction
industry to react.