Comment Log Display

I am writing today to register strong objection to the off-road
diesel regulations now being considered by the California Air
Resources Board (CARB).  In their current form, these regulations
would have a profound, negative impact on California’s
infrastructure rebuilding efforts, the health of the state’s
construction industry and its overall economy.  CARB is proposing
to take action on the regulations on May 24, 2007.

While my company supports reducing particulate matter (PM) and NOx
emissions from diesel engines, I am concerned that by accelerating
the timetable by which off-road diesel-powered vehicles must
comply with state limits, CARB is making compliance virtually
impossible.  There currently is no diesel engine that is capable
of addressing both PM and NOx emissions set forth in the
regulations.  In some cases the engines and equipment necessary to
meet the stringent standards in these regulations will not come to
market until 2014.  In essence, CARB is running the risk of
creating overnight a huge shortage of equipment needed to build a
variety of infrastructure, including projects funded under last
year’s infrastructure financing package as contained in
Proposition 1B through 1E.  

These regulations will produce immeasurable delays and costs to
critical infrastructure and housing development projects.  A
conservative estimate of the regulations’ cost is $13 billion.  

Now is not the time for the adoption of burdensome new regulations
that will only serve to further slow the housing market, put a drag
on the economy and disappoint California taxpayers who are anxious
to see the infrastructure funding they approved last fall go to
work in their communities today.  I strongly urge you to direct
CARB to withdraw the current proposed regulations at its May 24
meeting and commence immediate discussions with all stakeholders
to work out a more feasible plan to reduce diesel emissions.

Sincerely,

Headlands Reserve LLC

Sanford Edward