Comment Log Display

While I am not a contractor, I am an insurance underwriter who
specializes in underwriting contractors.  Your proposed rules will
have a direct impact on MANY of my customers, some of whom have
become good friends.  I am very concerned that your proposed rules
will drive them out of business.

Your rules, as proposed, require the purchase of technology that
does not yet exist.  Tier 4 engines do not yet exist.  CARB VDECS
do not yet exist for most equipment.  The notion that equipment
must be retrofitted with VDECS only a few years before it must be
replaced with Tier 4 engines is one of the most ludicrous
anti-business proposals ever.

The state is not supposed to impose unfunded mandates on local
governments.  There should at least be some sane limits on
unfunded mandates for what are mostly small businesses.

It was appropriate for the federal government to impose fuel
mileage and emissions requirements on automobile and truck
manufacturers.  It would be appropriate to impose similar
requirements on manufacturers of off-road diesel equipment.  Until
the equipment that meets your proposed requirements becomes
availabe, it is patently absurd to require contractors to buy it.

Most contractors operate with profit margins between 2% and 5%. 
With a profit margin of 4%, it would require them to complete
$25,000,000 of work to be able to replace $1,000,000 of
equipment.

CARB has suggested that contractors should just build the cost of
the new equipment into their prices.  That might make some sense
if everyone used published prices, but is amazingly naive for
contractors.  The public contract code and other laws and
regulations prohibit collusion in bidding public work.  

Under CARB's proposed regulations, contractors who wait the
longest to replace their equipment would be able to underbid the
contractors who quickly replace their equipment, driving those who
did what you wanted out of business.  Your proposals are
counterproductive at best.

There is no doubt that diesel emissions are bad for the
environment, and we all want a cleaner environment.  We also want
jobs, safe streets, and uncongested highways.  The voters of
California recently approved the spending of billions of dollars
over the next few years to repair California's badly decayed
infrastructure.  Who is going to do that work if CARB drives the
cost of those projects up or drives the contractors out of
business.