Comment Log Display

May 21, 2007


Dr. Robert Sawyer, Chairman
California Air Resources Board
1001 “I” Street
P.O. Box #2815
Sacramento, CA 95812

Re:    Proposed in-use off-road diesel regulation - comments

Dear Dr. Sawyer:

Southern California Contractors Association (SCCA) represents
almost 330 signatory contractors and those companies who supply
them in the 12 counties of the southern section of our state. As
the only all-union signatory contractor’s association in our
region, we are deeply concerned about the impact these proposed
regulations will have on our members and the thousands of workers
they employ.

Our members are committed to improving the emissions from their
fleets, and for cleaner air for all.  For example, our members
make up the largest single group of companies participating in the
statewide portable engine registration program.

The proposed off-road regulation, which will force turnover of
virtually every existing machine in an unrealistic time-frame,
will have devastating effects on our members. The proposal does
not take into account that current technology will not meet NOx
requirements and the planned Tier 4 technology that will, will not
be available for purchase until 2014-15, in most of the horsepower
ranges used by the machines used by our members.

We respectfully request, in conjunction with the Construction
Industry Air Quality Coalition (CIAQC) of which we are a founding
member, that the NOx portion of the rule be abated by a minimum of
five (5) years, to allow technology to catch-up to meet the
regulatory goals; to do otherwise will force many companies to
replace their equipment two times in ten years—a recipe for
bankruptcy for most of our members.

We will be present to discuss these issues with you at the meeting
on May 25, 2007 in San Diego. We ask that you and the other members
of your board hear our industry’s concerns and act on our request
to preserve both California’s environment and its economy. 

Sincerely,


D. Cash Benton
Executive Vice President