Comment Log Display

I am the Director of Risk Management for CALPASC, the California
Professional Association of Specialty Contractors. We have 550
members across the state, and those members employ approximately
75,000 people.
We oppose this regulation as proposed for the following reasons.
1. There is a huge discrepancy in estimated costs of compliance
between the ARB staff and industry. The truth of the actual costs
must be made known.
2. There was not typical stakeholder involvement in this
regulatory process. If there had been, there would not be such
consistent opposition expressed. 
3. This regulation is not ready to be approved. There will be
chaos instead of compliance.

Contractors need:
1. A level playing field when bidding jobs.
2. A regulation that is workable in practical terms.
3. A regulation where it is both clear and efficient to comply
with that regulation.
4. A regulation where the enforcing agency can enforce both fairly
and consistently. 

This proposed regulation in its current form accomplishes none of
these objectives.

What should take place:
1. A true stakeholder group should be convened. This group would
then roll up their sleeves, and come up with workable solutions.
The issues are important enough that monthly meetings could be
held, and real progress could be made in a short period of time.
2. A consensus would then be developed. Consensus is not
unanimity, but it is an agreement between most of the major
stakeholders.
3. A revised regulation would then be proposed. That revised
regulation would be accepted, enforceable, and fair. 

Thank You, 

Bruce Wick, Director of Risk Management 
CALPASC
909-793-9932