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Comment 153 for In-Use Off-Road Diesel Fueled Engines (ordiesl07) - 45 Day.

First NameWarren
Last NameSchmidt
Email Addresswschmidt@flatironcorp.com
AffiliationFCI Constructors, Inc.
SubjectPending CARB Regulations
Comment
Our fleet of off highway diesel engine numbers about 85 and about
13,500 HP at this time. The average age of our fleet is 6 year
old. With the current CARB emission calculator our fleet will not
be in compliance in 2010.
There are many more companies large and small whose equipment is
older and will not comply. Even if I dispose of ALL of my TIER 0
equipment (which is only 6 units(7%))I still won't be in
compliance under the proposed regulations. Please understand the
the replacement of these 6 units represents an investment from our
company of $600,000 to $1,000,000 and still be short of the
proposed requirements, and we only in the first year of
regulation! I haven't seen or been informed of very many
"approved" exhaust traps and the ones I have heard about are very
expensive, the numbers I've heard are around $20,000 to 40,000 per
unit which only buys you some time. Replacement will still need to
be made at some point. An co-operative effort heavily involing the
industry and CARB needs to be made to achive a workable solution to
keep California Building and not stuck in a world of unworkable
requirements.

Attachment
Original File Name
Date and Time Comment Was Submitted 2007-05-24 08:59:08

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