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I am writing to help explain the issue between Air Quality Agencies
and the Construction industry….to wit, the ‘coalition’ presents
costs as 13 billion while the ‘board’, 3 billion.  I have 40 years
of construction experience as a mechanical engineer involved with
equipment, its application, safety, and operation to give
perspective and expertise.

What is not understood is that construction is a very active and
time scheduled business, much more unpredictable than
manufacturing or most businesses.  It has to accommodate all the
‘unplannable’ variables like weather changes, and have people and
equipment available when needed, to continue work efficiently on
the ‘front’.  Anything that interferes or complicates this already
tough issue has a tremendously magnifying effect on costs.  The
unavailability of a piece of equipment because rules prevent its
use or delay availability once the need is identified, can halt
all progress on a site.

If one studies the bureaucracy imposed it will involve “permission
before proceeding” in an industry that is quite like the military,
it has to act timely.  (Can you imagine an army fighting a front
with impediments of authority and restraints such as time of day
allowed to launch specific weapons)?  This is why private
contracting is effective - it is less costly to contract work than
for the government to do it themselves, to get outside the self
imposed constraints, to allow risk and to reward
resourcefulness).

I suggest that the place to focus on making substantive
improvements is with manufacturers, and the fuel.  A retrofit
and/or a complex set of rules and exceptions will simply hamper
the progress of our state towards upgrading our infrastructure. 
The costs will be borne by the public, and must be fully and
accurately considered, by an independent unbiased and non
political technical group. The claims by construction operations
are not simply to be passed on, they are real and costly impacts
far beyond the apparent requirements. 

I believe we need a clear third party to judge the impact and set
priorities.  Imposing regulations on an existing fleet appears to
be misguided and overreaching.  And like the Nitrous Oxide
Retrofit programs of the 70's, the impact to fuel consumption and
requirements will increase as we face shortages.  

Dale Ronsin [Ronsin, Dale]   PE
Aptos, CA