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I respectfully request that the rulemaking for New Limits on
Emissions from Existing Fleets of Off-Road Diesel Equipment be
reopened and re-evaluated in light of the serious downturn in the
economy.

I am President of Vulcan Construction & Maintenance, Inc.,
headquartered in Fresno, CA. Our company is a general engineering
contractor licensed in California and operating since 1981. The
majority of our work is in public work construction. We are a very
small company and very much impacted by the economic downturn in
California which started in 2007.

Downturn in Construction:
Compared to a "normal" year our present construction volume has
declined by 42%. 
We now see anywhere from 10 to 15 bidders on public projects where
ordinarily there are 4 to 5 bidders. With such a competitive market
it is impossible to pass on any higher cost. Like most California
contractor's we are struggling to survive this serious downturn.

Decline in the Consumption of Diesel Fuel:
Consumption of diesel fuel for our company has declined by 79% as
compared to a normal year.

Resale Value of Equipment in an Existing Fleet:
In anticipation of the new California Air Resources Board rules
our company sold at an auction all except one Tier 0 equipment. Our
observation has been that resale values of older equipment have
drastically declined.

Credit Being Extended to Construction Contractors:
We are experiencing severe restrictions on available credits in
addition to very tight covenants.

I strongly believe it would be in the best interest of
Californians to revisit the costly new CARB rules, especially in
light of the troublesome economy automatically resulting in reduced
emissions. Strict enforcement will result in many contractor's
going out of business.

Respectfully submitted,
Bruno Dietl
Vulcan Construction & Maintenance, Inc.