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WIPF CONSTRUCTION
1300 HASTINGS RD./P.O. BOX 234
UKIAH, CA 95482
PHONE (707)462-8741
FAX (707)462-5409




DECEMBER 11, 2008	


AIR RESOURCES BOARD MEMBERS



	WE ARE WRITING YOU IN REGARDS TO THE OFF ROAD AND ON ROAD HEAVY
DUTY DIESEL ENGINE REGULATIONS THAT ARE PRESENTLY BEING PROPOSED
FOR ADOPTION.  AS A SMALL EXCAVATION AND TRUCKING CONTRACTOR, WE
WILL BE HEAVILY IMPACTED BY THESE REGULATIONS.  THE CAPITAL
INVESTMENT REQUIRED TO MEET THOSE REGULATIONS, WITHIN THE TIME
FRAMES OUTLINED, CANNOT BE SUPPORTED BY MOST COMPANIES.  ONLY THE
LARGE MULTI-STATE OR MULTI-NATIONAL COMPANIES WILL BE ABLE TO
SURVIVE.  THEY WILL BE ABLE TO ACCOMPLISH COMPLIANCE, ONLY BY
SHIPPING THEIR OLDER TRUCKS AND EQUIPMENT TO OTHER STATES TO WORK,
REPLACING THIS EQUIPMENT WITH NEW IN CALIFORNIA.  SMALLER
CONTRACTORS WILL NOT HAVE THE ABILITY OF HAVING THEIR OLDER
EQUIPMENT SUPPORT THEIR NEW EQUIPMENT AS WE HAVE IN THE PAST.  THIS
WILL CREATE A LARGE COMPETITIVE ADVANTAGE FOR THE VERY LARGE
CONTRACTORS, PUTTING MOST SMALLER CONTRACTORS OUT OF BUSINESS.
	WE HAVE BEEN IN BUSINESS FOR 20 YEARS, AND BY BEST CALCULATIONS,
WE WOULD HAVE TO PUT 100% OF OUR NET PROFITS INTO RETROFITTING OR
REPLACING OUR EQUIPMENT FOR THE NEXT 20 YEARS TO BECOME COMPLIANT. 
THE REGULATIONS, AS PROPOSED, WILL REQUIRE US TO BE COMPLIANT IN
LESS THAN 7 YEARS. HOW CAN WE BE EXPECTED TO REMAIN IN BUSINESS
WHEN OUR RATES WOULD NEED TO TRIPLE IN ORDER TO PAY OFF THE CAPITAL
INVESTMENT THAT WOULD BE REQUIRED, WHILE THE VERY LARGE CONTRACTORS
WILL BE MOSTLY REPLACING THEIR EQUIPMENT AS USUAL, MOVING OLD
PIECES OUT OF STATE.  COMPANIES SUCH AS OURS REQUIRE OUR OLDER
EQUIPMENT TO SUPPORT THE NEW PIECES WE PURCHASE, IT IS THE ONLY WAY
WE CAN COMPETE AND SURVIVE.
	
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	IN THE HANDOUT THE CARB  HAS BEEN DISTRIBUTING AT THEIR PUBLIC
MEETINGS, THERE IS A PIE-CHART THAT SHOWS WHERE 
THEY BELIEVE OUR EMISSIONS FROM VEHICLES COME FROM.  THIS CHART
SHOWS THAT 20% COMES FROM HEAVY DUTY, WHICH INCLUDES GAS ENGINES
AND MOTOR HOMES WHICH ARE NOT IN THESE REGULATIONS.  IN THEIR
STATISTICS THE BEST IMPROVEMENT IN EMISSIONS FROM VEHICLES THAT MAY
BE ATTAINED THROUGH THESE REGULATIONS MAY BE 10 – 15% REDUCTION. 
ANOTHER PIE CHART SHOWS THAT OF ALL OPERATIONS IN CALIFORNIA,
TRANSPORTATION CREATES ONLY 38% OF ALL GREENHOUSE GAS EMISSIONS. 
SO, BY ENACTING THESE REGULATIONS YOU WILL BE REMOVING 10 TO 15% OF
38% OF ALL GREENHOUSE GAS EMISSIONS.  THIS MAY BE A MONUMENTAL
REDUCTION OF MAYBE 3.8 TO 5.7 PERCENT.  WE DON’T BELIEVE THIS IS A
PERCENTAGE REDUCTION THAT WOULD WARRANT PUTTING MOST SMALL
CONTRACTORS OUT OF BUSINESS, PUTTING THEIR EMPLOYEES OUT OF A JOB
AND CREATING ECONOMIC CHAOS IN CALIFORNIA.
	WE WOULD PROPOSE A PLAN TO BUILD MORE MASS TRANSIT, GIVE PEOPLE
TAX CREDITS FOR UTILIZING MASS TRANSIT, REMOVING MAYBE 10 TO 25% OF
THE CARS OFF THE ROAD.  THIS WOULD YIELD A 7.4 TO 18.5 PERCENT NET
BENEFIT IN GREENHOUSE GAS EMISSIONS.  THIS PLAN WOULD ALSO GENERATE
CONSTRUCTION JOBS IN OUR SAGGING STATE ECONOMY, INJECTING CAPITAL
HELPING US TO UPDATE OUR FLEETS.
	IN CLOSING, WE HAVE BEEN RESEARCHING RETRO-FIT DEVICES.  THE
DEVICES THAT ARE PRESENTLY AVAILABLE ARE NOT ABLE IN MOST CASES TO
NOT COMPLICATE THE OPERATION OF MOST EQUIPMENT THAT THEY WILL BE
PLACED ON.  WHY DON’T WE ATTACK OUR GREENHOUSE GASES FROM ANOTHER
ANGLE, AND ALLOW OUR TRUCKS AND EQUIPMENT TO CYCLE OUT AS AGE AND
WEAR REQUIRE THEIR REPLACEMENT AS IT WAS DONE WITH PASSENGER
VEHICLES.  IT SEEMS TO US THAT BETTER PLANS CAN BE FORMULATED,
ALLOWING SMALL CONTRACTORS AND THEIR EMPLOYEES TO CONTINUE WORKING,
WHICH IS WHAT WE BELIEVE PAY YOUR SALARY.  THANK YOU FOR YOUR
CONSIDERATION IN THIS MATTER, HOPEFULLY IT IS NOT TOO LATE TO SAVE
US FROM THE ECONOMIC DEVASTATION THESE CARB REGULATIONS WILL LEAD
TO.


					SINCERELY, 
					ERNIE WIPF
					WIPF CONSTRUCTION	


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