Comment Log Display

First, I want to assure you that Jos. J. Albanese, Inc. supports
the reduction of PM and NOx emissions from diesel engines.  This
fact is evidenced by the hundreds of thousands of dollars we spent
to comply with the PERP regulations and the additional hundreds of
thousands of dollars we've committed to comply with the off-road
diesel regulations.  Although both of the aforementioned were well
intentioned regulations, I suggest they were ill-conceived without
any regard to the true economic impact on jobs and business in
California.

Second, given the current economic crisis and resulting dramatic
decrease in jobs, the enactment of this On Road Regulation will
hurt our business while crippling the industry.  This regulation,
like the off-road, will force the disposal of capital equipment
prior to the end of its useful life, reduce any potential re-sale
value of same, and require the investment of significant capital in
new equipment (or alternatively simply get out of the business).  

Individually, each of the aforementioned consequences will cost
jobs, tax revenue, and create an impossibility to comply given the
frozen credit markets; cumulatively, they will continue to
eradicate any opportunity for construction to lead the State out of
its current economic turmoil.

As the engine of job creation, this is the last industry that can
afford this economic assault, albeit a well intentioned one.  This
regulation will cost billions of dollars and last I checked, our
industry is not eligible for federal bail out money!  

I urge you to carefully consider the consequences of this
regulation and either reject it until a better time or support the
alternative proposal proposed by the DTCCC (Driving Toward a
Cleaner California Coalition.  The latter would give companies like
ours a reasonable and flexible time frame to absorb this
regulation.  

Please, look at this regulation, not through a narrow view of
on-road regulation, but from the global view of all the expensive
regulations adopted by this Board.  California needs a chance to
crawl from the depths of this recession; passage of this regulation
will reduce the likelihood of this happening. 

Kevin J. Albanese
Vice President/Chief Operating Officer
Joseph J. Albanese, Inc.