Comment Log Display

California Groundwater Association
	        An NGWA Affiliate State
	         P.O. Box 14369 „H Santa Rosa, CA 95402 „H (707)
578-4408
	            Fax: (707) 546-4906 „H email: wellguy@groundh2o.org
Established 1948

December 9, 2008

Mary Nichols, Chairman 
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Dear Chairman Nichols:

Re: Request for Modification of On-Road Diesel Truck and Bus
Regulation

On behalf of the members of the California Groundwater
Association, we are requesting that the California Air Resources
Board make modifications, as noted below, to the proposed On-Road
Diesel Truck and Bus Regulation.   For the last 60 years, the
California Groundwater Association (CGA) has represented the
groundwater industry in the state.  Our members include water well
drilling and pump installing contractors, industry manufacturers
and suppliers and technical experts such as geologists,
hydrologists, engineers and others in the private sector and
government.

CGA represents about 430 groundwater contracting firms employing
about 2,440 persons.  Non-contractor firms (1200) employ about
37,500 persons in the industry.  The groundwater industry is not
large in numbers but its functions are critical to the stateˇ¦s
wellbeing.  In times of drought, groundwater supplies up to 50% of
the stateˇ¦s water needs.  As you are well aware, California is
experiencing insufficient water supplies, as it has in the past. 
The groundwater industry has been able to help meet past challenges
of droughts but reduction of the industryˇ¦s capability to provide
groundwater will have adverse affects to all citizens of the
state.

Current and proposed CARB regulations will lead to reduced
capability to provide groundwater supplies unless modifications are
made.  The groundwater industry deals with complex geology and
hydrologic conditions throughout the state and must utilize a wide
variety of equipment in order to develop groundwater supplies for
the stateˇ¦s needs.   Much of that equipment is quite specialized
and has low or limited usage.  Thus the groundwater industry has
much equipment that is old (in years) but has had little usage and
is still in sound, usable condition.  For example, you may have a
drill rig that that is 25 years old but only driven 10,000 miles. 
There is not rapid turnover of equipment in this industry.  

The wide variety of equipment also means that groundwater
contractors must comply with an number of CARB regulations such as
the Portable Equipment Registration Program (drill rig deck
engines), the Off-Road Diesel Vehicle regulation (dozers, backhoes,
forklifts, etc.) and now the proposed On-Road Diesel Truck and Bus
regulation (drill and pump rigs, water trucks, rig tenders and
other vehicles needed for well construction and maintenance). 

A CGA survey has shown that the industry is attempting to comply
with the current regulations but many groundwater contractors have
small, local operations and are being forced to downsize or perhaps
even close their doors.  One contractor told us he would have to
cut his drill rig fleet in half (from 4 to 2 units).
Another contractor estimated the replacement costs to bring the
companyˇ¦s equipment into compliance with CARB regulations would be
twice the companyˇ¦s net worth.  He is considering closing his
doors.  The potential loss of the industryˇ¦s capability, due to
CARB regulations, to provide water could cripple the state.   One
can live without many things, but food and water are necessary with
water being essential ˇV even to grow crops.  

We note that the proposed On-Road Diesel Truck and Bus regulation
has agriculture industry provisions that provide exemptions for
specialty agricultural vehicles and extension of compliance dates
for both low-mileage and limited-mileage agricultural vehicles.

Certainly, the reasoning that resulted in the agricultural
provisions would also apply for the groundwater industry that
provides water for agricultural, domestic, municipal and industrial
uses.  In fact, a recent air emissions study prepared by a
groundwater manufacturer determined that water well equipment
accounted for 0.019% of all total emission hours in the US in
2007.

CGA requests that the California Air Resources Board delay
approval of the On-Road Diesel Truck and Bus regulation and direct
CARB staff to develop, and include in a subsequent revision,
provisions that provide exemptions for specialty groundwater
industry vehicles and extension of compliance dates for both
low-mileage and limited-mileage groundwater industry vehicles.  CGA
stands ready to assist staff in the development of these new
revisions.

While CGA proposes specific provisions for the groundwater
industry to help avoid catastrophic impacts on needed current and
future water supplies, we also recognize the impacts these
regulations have on other sectors of Californiaˇ¦s economy, the
environment and the publicˇ¦s wellbeing.  

Thus, we support the alternative proposal from the Driving Toward
a Cleaner California (DTCC) as a means to provide flexibility in
attaining improved air quality.  This proposal offers all affected
industries a number of ways to reach improved air quality.  The
more flexible mileage exemptions, dedicated specialty use vehicle
considerations, and a personalized compliance schedule for
businesses affected by two or more ARB rules would be of direct
help to the groundwater industry.  We look forward to meeting with
ARB staff to help ensure the continued capability of the
groundwater industry to help meet the water needs of all
Californians.
 
Sincerely,

J. Michael Mortensson

J. Michael Mortensson
Executive Director 

cc: Governor Arnold Schwarzenegger