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While we are supportive of reducing particulate matter from diesel
engines, CARB's proposed regulations for replacement and/or
retrofitting starting in 2010 is too onerous for our company. 
Companies like ours are being asked to dispose of equipment and
assets before their useful life and purchase new equipment before
financially feasible.  In this tough economic climate, this is an
unreasonable proposal.

We ask that ARB adopt the Driving Toward a Cleaner California
(DTCC) coalition's alternative proposal, which we consider to be a
balanced solution.  It would give companies like ours the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions.  Also, ARB's own analysis of the DTCC alternative
proposal confirms that it would result in similiar long term
emissions benefits.  Our company urges you to support the DTCC
alternative - we cannot risk the potential negative economic impact
of CARB's original regulation.