Comment Log Display

Marine Terminal Operators should not be required to adjust,
set-aside, or re-engineer very expensive and mission critical CHE
units in order for manufacturers to continue to bring their
products up to the operational emissions standards of the State and
POLB. It is our position that manufactures have pre-maturely
introduced products into the market in a rush to obtain market
share when in fact many of these emissions control products have
not been fully vetted within the Marine Terminal environment. It is
also our position that additional funding must be made available
and additional time allotted to both Marine Terminals and
manufacturers for achievement of requisite real-world compliance
and performance testing. To date this has not been the case. The
Ammendments as proposed would let manufacturers continue to
transfer responsibility for full vetting of products to the end
user.

Finally, we request that CARB and the State of California give full
and serious consideration to adjustments to the proposed amendments
as outlined in the PMA’s June 20th letter to the California Air
Resource Board.