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Comment 62 for Truck and Bus and In-Use Off-Road Regulation Updates (dec09update) - Non-Reg.

First NameMike
Last NameTelfer
Email Addressmike.telfer@telferoil.com
AffiliationTelfer Oil Company
SubjectImplementation of Diesel Regulations for Off-Road Equipment
Comment
Telfer Oil Company is a medium sized business that has operated in
California and surrounding states since 1958.  We are a company
concerned with the welfare of the people of the state of California
and the environmental impacts that we have on this state through
our business practices.  We strive to have as small a carbon
footprint as possible.  

However, we are a road construction company that operates 35
pieces of “off-road” diesel equipment, constituting 4518 HP.  43%
of this equipment, or 15 units, will need to be replaced or
retrofitted under the current CARB program.  Some of the units
needing replacement are as new as 2002.  The approximate cost to
install the retrofit equipment is $30,000 each for a total of
$450,000.00.  In addition, we have not been given any idea of
additional requirements that may come along as the next Tier is
instituted.  

The bottom line is the expense to do these retrofits in the
current economic climate and downturn is onerous to our business. 
We will not be able to invest those monies back into our business
which would result in job creation.  

We ask that CARB reconsider its’ initiation of these requirements
to a timeframe when the economy is in better shape and these
expenses can be absorbed.  

Attachment
Original File Name
Date and Time Comment Was Submitted 2009-12-08 11:57:19

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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