Comment Log Display

CALPASC, the California Professional Association of Specialty
Contractors, has 500 member companies across California. Our
comments to the proposed amendments are as follows:
1. We totally support the comments submitted by Michael Lewis on
behalf of the CIAQC, in his letter dated 7-20-2009. 
2. We oppose the recommendation by the SCAQMD in their letter of
7-17-2009, wherein they recommend reducing the time limit for early
retirement credit. It will take a long time for the construction
industry in California to recover from the recession we are in,
which recession is not yet at bottom. 
3. There may be many small fleets who are yet unaware of the
amendments giving early retirement credit, and may not understand
the need to keep equipment information for equipment sold or
retired prior to their first reporting period. Staff should prepare
a process for those fleets to make a good faith appeal to the
Executive Officer, if they have difficulty finding the information.


Sincerely, 

Bruce Wick