Comment Log Display

Dear Members of the California Air Resources Board:

Hello, my name is Bob Engel and I am a second generation owner of
a small construction, trucking and recycling company.  I am aware
taht the California Air Resources Board (CARB) is currently
considering the adoption of off-road diesel regulations that, if
implemented as presently drafted, would have a profound, negative
impact on my business.  We have been in business since 1946, YES,
61 years of providing jobs and service for Californians.  These
regulations would cripple our ability to provide services such as
our regional compost facility that provides crucial recycling for
our region of California.  The economic burden would be to much
for our small company to absorb on top of cutting our asset values
significantly.

Recyclers, envrionmental company's, Construction contractors and
the many workers want these regulations to work for everyone.
That’s why we understand the industry has proposed an alternative
approach which would clean up the air while keeping the most
number of recyclers, environmental and construction companies in
business and WORKERS employed.   Adopting the industry proposal
woulded keep the bidding environment at its most competitive; the
Rebuild California bond program on schedule; and construction cost
increases to a minimum.

I am writing to ask you to support this alternative at the CARB
meeting on July 26th  It will give California the cleanest off
road fleet in the world while ensuring recyclers, einvironmental
companies, construction contractors and workers are kept on the
job. 

The goals of this plan are simple:

1. 	Achieve better emission reduction for 2015 than the CARB
proposal.
2.	Keep the same starting date as the CARB proposal.
3. 	Require annual reporting to demonstrate progress toward the
goal.
4.	Provide maximum flexibility for contractors to reach the
target.
5. 	Allow more time at the back-end for new Tier 4 engines to
enter the fleet (estimated to be approximately 2014/2015)
6. 	Recognize the wide divergence in fleet sizes, emissions and
capabilities.
7. 	Permit each fleet to determine how best to achieve the
reductions.
8.	Give credit to those fleets that provide early emissions of
both NOx and PM.
9. 	Minimize the financial impact to keep the most firms in
business.
10. 	Maintain a highly competitive bidding environment.

The most significant difference between the CARB proposal and the
alternative plan is moving the 2020 goal for large fleets to 2025,
which is necessary in order to allow more time for Tier 4 engines –
which will achieve all the emission targets without any further
retrofitting and will not be available until 2014/2015 – to enter
the market and be acquired by contractors.                        
 

I want to be clear: Engel & Gray, Inc. is very supportive of
reducing particulate matter (PM) and NOx emissions from diesel
engines. There is no disagreement that we need to work
collectively to improve the state’s air quality and all of us want
to provide as healthy an environment as possible for our employees
on our job sites. Please consider adopting this sensible
alternative that accomplishes the same, if not better, emission
reductions while keeping California’s construction industry and
our state moving forward.

Sincerely, 

Bob Engel
Vice President
Engel & Gray Inc.