Comment Log Display

Dear California Air Resources Board Members:

Orange County Business Council includes among its members some of
the largest employers in the state and nation, with over 2,000,000
employees worldwide.

On behalf of OCBC, I am writing today to register strong objection
to the off-road diesel regulations now being considered by the
California Air Resources Board (CARB).  In their current form,
these regulations would have a profound, negative impact on
California's infrastructure rebuilding efforts, the health of the
states construction industry and its overall economy.  CARB is
proposing to take action on the regulations on May 24, 2007.

While my organization supports reducing particulate matter (PM)
and NOx emissions from diesel engines, I am concerned that by
accelerating the timetable by which off-road diesel-powered
vehicles must comply with state limits, CARB is making compliance
virtually impossible.  There currently is no diesel engine that is
capable of addressing both PM and NOx emissions set forth in the
regulations.  In some cases the engines and equipment necessary to
meet the stringent standards in these regulations will not come to
market until 2014.  In essence, CARB is running the risk of
creating overnight a huge shortage of equipment needed to build a
variety of infrastructure, including projects funded under last
years infrastructure financing package as contained in Proposition
1B through 1E.  

These regulations will produce immeasurable delays and costs to
critical infrastructure and housing development projects.  A
conservative estimate of the regulations cost is $13 billion.  

Now is not the time for the adoption of burdensome new regulations
that will only serve to further slow the housing market, put a drag
on the economy and disappoint California taxpayers who are anxious
to see the infrastructure funding they approved last fall go to
work in their communities today.  I strongly urge you to direct
CARB to withdraw the current proposed regulations at its May 24
meeting and commence immediate discussions with all stakeholders
to work out a more feasible plan to reduce diesel emissions.

We're all for better air quality, but not at the expense of jobs,
homes and good quality of life for Californians.  There has to be
a better way.

Sincerely,

Lucy Dunn
2 Park Plz Ste 100
Irvine, CA 92614