Comment Log Display

Et al-
     
  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 California’s infrastructure rebuilding efforts, the
health of the state’s construction industry and its overall
economy.

As a General Contractor we specialize in public work projects,
prisons, hospitals, education establishments, street maintenance,
transportation improvements, etc. We will be severely impacted:
1.	By cost to implement said standards
2.	Timeframe for completion will suffer due to lack of compliant
equipment
3.	We will not be able to carry the tremendous burden stated
herein

We want to be clear; Wysong Construction Co is very supportive of
reducing particulate matter (PM) and NOx emissions from diesel
engines. In fact, using the Carl Moyer program over the past five
years in Southern California alone, the construction industry has
replace more then 1,000 high polluting engines, resulting in a
reduction of more then 3,787 tons of pollution every year.

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. However, in their current form, the Board’s proposed
regulations are not viable from an economic or technological
perspective.

When CARB first announced its intention to promulgate these
regulations in 2000, their plan called for an 18-year timeline to
meet the state’s goals or reducing particulate matter emissions
only. Due to delays in developing these rules, that timeline has
been reduced to 13 years. In addition, the regulation on NOx
emissions has been added to the rule – which significantly alters
the kind of technology needed for companies to be in compliance.

There currently is no diesel engine that is capable of addressing
both PM and NOx emissions. This lack of equipment technology and
availability are serious barriers to meeting the targets under
these rules. In some cases the engines and equipment necessary to
meet the stringent standards in these regulations will not come to
market until 2014. In addition, an estimated 165,000 pieces of
machinery will have to be retrofitted, re-powered or replaced over
the next 13 years to meet yearly reduction targets.

Under the annual emission reduction targets required under this
proposal, many contractors will be required to first re-power or
retrofit an engine, only to have to turn around a few years later
and replace the entire piece of equipment when the technology to
do the fob right finally hits the marketplace.

While many of California’s larger construction companies have
already begun the process of re-powering or retrofitting its fleet
in anticipation of these regulations, the smaller companies with
less than five employees, which make up more than 55 percent of
the industry, will be severely hampered by the costs of
re-powering or retrofitting equipment that, in some cases, are the
sole assets of their family-owned businesses. Additionally, many of
these companies simply do not have the resources or access to
capital to re-power or retrofit their engines and may be forced to
park the equipment, ultimately costing jobs and revenue to the
state’s economy.

We estimate the total industry-wide cost of implementing these
proposed rules to be upward of $9 billion. For my company’s fleet
alone the cost will be in excess of $500,000. Since the
construction is a low-margin business, many contractors will be
forced to reduce their fleets and in some cases go completely out
of business in order to be in compliance with these regulations.

These rules will also significantly reduce the buying power of the
historic $43 billion infrastructure bonds the people of California
approved in November. Due to the enormous expense of replacing
this equipment, in some cases more than $1 million for each
machine – we will be forced to increase the cost of construction
projects. This means fewer roads, schools, housing and levees will
be built and the pace at which these projects can be completed will
be significantly slowed. 

However, restoring just five years to the implementation timeframe
will give equipment manufacturers time to catch-up and produce
engines that will allow the industry to meet California’s
progressive air quality standards and distribute the massive
expense of purchasing new equipment out over a longer period.

We look forward to working with you, CARB, environmental
organizations, the Legislature and other stakeholders to find a
feasible solution that achieves the state’s air quality goals
while keeping California’s economy moving forward.

Sincerely,


Will Ferraro
Wysong Construction Co.