Comment Log Display

As a responsible business, our organization is very supportive of
reducing particule matter (PM) and NOx emissions from diesel
engines.  We definitely need to work toward a solution that is
economically viable for companies of all sizes without placing
these companies at economic risk.  The proposed regulation does not
accomplish this and in fact puts a majority of companies in a
situation that jeopardizes our very existence.

CARB is proposing this multi-billion dollar regulation during the
worst econoomic crisis since the Great Depression.  California
truckers, construction companies, service businesses like mine and
bus operators are struggling to make ends meet in the face of a
massive slow down in the entire economy.  Added to this delimna is
the fact that credit is virtually non-existent.

Companies like mine are being asked to dispose of equipment and
assets before their useful likfe has been completed and purchase
neew equipment before it would otherwise be acquired.  A
combination of this proposed rule and the state of the economy have
left the trade-in or resale value of our equipment worth pennies on
the dollar.  My company and others like ours simply don't have the
resouces to retrofit our engines.  In my case this could result in
closing the doors and the loss of 15-20 addition jobs.

Given the multi-billion dollar cost of this regulation - and the
current volatile economic envirnoment - I urge you to support the
alternate proposal proposed by the Driving Toward a Cleaner
California Coalition that would give companies like mine the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions.

In fact, CARB's own analysis of our DTCC alternative confirms that
the DTCC alternative proposal achieves roughly similar emissions
benefits to the proposed regulations in the long-term.

We must be careful not to forfeit California economy and ability
to move goods across the state, build construction projects and bus
our children to and from school for the sake of protecting our
environment.  I look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.

Sincerely yours,

Bruce W. Adams
Geo Sales Manager
Reed & Graham, Inc.