Comment Log Display

This year MCM Construction is seeing a reduction in hours of
operation for our off road fleet of 25% compared to last year. In
addition we are expecting 4 of our 11 projects to be finished this
December. 

75% of our fleet contains tier 0 and tier 1 engines. This means
that our only way to comply is through the BACT part of the rule.
Foreseeing this rule, we got a head start and spent 1.5 million
dollars repowering our large track cranes and loaders. With this
early repower credit we are compliant with the Nox side of the rule
for a couple years. However, with the recent requirements from
CALOSHA requiring that installation of retrofits not inhibit
operator visibility, we’ve decided, until CALOSHA comes up with a
system for measuring what is an acceptable retrofit installation
that doesn’t block visibility, to retrofit our track cranes.
Currently there are only two retrofit technologies that are
verified for use with our tracked cranes that we can meet the
required retrofit operating temperatures for. One of those systems
requires an electrical plug in to regenerate for 8 hours and the
other is on a 6 week back order. We are required to Data log the
temperature readings for any engine that we are going to install
these retrofit devices on. Since its winter and we’re running out
of work for our cranes to do we are having trouble getting all the
temperature readings we need. 

	Our cost to comply with the PM portion of BACT this year is 300
thousand dollars. With the first compliance date of the On-Road
Diesel Regulation next year we expect to spend 600 thousand on
retrofits for the off road rule and another 500 thousand on
retrofits for the on-road rule. This is money we’re spending on
devices that neither increases the life nor the productivity of our
equipment. There is neither the money nor the technology to make
these regulations work. With the reductions in work from the
recession, CARB should be getting its emission reductions just from
the fact that equipment isn’t operating. I suggest that we give the
economy time to recover before putting even more of a monetary
strain on an already suffering construction industry.