My name is Brent Garcia and I'm the owner and CEO of Brewer
Crane & Rigging - a crane company based in San Diego. As
a small company we have already struggled keeping up with some of
the requirements of prior diesel emissions regulations. I
offer the following comments on your newest proposed amendments to
help ensure the regulations are practial, reasonable, and don't put
more small businesses out of business.
1. Phase out of Tier 3 should be extended to 1/1/2026 at
minimum for fleets. Tier 3 still represents the majority of the
available equipment repower options.
2. Tier 4 Interim should not be banned from purchase at all. The
current NOx fleet average is based upon fleets meeting a final
fleet average equivalent to Tier 4 Interim, so this should not be
eliminated as a purchase option at all. If a phase out of purchased
equipment is to be used for equipment certified to this level, it
must be no earlier than 2030. The ban on this equipment in 2024
will bring havoc to the ability for the owners of this equipment to
sell their Tier 4 Interim, excepting out of state at a much reduced
asset value. This again creates issues with bonding and financial
stability for fleets to purchase Tier 4 Final equipment.
4. A mandate to use renewable R99 or R100 diesel by the
end of next year is infeasible. Not only will this drive up the
cost of the fuel when everybody with off-road equipment will be
seeking to purchase this fuel, but many of our clients are in
contracts that last more than a year making such a change costly,
if not infeasible. Further, we cannot agree with the rosy picture
staff states on the availability of this fuel for all, including
that which is already mandated for marine in the Harbor Craft
regulation. Many of our clients have multiple sites across the
state that will need time for the adjustment. We believe CARB
should instead be offering some sort of incentive for early use of
this fuel, and then set the deadline for 1/1/2028.
Thank you for your consideration.