Comment Log Display

As the Road Commissioner for Modoc County, a large but sparsely
populated county with many miles of rural road to maintain, I have
many serious concerns about the implementation of the Advanced
Clean Fleets Regulations. A few of the most obvious include:
1. Performance: During summer projects and winter snow removal, we
have nearly every piece of heavy equipment we own on the job. Often
there is a short rest period before the equipment is needed again
and sometimes we work split shifts so equipment must be refueled
and continue rolling in order to ensure public safety. The
technology must accommodate this need before we can successfully
convert our fleet.
2. Maintenance & Repair: We have a small staff so we must be able
to perform a variety of different responsibilities. Our small
mechanic crew currently works on a large variety of vehicles and
equipment and their time is consistently booked solid with our
maintenance and repair needs. This fleet conversion will require
extensive training and create reduced productivity rates, likely
creating the need for us to hire additional staff. We will also
need to invest in new diagnostic equipment and most likely need to
outsource repairs to distant specialists that will likely be
overwhelmed with this rapid and widespread implementation.
3. Budget: In addition to the increased costs implied above, we
don't have the budget to purchase replacement vehicles within this
timeframe. We have many vehicles that are decades old but are still
nowhere near being scheduled for replacement. We maintain and
operate our equipment with care because we know it will need to
last a long time. An accelerated replacement plan will
significantly decrease our ability to properly maintain our
roadway, which is the primary reason for our existence.
Thank you for reconsidering the proposed implementation plan.