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Dear Board Members,
I am an employee of Pavement Recycling Systems, Inc., a 100%
employee owned specialty contractor with 160 owner / employees in
the asphalt construction industry. As owners, each of us is working
hard to keep the company from losing money and preserving the
company's value during these tough economic times. We have a fleet
of approximatley 120 trucks which will be affected under the
proposed ON Road Regulation as written, 80 of which are semi
tractors. Our average annual mileage on each semi is only 15,000
miles, which along with our stringent maintenance program, allows
us to keep our trucks for 20 years before replacing it, with half
of it's usefull life still avaiable and in good shape. This new
regulation would cost us an additional $1MM per year due to a
mandated accellerated rollover schedule, for trucks which are well
underutilized, but not enough to qualify for low use as currently
written. One Million dollars per year on top of the One Half
Million dollars it is costing our employee / share holders in
accelerated repowers, replacements and retrofits to comply with the
Off Road measure.
I respectfully ask you to consider the following before allowing
this measure to go forward:
1. Reconsider implementing a compliance schedule which considers
mileage and utilization and not just age. As written, we will be
required to repower or replace some vehicals with only 25% of their
useful life used.
2. Consider the impacts to the Employee Owners of California
impacted by these regulations.
3. When implemented, work with the companies striving to comply.
These regulations are tough to completely understand and comply
with. As the Off Road regulation is written, it penalizes those
with a history of compliance with tougher penalties on violations
than those who have clearly ignored the regulation. We ask you
strictly enforce these rules and take strong action against those
taking the chance they wont get caught - like out of state
contractors risking non-compliance and counting the penalties being
geared more toward assistance with compliance than penalties for
ignoring the regulation. Companies showing honest efforts to comply
should not be penalized. 
4 Recommend to Cal-Trans they specify compliance to this
regulation be enforced by the project inspectors on their projects,
minimizing non compliance from out of state contractors.
5. Grant in state corporations a 5% advantage at bid time for all
state sponsored projects. This will not cost the state but will
help level the playing field for the California Companies. The cost
to comply with all regulatory programs is higher in California than
neighboring states and this 5% consideration will help keep work,
profits, employement and taxes in California.

Thanks you for you consideration. 

Steve Concannon
Pavement Recycling Systems, Inc.