Comment Log Display

SUBJECT:	Request for Extension
		April, 2009 EVR Deadline

Dear Ms. Nichols,

This letter is written to request your assistance in extending the
EVR compliance deadline of April, 2009. The current deadline does
not allow ample time to go through the permitting process,
purchase the necessary materials and equipment, and hire
contractors to complete the work. 

We currently operate thirteen locations in Southern California,
one of which has the Healy EVR system with ISD. This system is
both expensive and has numerous operational problems creating high
maintenance costs.
By extending the EVR compliance deadline, CARB will allow
owner/operators the needed flexibility to comply with mandates in
an orderly, cost-effective manner. Extending the deadline to four
years from certification would allow the best, most cost effective
systems to be identified, and would give sufficient time for
permitting, training and installation. In the meantime, the
balance systems we operate are tested and certified annually to
insure that they continue to perform the vapor recovery task for
which they were designed.

We ask that CARB take action as soon as possible to avoid the
logistical nightmare that is sure to occur if the deadline is not
extended. Thank you.



Sincerely, 



Bill Vance
Vice President