Comment Log Display

The PERP program is both confusing and cumbersome.  I have tried to
register 4 pieces of equipment with the ARB,and after using and
following the online instructions, all four applications were
returned with multiple additional requests for information.  Those
who are employed full time by the ARB may know and understand the
confusing acronyms and rules, but those of us that are affected by
them rarely have a lot of available time that it takes to read and
hopefully understand them.

I suggest that a much simpler approach be implemented; that all
machines have a phase out from the date of manufacture.  In our
company, much of our equipment is depreciated over a period of 15
years. I would suggest that equipment be allowed use for 15 years
or 7,500 hours (which ever occurs first), after which it must
either be re-powered with a compliant power source or scrapped.  

I would also suggest that any rule be implemented state wide,
avoiding special rules from the 35 air districts.  Having
individual Air Districts and thier rules only adds to the chaotic
state we must operate in.

We all want clean air and a healthy environment, but we also  need
to have a healthy economic state.  We must work towards crafting
rules that encourage willing participation and the success of our
businesses that drive our State's economy.

After submitting message (Comment 12) minutes ago, I realized that
I should have shared some data with you.

Our company has 51 air compressors in our fleet, powered by diesel
engines of up to 80 hp.  Of these compressors, 23 are powered by
Tier 0 engines that can not be registered (6 have 51 hp engines,
the rest have 80 hp).

These compressors have 500 to 3,000 hours of use recorded on their
hour meters, with many years of usefull life remaining.

Since we can no longer lawfully use these compressors in this
state, the cost of replacement will be $11,811 each, for a total
of $271,657.00.

Obviously, this is a significant financial burden placed on our
company.