Comment Log Display

March 20, 2007

California Air Resources Board
Dr. Robert Sawyer, Chairman
1001 I Street
Sacramento, CA  95812


Dear Members of the ARB,

The emergency amendment last December to re-open the Portable
Registration Program was only the first step towards rectifying a
gross injustice to the owners of portable engine equipment owners
and to the residents of the state of California. This program
still has many problems that need to be resolved before a
permanent decision on the temporary changes becomes final. 

1) Tier 0 engines need to be allowed into the statewide program.
Just because you don’t want Tier 0 engines into the program,
doesn’t mean they don’t exist. They still continue to operate in
this state every day. Allow the statewide registration program to
fulfill its intended function and identify where these types of
equipment are located.  The statewide registration program should
be an all inclusive program and not divided up amongst individual
air districts – which may or may not even allow the engines into
their program.

2) The “resident engine” policy will have costly and long term
effects to the California used construction equipment market.
Unless an equipment’s engine was previously operated in
California, a brand new piece of equipment containing a Tier 3
engine must be purchased. Upgrading to new equipment is very
costly to the small business owner and in fact, only just now
becoming available. The first Tier 3 engine in the portable
concrete pumping industry was just sold this past January. These
engines are NOT readily available and will not be until much
later. By matter of record, we also know that not very many, if
hardly any at all, portable Tier 1 and Tier 2 engines were
registered up until December, 2006 in the statewide program. This
leaves a very limited quantity of used equipment available. What
do you do if you can’t buy used equipment? I would hate to think
that as a consumer, I had to buy a brand new car every time a
cleaner model engine was produced. It is simply impractical.

3) The revised fee schedule is unjust. In fairness to those who
actually registered their equipment in earlier years, we supported
a late penalty for registration fees. However, charging for
inspection fees when the inspections were not administered seems
punitive. I would urge you to reconsider the fee schedule and
reduce the fees by the yearly inspection fee. 
 
My comments only reiterate what you have heard before. You’ve
heard from many associations, organizations, and individuals who
have all given you the same message in various ways. Your work is
not done. Let’s take a practical approach and create a model
program that can be viewed by other states as one that creates a
cleaner environment and in doing so doesn’t break the backs of the
small business owner.  To leave the program “as is” without taking
into consideration the suggestions you will hear on Thursday is
simply wrong. 


Sincerely,





Christi Collins
Executive Director, ACPA