Comment Log Display

Manson Construction is the largest dredging contractor on the West
Coast. Our industry plays a vital role in maintaining shipping
lanes, providing coastal protection and restoring coastal habitat
up and down the state of California. We also employ many
californians with high paying, union craft jobs. Manson has a long
history of complying with local district as well as statewide air
regulation. We have invested in SCR systems and repowered very
large specialized marine equipment with costs in the millions of
dollars. 

The current changes to the PERP regulation are another example of
a patchwork approach to regulation impacting our industry that has
had significant detrimental effect on our business and competitive
postion relative to less informed contractors from out of state.
While we don't necessaryily disagree with the inclusion of marine
engines in the PERP, we wish to point out to the board that there
is a significant industry out here employing people and in some
cases working hard to comply that finds itself in the very
difficult position of having the very same engines included in no
less than three regulatory regimes. All of our dredge engines are
registered under the PERP, but because we work in state territorial
waters, we also are forced into local district permits and often
district offsets. In addtion, the ARB has proposed to extend the
harbor craft rule to dredges. The ATCM applies to use (and we are
repowering a 10,000hp vessel at the moment to comply), yet with
this change, we should have installed higher emitting marine
engines and would have been exempt from the ATCM. We implore the
board to direct staff to recognize the overlaps and work with
industry to come up with one regulatory regime for dredges. We
would be happy to comply and stop wasting money that is ultimately
our clients (the taxpayers).

Thank You.


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