Comment Log Display

Due to current extrememy difficult economic conditions,  I strongly
urge approval of ARB Staff recommendation to extend replacement
deadline for currently registered non-certified diesel engines
until December 31, 2010. 

In addition to this extension, I want to suggest a minor change to
regulations which will have negligible impact on the environment
while helping many small businesses and individuals in the Film
Industry. This change would simply allow an existing compliance
deadline for one category to also apply to a similar category of
equipment used in the motion picture industry which utilizes the
IDENTICAL off-road diesel engines. In the category identified as
"OFF-HIGHWAY VEHICLES" non-certified diesel engines operated as
part of small or medium size fleets are allowed more lenient
compliance deadlines of 2015 for small fleets and 2013 for medium
fleets.  The category of equipment identified as "PORTABLE
GENERATORS", which is so prevalent in the film industry, use the
same off-road engines as are used in "OFF-HIGHWAY VEHICLES",
however are not allowed the same, more lenient deadlines for small
or medium size fleets. Considering that the identical engines are
used in both categories and utilization hours as rental equipment
should be very similar, I believe compliance deadlines  should be
the same for "PORTABLE GENERATORS" and "OFF-HIGHWAY VEHICLES" based
on fleet size. This minor change would greatly assist small
businesses such as mine in the current bad economy and would
correct an apparent inequity in CARB regulations.