Comment Log Display

Attention:  Clerk of the Board, California Air Resources Board

Dear Ms. Blakeslee:

The Metropolitan Water District of Southern California
(Metropolitan) appreciates the opportunity to provide comments in
response to the California Air Resources Board (ARB) 15-day
proposed modifications for the Statewide Portable Equipment
Registration Program (PERP). Metropolitan supports several of the
changes that the California Air Resources Board (CARB) is proposing
to make to the PERP to help provide regulatory relief to portable
equipment owners, especially in light of the economic situation in
California.  To facilitate this goal, Metropolitan is providing the
following comments. 

Recordkeeping and Reporting

Under the current regulation, a Provider of Essential Public
Service (PEPS) is required to submit for both certified and
non-certified engines, an annual report containing among other
information, the estimated time spent in the three counties where
the engine operated most frequently.  However, the proposed
amendments would expand the information required to be kept for
both non-certified engines and equipment to include the street
address, the city, county and UTM coordinates, or other location
indicator, each time the engine or equipment unit is brought to a
new location.  Requiring this information is contrary to the
efforts to streamline the regulations and decrease the regulatory
burden on portable equipment owners, and does not appear to provide
any commensurate benefit to the purpose of the regulation.
Therefore, Metropolitan recommends that the recordkeeping and
reporting requirements for PEPS remain unchanged. 

Application Process - Electronic Notification of Registration

Metropolitan appreciates the proposed provision for adding the
option for electronic notification to the applicant when an engine
or equipment unit has been registered in Section 2453 Application
Process. However, there may be a lag time from the time of
electronic notification to an applicant’s receipt in the mail of
the registration identification device that is affixed on each
engine or piece of equipment. To address this timing issue, we
recommend that language be included in the regulation to allow the
equipment to be operated once the electronic notification is
received, as long as the registration is maintained with the
equipment, and the operating and recordkeeping conditions are
implemented. 

If you have any questions, please contact Janet Bell at (213)
217-5516 (jbell@mwdh2o.com). 

Sincerely, 

Janet Bell
EHS Program Manager
Metropolitan Water District of Southern California
700 North Alameda Street
Los Angeles, California 90012
(213) 217-5516