Comment Log Display

ATTN:   Clerk of the Board
               California Air Resources Board
               1001 I Street
               Sacramento, CA 95814

RE:  Proposed Amendments to the Small Off-Road Engine Regulations:
Transition to Zero Emissions

To the California Air Resources Board:

Associated California Loggers is the trade association representing
logging companies, log trucking companies, and log road building
companies in California.  Our members are at the forefront of fuels
reduction, thinning, and biomass collection at a time when
California has faced its two worst wildfire seasons in history.

This particular period of crisis in California history - with its
terrible mix of loss of human life, wildfire carbon emissions, loss
of animal life and species habitat, and the destruction of hundreds
of homes and millions of acres of timberland - strikes as exactly
the wrong time to be targeting chainsaws, water pumps and other
"tools of the trade of wildfire prevention and suppression."   
Against the emissions produced by wildfire, the emissions
reductions contemplated here strike as a comparatively small.

Moreover, we believe that the rule as proposed simply isn't
workable, and that exemptions for specific pieces of equipment must
be exempted from the Proposed Rule.
Those specific pieces of equipment include large chainsaws, water
pumps required during the conduct of forest management activities
for the purpose of wildfire preparedness, portable pumps relied
upon for drafting water to fill water trucks, off-road forestry
equipment with water tank and pump for wildfire preparedness, and
portable air compressors to service forestry equipment.

Associated California Loggers believes that our comments should be
considered with an eye towards worker safety and wildfire
preparedness.   We have been working with the Governor's office on
"workforce development" of a young and diverse workforce and we
believe that it would be counterproductive for this important work
to be rendered impossible to perform due to unrealistic "electric"
engine requirements for wildfire work in the woods.

Thank you,

Eric Carleson
Executive Director
Associated California Loggers