First Name | James |
---|---|
Last Name | Bury |
Email Address | buryj@putzam.com |
Affiliation | Putzmeister America |
Subject | comments on "Draft Concepts" |
Comment | Dear Dr. Sawyer and ARB Board, Thank you for your recent efforts and considerations in the emergency measures being taken in the PERP program. In conjunction with the Staff, your openness to cooperation with those who wish to comply but missed the call to register is welcomed and applauded by Putzmeister and its customers. Unfortunately, I do not feel the spirit and intent of your directive has been completely embraced by the proposal that the Staff has presented for your consideration on December 7th. I am unable to attend the ARB meeting due to a previously-scheduled Canadian government regulatory meeting, so I am writing to you today as a communication of where we feel the proposal continues to fall short of what is needed. 1) In the first point of the new “Draft Concepts”, there continues to be no provision for the sale and registration of any new Tier II equipment into California between October 1, 2006 and the time that these proposals are approved and become effective. This equipment is considered appropriate from an emissions standpoint, so why would it not be permitted from a registration standpoint? I understand the Staff’s intent of limiting the registration to “resident” machines to stop a flood of non-CA equipment, but this totally cuts off new equipment simply because it does not have a California history. This was brought up at the November 20th meeting, but apparently was not considered important or was ignored. 2) In the fees schedule, it is still unclear where the Staff is getting their numbers from. Unless I am mistaken, up until relatively recent times, the registration was $30 and the inspections were $75. Even if Staff believes the registrants should pay for an inspection that never occurred, I do not see how they are justifying a increase from year-over-year as proposed. In the meeting, can we please get this breakdown from Staff so we can finally understand the rational? The fees continue to seem outrageously high. 3) We do not understand why the fifth point exists. Why does Staff not allow Tier 1 engine owners show proof of purchase date? By separating Tier 1 and Tier 2 (point #6), you set up a situation like the following: resident buys a 1998 Tier 1 unit second hand in 2005. By Staff’s proposal, they do not pay fees for 2005 but must go al the way back to 1998. It is recommended that point 5 be eliminated and point 6 includes both Tier 1 and Tier 2. 4) In point #7, Staff is phasing out all Tier 1 and Tier 2 engines from PERP. Why? They are still usable machines and the owner should still be able to use them in their fleet averaging. By emission regulation, only non-tiered machines (Tier 0) are mandated to be eliminated for emission reasons by the EPA. Even those who have faithfully registered their Tier 1 engines over the last 8 -10 years should disagree with this change. The simple solution to this would be to remove the word “current” from the Staff’s proposal. 5) We continue to feel the exclusion of the non-tiered machines into PERP is a mistake and seems to be considered a non-negotiable absolute by Staff. They continue to believe that these machines should be forced to register with every district that they operate in. This is obviously not in-line with the original intent of creating a statewide program to simplify registrations and assumes that the districts will allow a Tier 0 into their program. This is a very sizable population of machines that Staff is forcing into California oblivion three years before the US EPA mandates their extinction. Putzmeister does not see how this latest proposal by Staff, though well-intentioned as it may be, resolves the issues discussed in the November 20th meeting and actually adds in a couple of additional controversial issues. We do not intend to further delay the opening up of the registration program to those who sincerely want to join, but it would be very helpful if these issues were corrected and integrated as requested by the large number of attendees on November 20th. Please consider looking into this at the December 7th meeting. Sincerely James Bury Engineering Manager Putzmeister America |
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Date and Time Comment Was Submitted | 2006-12-06 13:05:26 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.