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One More Try…
November 19, 2008

If you own off-road diesel construction equipment in California you have one more shot at slowing down passage of the California Air Resources Board’s (CARB) unreasonably strict and expensive regulations.

 

If you value your construction business, please take the time to read the following information about what you can do at this moment, as sent out today by AGC of America, AGC of California, and the San Diego Chapter of AGC (collectively “AGC”).

 

This may literally mean whether you will be able to stay in business. That is how important it is that you take action on this:

 

Request for Information Relating To California’s New Rule on Off-Road Diesel Emissions

 

November 19, 2008

The construction industry needs your help! Without the benefit of your personal experience with either the recent downturn in construction or directly with California’s new rule on off-road diesel emissions, the California Air Resources Board (CARB) will proceed with its plans to add billions of dollars to the cost of construction throughout the state of California! For only a few minutes of your time, you can get directly involved in the effort to bring reason to the debate over these plans.

 

Background AGC of America, AGC of California, and the San Diego Chapter of AGC (collectively “AGC”) are preparing to petition CARB to reopen its rulemaking on emissions of nitrogen oxides (NOx) and particulate matter (PM) from existing fleets of off-road diesel equipment. CARB finalized that rule on April 4, 2008, and the rule took effect on June 15, 2008, subject to federal approval of CARB’s request for a so-called “waiver of federal preemption.”

 

AGC believes that CARB should reopen the rulemaking because economic and other circumstances have dramatically changed since CARB finalized its rule. The economic costs and environmental benefits of the rule are turning out to be very different from anything that CARB could have anticipated at the time it made its final decisions. AGC is much more likely to succeed if it can provide CARB with real life examples of the downturn in construction and how the agency’s new rule is actually playing out. AGC is therefore asking its members and other interested parties to share their personal experiences with any of the issues listed in this document. With the permission of those involved, and only after they have had an opportunity to review anything that AGC would attribute to them, the association hopes to attach written summaries of such experiences to the petition that it files with CARB.

 

Who to Contact

If you have any information on any of the following issues, please send an email summarizing that information to AGC’s Senior Environmental Advisor, Leah Pilconis (pilconisl@agc.org), or to the association’s General Counsel, Mike Kennedy (kennedym@agc.org). Or, if you prefer, feel free to call either Ms. Pilconis (703-837-5332) or Mr. Kennedy (703-837-5335). AGC would like to complete its work within the next two weeks. If you think you can help, please either send an email or make a call as soon as possible! Information that the Construction Industry Needs to Share with CARB

 

1. Experience with the Downturn in Construction

 

Can you provide any data on the recent downturn in construction, or relate any personal experiences with it?

 

 

Are you aware of any published data on the number of construction contractors bidding for (or otherwise pursuing) the projects that are still moving forward?

 

If you are a construction contractor, have you personally seen any changes in the number of other construction contractors bidding for (or otherwise pursuing) the projects in which you have an interest?

 

If you are a construction contractor, have changes in the competition for available work had any effect on your power to pass higher costs along to project owners?

 

 

2. Experience with the Recent Decline in the Consumption of Diesel Fuel

 

Are you aware of any published data on the recent decline in the consumption of diesel fuel?

 

If you are a construction contractor (or you lease off-road diesel equipment to construction contractors), has your own consumption of diesel fuel declined – and if so, by how much?

 

 

3. Experience with the Number and Variety of Verified Diesel Emission Control Systems (VEDCS) Available to Construction Contractors

 

If you are a construction contractor (or you lease off-road diesel equipment to construction contractors), how many equipment dealers in your area sell and/or install VDECS suitable for your type of equipment?

 

If you have asked an equipment dealer to tell you how much of your equipment the dealer could retrofit:

 

How long did it take the dealer to assess your fleet?

 

What did the dealer tell you?

 

4. Experience with the Actual Installation of VDECS

 

If you are a construction contractor (or you lease off-road diesel equipment to construction contractors) and you have talked to a dealer about retrofitting your equipment, how long were you told it would take for the dealer to perform the work?

 

If you actually engaged a dealer to retrofit all or a portion of your fleet, how long did it take the dealer to complete the task?

 

If you are an equipment dealer, how many mechanics and other skilled workers do you have available to retrofit existing fleets of off-road diesel equipment?

 

 

5. Experience with the Cost of Maintaining VDECS

 

Do you have any data or other information on the cost of maintaining VDECS?

 

 

6. Experience with Any of the Ways in Which VDECS May Affect Performance

 

If you have installed VDECS on some or all of your equipment, do you have any data or other information on how these devices have affected the performance of your equipment?

 

7. Experience with the Resale Value of Equipment in an Existing Fleet

 

Are you aware of any published data on recent changes in the prices being paid for older pieces of equipment (that tend to have higher emissions)?

 

Have you personally witnessed any changes in the prices being paid for such equipment?

 

8. Experience with the Credit Being Extended to Construction Contractors

 

Have you personally seen any changes in the amount of credit that banks or others are willing to extend to construction contractors – either to purchase and install VDECS or to purchase new equipment?

 

Have you personally seen any significant changes in the terms and conditions on which banks or others are willing to extend such credit?

 

Posted by Loren Faulkner on November 19, 2008 | Comments (0)