August 26, 2003

Michael J. Tollstrup

California Air Resource Board

P.O. Box 2815

Sacramento, CA 95812

Subject: Proposed changes to CARB’s Portable Equipment Registration Program (PERP)

Dear Michael J. Tollstrup,

We appreciate the opportunity to respond to the proposed changes to CARB’s PERP. We are supportive of efforts towards cleaning the air in California. Some of the concerns that our company has with regards to the proposed changes to the Portable Equipment Registration Program are as follows.

  • Notifications – As the current regulation stands there is an existing notification process that allows the local air districts to know where portable equipment is located. Any additional requirements to this notification process would hinder the flexibility of our contractors to move their equipment and perform required work in a timely, cost-effective and efficient manner. Furthermore, increasing administrative costs to these contractors’ companies might increase our costs and eliminate work done in California.
  • Record Keeping – Adding increased recordkeeping to the PERP, would require additional resources for both CARB and our contractors. These resources all come at a very high cost, creating little or no value and would actually take money away from our contractors that could be applied towards cleaner engine technology.
  • Project – Any change of the term “Project” is very concerning and would leave a lot to be interpreted by the local air districts. The proposed application of the term “Project” could prevent many activities required in the oil and gas production processes from taking place. Thus crippling the production of oil and gas resources in California. We would like to recommend that the current application of the term “Project” remain as intended by the original PERP regulations.
  • Fleet Average – The proposed fleet average rule with only two horsepower categories is very limiting and not realistic when we consider the availability of Tier III & IV engines with horsepower greater than 750 HP. We recommend an expanded approach to the fleet average that takes into consideration the availability of Tier III & IV engines in the larger horsepower ranges. Also, CARB should take in account that retrofit devices have not been proven to work in all portable equipment applications.

From our review of the proposed changes to the PERP, it is apparent that the some of the proposed changes have similarities to stationary equipment programs. The nature of portable equipment is its flexibility to be mobilized and operated under wide variety of activities and locations. The PERP must continue to recognize the mobile nature and flexibility of this equipment. Applying stationary strategies and thinking to the PERP would limit equipment flexibility and prevents growth within our industry. Your consideration to our concerns is greatly appreciated.

Sincerely,

Rock Zierman