I respectfully submit the following comment for your consideration.
I feel that given the voluntary nature of the proposed survey, the sample pool
and the resulting measurement of emissions may be skewed. Generally,
respondents who possess resources to participate in a survey of this nature, and
furthermore, is willing to have their equipment emissions measured on site, tend
to be larger, established businesses, who operate fleets powered by newer,
cleaner running diesel engines. In the construction industry, it is often the
smaller operators, several tiers down in the contractor hierarchy, who, due to
the marginal profitability of their enterprise, retain and operate older or
grossly polluting equipment out of economic necessity.
In order for the proposed ?real-world? emission test to be representative of the
actual operating fleet, I strongly feel that an effort needs to be made to
capture these smaller entitles in the your sampling, either through carefully
weighing the size of the operators in your response pool, or through some other
remedial measures that will account for these smaller, often higher polluting
operators, who in the aggregate, may be responsible for a significant portion of
pollutants from non-road diesel equipments.
Anonymous public comment
This is comment on Notice
Agency Information Collection Activities; Proposed Collection; Comment Request; Populations, Usage and Emissions of Nonroad Diesel Equipment in EPA Region 7; EPA ICR No. 2156.01, OMB Control No. 2060- 0553
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Public Submission Posted: 09/28/2007 ID: EPA-HQ-OAR-2003-0225-0006
Oct 09,2007 11:59 PM ET