Comment Log Display

Dear CARB Board and CEO:

For a number of years I lived near the Port of Long Beach so that
I am particularly sensitive to the "Ports Issue", including
drayage.  I strongly concur with the Communities for Clean Ports
position cited below.

PROGRAM SHORTCOMINGS
Overall, this is a decent "floor", but the rule is inadequate for
areas with severe and growing air pollution problems -- like the
South Coast Basin or the San Joaquin Valley. The CARB port trucks
rule will not result in getting the cleanest commericially
available trucks on our roads given their standards and timeline,
which again include meeting EPA 2007 standards only and placing
heavy emphasis on retrofitting old trucks. Instead, the goal of
the program should be ensuring that the cleanest available trucks
and technologies replace dirty diesel trucks, as soon as possible.
Here are some additional recommendations to improve it:

Close the 2004-2006 Loophole: CARB should require all trucks to
meet 2007 standards by 2013;

Make sure all major Inland and Central Valley rail yards are
included; 
Enforcement & Accountability: Clean up the regulation's language
to ensure adequate enforcement of the port truck rule; 
Funding: Currently, the Air Resources Board does not include any
funding sources. It will rely on other sources that are as yet
undetermined.
This may prove to be a major stumbling block given the cost of
retrofitting a truck, or purchasing a new, cleaner truck.

Timeline: The CARB rule would not be enforced until the end of
2009 -- 2 years from now.

Thank you for your consideration.

Robert D. Wheeler, Ph.D.
29071 Calle del Buho
Murrieta, CA
92563-5661