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Hello, my name is Steve Sloat. I am in the warehousing business and
am currently serving as the Vice President of the Pacific Coast
Coffee Association. As a California resident, I am among those
that are justifiably concerned about our air quality. While I
stand behind the intent of your proposed regulation, I can not
support the means to that end. The economic impact of such a
regulation would be devastating, forcing hundreds, if not
thousands of owner operators out of business. The great majority
of trucks currently picking up containers at California ports
could not afford the modifications (or the cost of newer
equipment)necessary to operate under these requirements.
Eventually, the only trucking companies able to operate under
these restrictions would be either large, well funded operations,
or (more likely)port owned transportation services. I am certain
that your study found that the greatest cause of excessive
emissions, is idling trucks waiting in line to receive service at
under staffed and over crowded terminals at the ports. If the port
authorities were truly concerned about this problem, they would
urge the steamship companies to help alleviate this situation by
adding more personnel, and most importantly opening night gates
for peak periods. The increased and effective use of night gates
would help to solve this problem in two ways. First, by
alleviating long lines and wait times, excessive idling would be
curtailed. Secondly, with more truckers making use of night gates,
nearby surface streets and freeways would see less congestion in
the form of stop and go traffic that greatly increases harmful
emissions.  Thank You,   Steven J. Sloat  PCCA