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Comment 12 for In-Use Off-Road Diesel-Fueled Fleets and Off-Road Large Spark Ignition Engine Fleet Requirements (on-offroad10) - 45 Day.

First NameChris
Last NameTorres
Email Addresschristorres@fandltrucking.com
Affiliationmember, CDTOA, CTA
SubjectON road rule modifications
Comment
To the Board,

     The proposed amendments are a valiant attempt to fix this
broken rule.  My company, as with many others, spent a great deal
of capitol to upgrade our equipment knowing that the rule was
coming into play.  We would have continued to operate our older
equipment if we knew that there would be more time to comply. Now
we are being penalized for our early action. We will now have to
add filters to our equipment that should be payed  off and
realizing some additional capitol recovery. 

     By giving the older equipment a longer period to comply CARB
will be giving a competitive advantage to those people who did not
do anything and continue to emit higher emissions. Where as the
people ( me, us) who have taken early action, reduced emissions
with cleaner equipment, have to suffer with lower rates that the
non-compliant operators can survive on. These people have not spent
any capitol, while the CARB makes their mind up on the rule.

     I like many others did and are doing our part to clean the
air. We would not have purchased equipment as the normal course of
business. Especially now,then, in this horrible economic
environment. We have struggled to make our payments, pay our
payroll etc. We are the group who needs to be helped. We are the
ones who risked our capitol/lively hood to bring cleaner air to the
state.

     I would like to see the rule stay the same as originally
pasted by the board in 2009. This would keep the economics even for
all involved. 

Chris Torres
F & L Farms Trucking Inc.


Attachment
Original File Name
Date and Time Comment Was Submitted 2010-11-16 16:06:53

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