Comment Log Display

I respectfully oppose the elimination of the delay of the 2007
standards for the drayage truck rule.
There was consideration of delaying that requirement until 1/1/17
but instead it has been decided to require that drayage trucks can
only access ports and rail yards with 2007 emissions compliant
engines starting on 1/1/14. 
Per a study of emissions at the Port of Oakland conducted by Prof.
Robt Harley, UC Berkeley, during 11/2009 through 6/2010, it was
learned that the PM emmissions had been reduced by 50%. Also, the
NOx was reduced by 40%. This study was presented to CARB in Dec
2010 at the Mobile Source Emissions Workshop in Sacramento.
I believe this was attributed to the replacement of older
1980-1990's vintage trucks with 2004-2006 truck engines. Also, the
retrofitting of late model 1990's engines with DPF has had a
positive affect on reducing PM emmissions. 
Many small trucking companies and owner operators invested in
2004-2006 technology in 2008 & 2009 in order to be compliant and to
ensure that they would be able to continue to service the Port of
Oakland for years to come. Many did this at a tremendous financial
burden. They have the option of retrofitting those trucks but it
only gets them until 1/1/14. With the burden of a truck payment and
a DPF install, it would have a devistating financial consequence
for them. In our fleet, we installed 23 DPF's on trucks 1996 to
2001. We feel that these trucks are much cleaner than before and
have helped to achieve a huge reduction in PM and NOx, as stated
above. 
In conclusion, I request that CARB reconsider its cancelation of
the 1/1/17 compliance date for 2007 compliant engines.  I know that
some fleets were able to upgrade to 2007 & 2010 standard engines,
and I know it was a financial burden to them. Perhaps offering an
attractive credits package to them would help offset the
anticipated competitive edge they feel older trucks would pose to
them.
Thank you for your consideration
Alan Osofsky