Comment Log Display

My first comment is the second amendments to the original proposed
regulation are unwieldy.  There is not a practical way for the
public to completely understand it.  I am not sure that the authors
have a good idea of what they have written or the would have
written it in an understandable way.

The conditions that led to the December 2010 amendments are still
relevant.  Therefore the proposal should be postphoned.

1.  Diesel is still expensive which means: a. Better fuel
management is in place. b. Freight is increasing therefore there
will be less shipping. c. Inefficient engines will be used less.  


2.  There is unlikely to be 2007 level construction in the near
future because: a. the housing inventory is well over market.  b.
The foreclosures will continue for another 1 - 2 years.

3.  The phase in period does not accommodate the ability of
trucking rates to pay for the increased expense.  The exemptions of
the pre 1996 motors are arbitrary and do not apply to all affected
fleets evenly.

4.  The lack of interest in the early retrofit credits can now be
documented and indicates:
a. Lack of faith in the government's will to follow through on the
enforcement of this law.  b. The unwillingness for the industry to
spend $18,000 to keep using a $10,000 truck.