Comment Log Display

November 26, 2008
	

The Honorable Governor Arnold Schwarzeneggar
State Capitol Building
Sacramento, CA 95814

Dear Governor Schwarzeneggar:

The California Air Resources Board (CARB) is currently considering
the adoption of an on-road diesel truck and bus regulation that, if
implemented as presently drafted would have a profound, negative
impact on California’s economy.

I want to be clear:  The California Moving and Storage Association
(CMSA) and its over 550 member companies are very supportive of
reducing particulate matter (PM) and NOx emissions from diesel
engines.  There is no disagreement that we need to work
collectively to improve the state’s air quality and all of us want
to provide as healthy an environment as possible for our families,
our employees and all Californians.  However, in its current form,
the Board’s proposed regulation places a significant economic risk
on our business today, jeopardizes many of our members future
viability in the moving and storage industry, which is already
reeling from unprecedented financial turmoil.

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression.  California
truckers, particularly moving companies, are struggling to make
ends meet in the face of a massive slow down in the residential
real estate market.  The proposed legislation will require small
businesses to spend dollars that they don’t have, in a market where
there is virtually no access to capital for business, large or
small.

Companies like those represented by the CMSA are being asked to
dispose of equipment and assets before their useful life has been
completed and purchase new equipment before it would otherwise be
acquired.  A combination of this proposed rule and the state of the
economy have left the trade-in or resale value of our equipment
worth pennies on the dollar.  Many CMSA member companies and others
like us simply don’t have the resources or access to capital to
retrofit our engines.  Some of our members may be forced to sell
off our trucks at a loss or shut their companies’ doors, ultimately
costing jobs and revenue to the state’s economy.

Many of California’s trucking companies have already begun the
process of retrofitting or replacing their fleets, whether in the
normal course of their business cycle or in anticipation of these
regulations.  However, the smaller owner/operators – those with
fleets of five trucks or less – who make up more than 55 percent of
all trucks registered in the state, will be severely hampered by
the costs of retrofitting or replacing trucks that, in some cases,
are the sole assets of their family-owned businesses.

Given the multi-billion dollar cost of this regulation – and the
current volatile economic environment – I urge you to support the
alternative proposal proposed by the Driving Toward a Cleaner
California (DTCC) Coalition that would give companies the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions.

In fact, CARB’s own analysis of our DTCC alternative confirms that
the DTCC alternative proposal achieves roughly similar emissions
benefits to the proposed regulation in the long-term.

We are a small Mayflower moving agent in northern California with
9 trucks in our fleet. Based on the proposed new regulations we
would have to retrofit or replace 7 of them. This is not something
we could afford or budget for.

Sincerely,




Earl Farnsworth JR
President
Farnsworth Mayflower
Member of the California Moving and Storage Association
www.thecmsa.org