Comment Log Display

Dear Sir/Madam,

We appreciate this opportnity to comment on the modifications to
the Truck and Bus Rule.  While we do support many of the changes,
we beleive that some of the modifications need to be changed or
clarifying language inserted.  

Our primary concern is the exemption of drayage trucks from this
rule.  Our comapny will spend a signicant amount of money to
upgrade trucks under the drayage truck rule, yet we will get no
credit under the truck and bus rule.  In fact, if we have to take
the drayage trucks out of the fleet averaging or other BACT
complaice methods, we will actually be penalized under the truck
and bus rule.  This is especially troublesome considering the very
small amount of time our trucks spend in a port in relation to the
amount of time these trucks spend on the road outside of a port. 
In some months, these trucks may not operate at all in a port and
spend the entire time hauling materials that do not go into or out
of a port or railyard.

We performed an internal analysis on 6 of our trucks that travel
into the Port of Stockton to haul cement.  These trucks operate a
total 42 hours per day.  Out of those 42 hours, the trucks operate
approximately 1 hour within the port.  This equates to about 225
hours per year of operation within the port, and that is probably
over estimating.  Considering the fleet makeup, we will be required
to replace one truck every two years at approximately $75,000 to
comply with the drayage truck rule.  We estimate that the cost will
equate to $333 for ever hour the trucks operating in the port.  It
is understood that this is not a forum to change the drayage truck
rule, but considering the small percentage of time those trucks
spend in the port versus on the highways, we request that language
be inserted into the truck and bus regulation that allows drayage
trucks to be part of the fleet for fleet averaging and BACT
compliance.  Considering the slow economy, this change would help
to make retrofitting and replacments more cost effective.

Another part of the rule that language should be added is under
the defintion of "2008 Baseline".  Under the current definition,
the 2008 baseline if for trucks that operated 1000 miles in 2008. 
To be consistent with other parts of the rule (definition of low
use), we request that the definition include trucks that also
operated over 100 hours during 2008.

Lastly, we appreciate the new provisions for early retirement.  We
do however, believe that there should be provisions for trucks that
are scrapped or used for parts and not actually sold.  Since the
goal is to get the older trucks off the road, there should be
credit giving to trucks that are taken permanently off the road and
scrapped.

Sincerely,

Steve Azevedo
California Environmental Manager
Knife River Corporation