First Name | ChOuris |
---|---|
Last Name | Torres |
Email Address | christorres@fandltrucking.com |
Affiliation | F & L Farms Trucking Inc. |
Subject | Revisions to rule |
Comment | To all Honorable board members, I have been involved in this process for the last 24+ months. I have spent a considerable amount of time away from my business to try and provide my imput on this regulation. The revisions are just a formality to make this regulation law. The agricultural provisions need to be further defined as to the "process" in first point of processing. When I attended the December meeting, when this regulation was approved, there was mention of further study of the economic impacts of implimentation of the rule, has this happened? Will that information change the rule? How accurate are the levels of PM and NOX at our current level of operation? Our company is 40% down in gross proceeds this year. This equates to 40% less miles operated. Our company is not the only one in this situation. All of the studies that brought this regulation to play were acomplished during the high time of the constrution boom. Should this not be considered now? We have tried to be proactive in purchasing new equipment. We are struggling to make the payments. This regulation has also brought on a large amount of competative disadvantage with it. The companies that are in nonattainment areas that have large metropolitan air management districts that are able to fund truck replacements (secat) make it difficult for us that are in attainment areas to compete for the same business. These trucks are not used exclusively in the nonattainment areas they are traveling outside and competing against others that don't have the availability of truck replacement. Can the board reconsider the timeline of implimentation of this rule? I am personaly on the fence regarding this part of me says lets go but then part says slow it down. If a delay is possible, some provisions for the folks that were proactive would need to be made. We proactive folks are counting on higher rates, we have not seen them yet. I don't know if we will anytime soon. Thank you for your time, Chris Torres, President, F & L Farms Trucking Inc. |
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Date and Time Comment Was Submitted | 2009-09-02 20:17:42 |
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