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Comment 15 for Statewide Truck and Bus Regulation 2008 (truckbus08) - 15-1.

First NameChOuris
Last NameTorres
Email Addresschristorres@fandltrucking.com
AffiliationF & L Farms Trucking Inc.
SubjectRevisions 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.

Attachment
Original File Name
Date and Time Comment Was Submitted 2009-09-02 20:17:42

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