Comment Log Display

October 19, 2009
VIA REGULAR MAIL and E-MAIL

Mary D. Nichols
Chair, California Air Resources Board
1001 I Street, P.O. Box 2815
Sacramento, CA  95812-2815
mnichols@arb.ca.gov

RE: CMSA Written Comments on the California Air Resources Board’s
Truck and Bus Regulation (second 15-day Notice of Public
Availability of Modified Test to Consider the Adoption of a Diesel
Particulate Matter and Oxides of Nitrogen and Greenhouse Gases
Control Measure for On-Road Heavy-Duty Diesel-Fueled Vehicles
Operating in California)
	

Dear Ms. Nichols:

My name is Stephen J. Weitekamp and I am the President of the
California Moving and Storage Association, located at 10900 E.
183rd St. Ste 300, Cerritos, CA 90703.  Our Association represents
approximately 430 licensed moving companies and another 130
companies that provide services for the moving industry. These
companies provide jobs for approximately 10,000 Californians, but
many of our members are struggling to survive in this state’s
current economic situation and the new CARB law will undoubtedly
result in some going out of business or moving out of California. 
This is a plea for help from an important sector of small
California based businesses that need relief from the present
provisions of CARB.

The CARB On-road Diesel Engine Regulation will make many local
moving trucks illegal after 2010. This will severely impact
California-based moving companies and further add to the state’s
worsening economy. 

California’s recession is the worst in at least three decades and
the unemployment rate was an unheard of 11.5% in May and likely to
increase through the remainder of this year.  This is the absolute
WORST time to enact draconian regulations on any business that owns
a diesel powered truck including the moving and storage industry.

During the CARB hearing process, many within our industry hoped
that CARB would modify their rule into mileage tiers to accommodate
trucks that run 10,000 – 30,000 miles, 30,001 – 70,000 miles and
70,000 + miles per year. Minimally, we believe CARB should have
adopted a two tier rule, at least within the moving and storage
industry. In our industry there are two completely different types
of diesel trucks utilized – high mileage and low mileage.  The high
mileage users tend to drive more than 100,000 miles per year and
are in industries such as long distance moving, logistics/delivery
and freight.  Low mileage users tend to drive 30,000 miles or less
per year and are in industries such as local moving and delivery. 
CARB has ignored all requests and suggestions to tier the rule even
though it did for the Off-road rule.

It has also recently come to my attention that there is
controversy regarding the scientific studies CARB used to justify
these regulations and whether or not they were properly peer
reviewed.  A growing list of prominent scientists disagrees with
the regulatory process and one-sided science that is being utilized
to take-away our equipment. We need your support to make sure CARB
is being responsible for everyone.

Prior to 2009, an efficient market existed for late model used
trucks. High mileage industries buy new trucks and after four or
five years of use sell them to companies that provides local
services.  Low mileage industries efficiently utilize these trucks
for many years before replacing them. We are the ultimate recyclers
and re-users of diesel trucks. There is a huge environmental
savings to this reuse that CARB again ignores.
My Association and industry is requesting changes to the existing
regulations:

1)Provide an exemption to trucks driving 30,000 miles or less per
year.  This allows for a market to exist for the high mileage users
to trade-in/resell/replace their trucks while allowing the low
mileage industries to survive and utilize newer more efficient
equipment.

2)Push out the start of the regulations for at least two
additional years – these regulations should not be enacted until
California is deep into an economic recovery.

3)Increase the time period between each truck year replacement
date – California’s current economic state and the cost of new
trucks coupled with the frozen capital markets has made it almost
impossible for us to survive this economic crisis without
significant risks.

Many CMSA member companies cannot afford to simply purchase new
trucks.  Even if they could, the credit markets are dysfunctional
and they cannot risk large truck payments when business is down
significantly.  A retrofit solution doesn’t exist and even if it
did, it only buys a few years before many trucks ultimately become
illegal in California. Retrofitting is not a reasonable proposition
for the low mileage industry.

Please use this opportunity to make changes to the CARB
regulations that are fair, equitable and realistic.
Sincerely,
 
Stephen J. Weitekamp
President