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Comment 81 for Statewide Truck and Bus Regulation 2008 (truckbus08) - 45 Day.

First NameTom
Last NameTanner
Email Addressttanner777@aol.com
AffiliationA-1 Sweeping Service
Subjectfinancial impact will kill many
Comment
These new smog rules are going to have adverse economic reactions. 
 Industry (any trucking, const, heavy equipment, etc...) will
always eventually replace their old equipment anyhow, by virtue of
natural attrition.   The way CARB proposes to accelerate this, by
mandating expensive retrofits to older value-less equipment, will
simply mean that "the big get bigger, and the small get smaller" :(
 Only those with deep pockets (the larger fat cats) will be able to
go out and buy the newer engines or new units, and dump their old
fleet "overnight".   

It's the small time startups, or small-time guy in a niche
industry, or in a small-town geographic locale, that keep the
market economics fair play.  In other words, if only the larger
fat-cats either already have equipment that's already new, or can
simply afford to dump their old fleet overnight, then what do you
think will happen to the competition factor?   Those big enough to
weather this would control the market, that was previously "kept in
check" by small time startups, small-town mom-&-pops suppliers,
etc...  If those of us with older equipment are forced to abandon
ship, those that remain will simply have a captive market to gouge
for whatever price they want.

I know for a fact that I can not survive, if the laws as proposed,
go through.   The equipment I have is not worth retrofitting at
$20k+ each with after-market devices.  It is questionable whether
it can even be done, whether it fits, whether it's safe, etc...   I
could certainly go out and buy several new units at $250k each, but
there is no way in h*ck that my customers will shoulder the cost
per hour I'd need to charge.   They'd simply call up a "fat cat" in
a larger city 1 hr. away.  So much for checks and balances of
market economics, eh?   Get ready to love your future tax-burden
for cost of public works, public roads, etc...

I could shoulder perhaps retroffiting one or two, or perhaps
getting a unit per year, over the next few years, but in our
industry, we need backup machines.   The grueling type of work we
do (sweepers on paving jobs), takes a lot of abuse.  Yes even on
brand new units, they can breakdown on a job.  So we are accustomed
to keeping a spare within "striking distance".   Therefore I have
spares that litterally may only go out a few weeks or a month's
worth per year.   Common sense says that they are not worth
spending any time or extra money on these.  I would simply fold my
cards and bail.    

There's got to be some concession by CARB to allow some sort of
low hours/miles backups, or exemptions for niche industries.

CARB personell seems to think that "supply and demand" will
naturally step up to the plate, and commerce will keep at the
current pace.  Their logic is simple, to those who cry "financial
impact":  They'll say "Raise your price".  To that, a friend of
mine challenged that logic, and said "If McDonalds raised Big Mac's
to $14 each, people would buy less".  The CARB person responded: 
"No they wont.  Because people still have to eat".   Well
unfortunately sir, people don't need to "eat" new streets.   People
don't need to "eat" clean parking lots and cleaner streets. 
Believe me, cities (for their street programs) and private shopping
center owners (for their parking lots) do choose ALL THE TIME to
buy less (in your analogy "eat less").   A city, for example, that
cleans residential streets 2x per month, could indeed elect to drop
down to 1x per month, if the cost became prohibitive.  Afterall,
the leaves and litter "can wait a bit longer".   Heck, I'm old
enough to remember when my residential street was swept 1x per week
in my neighborhood as a kid.  Why do you think they decreased?  The
almighty dollar speaks!   And the same is true for shopping center
owners, industrial plant owners, etc...:  When times get tough,
they cut back on frequency.  I've had many customers go from, for
example, 2x per week service, to 1x per week service.    And Uncle
Sam can indeed elect to delay road repairs for "awhile longer" if
it becomes too expensive.  Afterall, "people can drive a *little
longer* on roads with pot-holes, eh?"   So PLEASE!  don't tell us
that "people will continue to buy the same amount of Big Macs". 
They won't in a lot of cases, where your analogy doesn't hold.   

In the case of street sweepers, if your stated goal is to reduce
pollutants, then it would seem to me that you should aim to have as
many as possible street sweepers roaming the streets!   Example: I
have many customers who, if they seek to "watch their budget", will
have us only come in at the end of a day during a truck haul (where
dirt is getting drug out of construction sites).  Or, if the cost
is reasonable, will elect to keep us there all day, not letting it
build up to begin with.  Which option do you think is more
effective at fugitive dust control?  Which option do you think will
arrest the dirt before it is spread onto side streets (invisible
enough, yet still present, at places that aren't on sweep routes)  
So let's be reasonable, if street sweepers are reasonably priced,
customers will use them more liberally.  You can't have it both
ways.  You will indeed have more pollution with less sweepers, and
you will indeed have less sweepers with higher cost-per-hour/less
competition.    

The sole purpose of a sweeper is to pick up and remove debri,
which results in air-borne cilicate pollution, ground water runoff
with silt, etc..   What better tool for use in your stated goal??

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Date and Time Comment Was Submitted 2008-12-01 12:10:41

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