Comment Log Display

December 2, 2008

California Air Resources Board
1001 “I” Street
P.O. Box 2815
Sacramento, CA 95812

Dear Members of the California Air Resources Board,

Currently you are considering the adoption of an on-road diesel
truck and bus regulation that, if implemented as presently drafted,
would have a profound and negative impact on California’s overall
economy. 

I want to be clear that Camacho Brokers, Inc. is very supportive
of reducing particulate matter (PM) and oxides of nitrogen (NOx)
emissions from diesel engines. There is no disagreement that we
need to work collectively to improve the state’s air quality and
all of us want to provide as healthy an environment as possible for
our families, our employees and all Californians.  However, in its
current form, the Board’s proposed regulation places a significant
economic risk on our business, today, and jeopardizes our future
viability in the trucking industry. 

I am writing to urge the state to adopt a regulation that allows
for flexibility and early incentives, while also achieving
significant emission reductions. To that end, the Driving Toward A
Cleaner California Coalition has submitted an alternative proposal
to the current ARB proposed regulation. This alternative proposal
would achieve the early PM and NOx emissions reductions to improve
the state’s air quality that you are seeking in the ARB’s current
proposed rule, while providing much-needed flexibility to comply
based on a variety of factors including mileage, type and use of
the vehicle, and the best use of the available technology. 

This rule comes at a time when California truck owners are
struggling to make ends meet in the most severe economic climate
we’ve experienced in decades -- skyrocketing diesel prices, record
home foreclosures, a 17-year low in housing starts, a credit crisis
and the imminent threat of a full-blown recession.  Our volume of
business has decreased substantially at a time when the costs of
doing business have risen sharply.  This is not the time to burden
the trucking industry with new requirements that demand
expenditures that would put us out of business.

Our trucking operations are part of our services as a U.S. Customs
brokers at the border of California with Mexico.  Because we are
involved in cross-border operations we are not eligible for any
grants to assist us with the expenses of upgrading equipment.  The
same is true of many smaller companies who occasionally provide
service out of state in order to produce income, but this means
that they too are then unable to benefit from any grants offered.

Under the annual emission reduction targets required under the
current ARB proposal, many truck owners will be required to first
retrofit an engine, only to have to turn around a few years later
and replace those trucks.  The costs of operating a transportation
company are many.  The amount of finger-pointing at the trucking
industry as the cause of so many of the country’s woes is
ludicrous.
Trucking is a vital part of the movement of goods.  Even if goods
arrive in the country by ship or by airplane they arrive at their
final destination by truck.  When the increasing costs of business
drive the smaller companies out of business, decreasing the
competition, the prices of transportation will only go up, further
affecting the prices of all goods, adding to the problems that
already exist in our economy, both within California and across the
United States.  We do not need to force businesses out of existence
and raise the prices of goods for an already beleaguered citizenry,
no matter how important the cause.  We must work together to find
better methods of accomplishing our goals.

Many of California’s trucking companies have already begun the
process of retrofitting or replacing its fleet, whether in the
normal course of their business cycle or in anticipation of these
regulations.  However, the smaller owner/operators – those with
fleets of five trucks or less – who make up more than 55 percent of
all trucks registered in the state will be severely hampered by the
costs of retrofitting or replacing trucks that, in some cases, are
the sole assets of their family-owned businesses. Additionally,
many of these companies simply do not have the resources or access
to capital to retrofit their engines and may be forced to sell off
their trucks or shutter the company’s doors, ultimately costing
jobs and revenue to the state’s economy. 

We must not forfeit California’s economy for the sake of
protecting our environment. That’s why, as a member of the Driving
Toward a Cleaner California Coalition, we’re working together,
across industry sectors, to develop a feasible solution that
achieves the state’s air quality goals while keeping California’s
economy moving forward.  I ask that you evaluate the coalition’s
alternative proposal and work with the industries impacted by this
rule to adopt a final product that achieves the balance this
alternative proposal seeks to find.

We look forward to working with you, CARB, environmental
organizations, the Legislature and other stakeholders to accomplish
these goals.

Sincerely, 




Barbara J. Camacho, President
Camacho Brokers, Inc.