Comment Log Display

November 11th, 2008

 

California Air Resources Board

1001 “I” Street

P.O. Box 2815

Sacramento, CA 95812

 

Dear Members of the California Air Recourses Board,

The California Air Resources Board (CARB) is currently 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: Western Truck School, who has been an active
small business in California since 1976,  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 Commercial Driver Training 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. Further,
we urge that the state consider,  due to the limited mileage and
primarily off-road use of Commercial Driver Training trucks, as
well as the excessive cost incurred to retrofit or bring our aging
fleets into compliance, an exclusion for trucks in the Commercial
Driver Training field.

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.

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 at inflated prices from the dealerships
brought on by demand and inventory. 

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, or Commercial Driving School
fleets of 10-40 trucks,  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, including us, 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. With locations
throughout the state of California, the impact to our livelihood as
well as the future of Commercial Driver Training in California is
threatened.

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, give special thought to further exclusions to
Commercial Driving Schools in California,  and work with the
industries severely impacted by this rule to adopt a final product
that achieves the balance this alternative proposal seeks to find. 
Our successful future depends on it.

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

Sincerely, 

Michael Darling - Vice President of Operations 
(800) 929-1320  www.westerntruckschool.com