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Dear ARB, We are a family owned trucking company in the SF East Bay
Area for the last 45 years,  that employs about 150 people. Our
drivers are members of Teamsters Local #70 in Oakland, Ca. We are
concerned over the agressive nature of the Private Fleet rule in
regards to replacing or retrofitting trucks that do not have the
latest emission technology. Our company purchases good quality used
trucks when it is time for replacement. Due to the nature of
competition we face in a typically non union environment, we have
to watch our costs in order to stay competitive and continue to
employ quality union labor. Our employees receive an attractive
benefit package that is virtually unheard of in these current
times. In return our employees stay for many years and consider
their employment as a "career" rather than a "job". The point being
that we can provide an attractive working environment using the
latest equipment we can afford that suits our operational needs.
Our trucks only travel within N. California and average about
40,000 miles per year. Their useful life for us is about 10 to 15
years. In the last 2 years we have replaced 17 of our oldest
equipment, 1980 vintage, with late 1990 early 2000 equipment. For
us to purchase "new" equipment is not economically feasible. We
take advantage of the quality used truck market. It affords us the
latest equipment at a price we can afford. Basically, we feel that
through this attrition rate, we can do our part to deal with the
emission problems that our state is facing and still maintain a
competitive posture in these uncertain times.
Thank you for your consideration.
Alan Osofsky, Gen Mgr.