Comment Log Display

We are a transportation and organics recycling company that has
been in business since 1946.  We Care about clean air and want to
work to achieve a reasonable goal for California.  The regulations
CARB is looking to implement as presently drafted will have a
prolonged negative effect on the California economy.  They will
reshape trucking industry, cause service disruptions, hurt
infrastructure programs  as many small SERVICE businesses are put
out of business. Why?
1. Your actions have devalued our current assets 30-70% meaning
Banks that look for assets to loan against will not loan us money
since you devalued our existing trucks.
2. With no borrowing power from this devaluation and the current
state of the national economy, previously well capitalized business
cannot purchase the equipment you are asking them to buy.
3.The time frame of the replacement is unreasonable even in good
times!
Your regulations are based on inadequate information and a
complete lack of understanding economics and  business, more
importantly the Trucking Business.  Why?
1. Your inventory of on road equipment is not accurate!  
2. Your inventory of miles driven either does not exist or is
completely inaccurate.
3. Your equipment upgrade schedule does not take into account a
trucks yearly mileage so therefore does not reflect the trucks
contribution to air pollution.  Ex. Three 1993 trucks, one travels
100,000miles a year one travels 25,000 and one 12,000.  Which harms
the air quality the most? Answer is #1 using common sense but your
calculations say all three.
4. Some companies like ours have two trucks per driver because the
trucks are configured differently.  This means only one truck is
emitting PM or NOX at a time.  CARB does not figure this out.
5. We have looked to Carl Moyer for funding but are told our
mileage is high enough but CARB says we have to replace this same
equipment Moyer says is not worthy of funding!
So what does the above mean?
We have replaced an older truck with a new 2007 truck but even
this is truck is facing limited life.   Given the multi-billion
dollar cost of this regulation – and the current volatile economic
environment  - I urge you to support the alternative proposal
proposed by the Driving Toward a Cleaner California (DTCC)
Coalition that would give companies like mine the opportunity to
comply in the most reasonable timeframe and flexible manner
possible while still attaining aggressive emission reductions. 
In fact, CARB’s own analysis of our DTCC alternative confirms that
the DTCC alternative proposal achieves roughly similar emissions
benefits to the proposed regulation in the long-term.
We must be careful not to forfeit California’s economy and ability
to move goods across the state, build construction projects and bus
our children to and from school for the sake of protecting our
environment. (I/We) look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.
Sincerely, 
Bob Engel
Engel & Gray, Inc.