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By industry standards, CD matthes is a small company with 20 power
units and 45 57 foot trailers. We have 2 owner operators that work
with us as well. We are a speciality carrier in the fact that we
have just 57 foot trailers and haul empty food and beverage
containers. The proposed rules, as they a currently written, will
effectively outlaw 57 foot trailers in the State of California. The
companies that use this type of trailer are required to maintain an
overall length of 65 feet or less. This requires a small cab over
engine truck with a cab no larger than 75 inches. There is no truck
maker in North American building any of these trucks any longer.
All production appears to have ceased in 2004. The NOX retro fit
kits will not fit on these trucks and still be able to maintain the
65 foot rule. Newer engines will not fit into the the engine
compartment as they are to large for the available area. 

This leaves the few carriers that use these trucks with only 2
options. By new conventional trucks and new 53 foot trailers or go
out of business. We want to comply with the new rules but the cost
is prohibitive to a small company like this one in such a short
time frame. CD Matthes grew to its' present size from one truck
over a period of 23 years. These rules will require us to purchase
an even greater number of new trucks and trailers in 2 to 3 years.
The cost of this equipment will be somewhere around 4 to 5 million
dollars. This company's gross revenue per year is appoximately 3.5
Million.

If we can afford to re-equip our entire fleet in such a short time
period, we will need to place an extra 3 trucks on the road to be
able to haul the same volume of product we are hauling now. This,
of course, would be at a greater cost to the customer because it is
3 more loads than what we are currently hauling. We would also need
to increase our current rates by 10 to 15 percent to cover the cost
of new equipment. We do not believe that the current market will
bear this cost. That bottle of water that used to cost $1.50 will
probably cost $2.00 after this happens. 

Basically, If we do nothing we are out of business. If we try to
comply with the new rules we will go out of business. We need a
better soultion to this problem. We need a soultion that will not
destroy the States's ecomony by bankrupting the states trucking
infrastructure. Only the very large companies will be able to
survive and do business in California. They will not be able to
handle the volume of product to be hauled and therefore the cost of
everyday products will rise because the surviving carriers will set
the rates at much higer prices due to less competition for the
freight.

In short these rules will wreak California's economy and destroy
our ability to compete in the world market place.