Comment Log Display

November 24, 2008

From:  Lee Hobbs, Chief of Operations
       Hobbs Trucking Co.

To:  The California Air Resources Board

Dear CARB Board Members

This letter is sent to strongly urge you to reconsider your
current proposed General Fleet rule for California for trucks
operating in California.

Instead, I respectfully request that you adopt a simple but
effective alternative that is similar to your ban on all trucks
1988 or older.  My idea is to ban, on an annual basis, all trucks
that are older than 12 years old as of the date of registration
renewal.  The fleet of trucks operating in the state would then
reach your goal of only 2010 engines on the highway in the target
year of 2022.

Adoption of this alternative would accomplish your end goal in the
same year and save the trucking industry millions of misspent
dollars on retrofit equipment that does not work as advertised.  I
know that many of the current verified DPF devices are not
producing the CARB's reported result and have been removed from the
verified list as a result.  Those truckers who bought those devices
are out the money on devices that do not operate as advertised.  We
can no longer afford to comply with your requirements when they
simply do not produce the reported results.  If you adopt my
suggested plan, we, the truckers will be allowed to get the
expected life out of the trucks that we buy and the older more
polluting trucks will just go away.  The result of my idea is a
guaranteed result of cleaner air over time with no administration
or enforcement costs to anyone.  This is a good thing when you
consider that we are in the worst economic downturn since the Great
Depression of the 1930's.

Please, for the sake of fiscal responsibility and sanity, do not
adopt the proposed General Fleet rule and if you cannot accept my
suggestion, please then consider the proposal set forth by the
coalition called Driving Toward a Cleaner California.  Anything is
better and fiscally more responsile than the plan currently set
forth by the CARB.

Respectfully,

Lee Hobbs