Comment Log Display

     There should be a exemption for low use vehicles, those used
45 days or less a year, these should not be under the same
constraint as the other vehicles.  Also we should have a division,
for small companies that drive less than 30,000 miles per year, per
vehicle.  They should have a more relaxed phase in, say one vehicle
by 2011, another by 2015, another by 2019.  The reason is we have
to pay for these new vehicles, through operations; otherwise we
will only have a lease option available to purchase new vehicles,
with a balloon payment sometime in the future.  As a owner of 3
trucks that drive weekly and a spare truck that drives only when we
have holiday routes, 10 days a year, this proposed ruling would
make us get rid of the spare truck, cause us to buy imperfect
trucks earlier than the manufactures can produce engines that will
meet the future specifications.  I am told by a International
dealer that a 2010 spec engine will not be available until 2011
model year which means late year 2010.  Why would I want to buy any
interim motor that would not meet even the 2010 spec?  California
would be further ahead to have the vehicles purchased as the
technology is available to meet their specification.  

  In my business we can run a truck for 20, twenty years,
currently I have a 15 year old truck with 273,377, 1519 miles per
month, the motor was rebuilt in the last twelve month, no smoke or
visible particulate.  I have a 12 year old truck with 309132 miles,
2146 miles per month, motor was rebuilt in the last six months, no
smoke or visible particulate.  I have a ten year old truck with
169,099 miles, 1409 miles per month, not yet rebuilt, no visible
smoke or particulate.  The 24 year old spare truck has less than
600 miles this year, and it is used on the holiday route, ten days
a year and if another truck needs repair in a shop for a few days. 
This truck has been in spare status since 1996 when we purchased
the other replacement truck.  Its motor was rebuilt after we bought
it around 1992, it was a used truck so it had higher existing miles
and very little miles since 1996.  No smoke or visible
particulates.

   Let me sum up what I have stated above, small businesses cannot
afford to take on several new trucks in a very short time.  If a
truck runs only limited mileage it should be exempt, as long as it
passes the smoke test for its model year. As can be seen from my
average miles driven, we are not the target market to effect a
large change on air quality that will be for trucks that drive more
than 1000 miles per week.  Please focus on these individuals, as,
the greatest improvement to air quality will be seen sooner than, a
one size solution for all of us truck owners.  
    
    I employ 12 people, three use trucks, even the economy is
sluggish we will come out the other side with no lay offs.  But if
I have to buy new equipment, on a short schedule, we will have to
lay off at least one to three individuals to meet the debt burden,
depending on the time frame between the purchases.  
    
    If we have a slower phased in purchase schedule, I can buy the
trucks and still retain my employees, driving cleaner motor trucks
than what is available in the next three to four years.  Also,there
should be a exemption for low use vehicles, those used 45 days or
less a year, these should not be under the same constraint as the
other vehicles.  Also we should have a division, for small
companies that drive less than 30,000 miles per year, per vehicle. 
They should have a more relaxed phase in; say one vehicle by 2011,
another by 2015, another by 2019.  The reason is we have to pay for
these new vehicles, through operations; otherwise we will only have
a lease option available to purchase new vehicles, with a balloon
payment sometime in the future.  As a owner of 3 trucks that drive
weekly and a spare truck that drives only when we have holiday
routes, 10 days a year, this proposed ruling would make us get rid
of the spare truck, cause us to buy imperfect trucks earlier than
the manufactures can produce engines that will meet the future
specifications.  I am told by an International dealer that a 2010
spec engine will not be available until 2011 model year which means
late year 2010.  Why would I want to buy any interim motor that
would not meet even the 2010 spec?  California would be further
ahead to have the vehicles purchased as the technology is available
to meet their specification.  

  In my business we can run a truck for 20, twenty years,
currently I have a 15 year old truck with 273,377, 1519 miles per
month, the motor was rebuilt in the last twelve month, no smoke or
visible particulate.  I have a 12 year old truck with 309132 miles,
2146 miles per month, motor was rebuilt in the last six months, no
smoke or visible particulate.  I have a ten year old truck with
169,099 miles, 1409 miles per month, not yet rebuilt, no visible
smoke or particulate.  The 24 year old spare truck has less than
600 miles this year, and it is used on the holiday route, ten days
a year and if another truck needs repair in a shop for a few days. 
This truck has been in spare status since 1996 when we purchased
the other replacement truck.  Its motor was rebuilt after we bought
it around 1992; it was a used truck so it had higher existing miles
and very little miles since 1996.  No smoke or visible
particulates.

   Let me sum up what I have stated above, small businesses cannot
afford to take on several new trucks in a very short time.  If a
truck runs only limited mileage it should be exempt, as long as it
passes the smoke test for its model year. As can be seen from my
average miles driven, we are not the target market to effect a
large change on air quality that will be for trucks that drive more
than 1000 miles per week.  Please focus on these individuals, as,
the greatest improvement to air quality will be seen sooner than, a
one size solution for all of us truck owners.  
    
    I employ 12 people, three use trucks, even the economy is
sluggish we will come out the other side with no lay offs.  But if
I have to buy new equipment, on a short schedule, we will have to
lay off at least one to three individuals to meet the debt burden,
depending on the time frame between the purchases.  
    
    If we have a slower phased in purchase schedule, I can buy the
trucks and still retain my employees, driving cleaner motor trucks
than what is available in the next three to four years.