Comment Log Display

California Air Resources                     December 9, 2008
1001 “I” Street
P.O. Box 2815
Sacramento, CA 95812

Dear Members of the California Air Recourses Board,

Currently you are considering the adoption of an on-road diesel
truck and bus regulation that, if implemented as presently drafted,
would have a profound and negative impact on California’s overall
economy. 

 Dependable Highway Express is very supportive of reducing
particulate matter (PM) and oxides of nitrogen (NOx) emissions from
diesel engines. We do not disagree that we need to work
collectively to improve the state’s air quality and all of us want
to provide as healthy an environment as possible for our families,
our employees and all Californians. However, in its current form,
the Board’s proposed regulation places a significant economic risk
on our business, today, and jeopardizes our future viability in the
transpiration industry. 

We urge the you to adopt a regulation that allows for flexibility
and early incentives, while also achieving significant emission
reductions. Driving Toward A Cleaner California Coalition has
submitted an alternative proposal to the current ARB proposed
regulation. This alternative proposal would achieve the early PM
and NOx emissions reductions to improve the state’s air quality
that you are seeking in the ARB’s current proposed rule, while
providing much-needed flexibility to comply based on a variety of
factors including mileage, type and use of the vehicle, and the
best use of the available technology.

This rule comes at a time when California truck owners are
struggling to make ends meet in the most severe economic climate
we’ve experienced in decades high diesel prices, record home
foreclosures, a 17-year low in housing starts, a credit crisis and
the imminent threat of a full-blown recession.

Under the annual emission reduction targets required under the
current ARB proposal, many truck owners will be required to first
retrofit an engine, only to have to turn around a few years later
and replace those trucks. 

Many of California’s trucking companies have already begun the
process of retrofitting or replacing its fleet, whether in the
normal course of their business cycle or in anticipation of these
regulations.  However, the smaller owner/operators – those with
fleets of five trucks or less – who make up more than 55 percent of
all trucks registered in the state, will be severely hampered by
the costs of retrofitting or replacing trucks that, in some cases,
are the sole assets of their family-owned businesses. Additionally,
many of these companies simply do not have the resources or access
to capital to retrofit their engines and may be forced to sell off
their trucks or shutter the company’s doors, ultimately costing
jobs and revenue to the state’s economy. 

We must not forfeit California’s economy for the sake of
protecting our environment. That’s why, as a member of the DTCCC &
CTA we’re working together, across industry sectors to develop a
feasible solution that achieves the state’s air quality goals while
keeping California’s economy moving forward. I ask that you
evaluate the coalition’s alternative proposal and work with the
industries impacted by this rule to adopt a final product that
achieves the balance this alternative proposal seeks to find.

We look forward to working with you, CARB, environmental
organizations, the Legislature and other stakeholders to accomplish
these goals.

Sincerely, 

David Delucchi
Director Fleet Maintenance