Comment Log Display

December 9, 2008

Chairwoman Mary Nichols and Members of the Board
California Air Resources Board
1001 I Street
Sacramento, CA 95812

RE:   Proposed Statewide Truck and Bus Regulation 

Dear Chairwoman Nichols and Board Members:

The Solano Asthma Coalition is a member of the CAFA network.  As
asthma advocates, we are very concerned about poor air quality
associated with diesel pollution and urge you to approve a strong,
health protective regulation.

We recognize the challenging economic times that the state is
facing as the Board is presented with this regulation.  However,
the economic and health costs of doing nothing are apparent. 
Because California is home to some of the worst air quality in the
country, it is not surprising that asthma is a major cause of lost
school days and emergency room visits.  In California, there are
over 14,000 asthma-related hospitalizations a year just for
children under the age of 15 with a cost of about $19,000 per stay.
 Furthermore, the November 2008 Jane Hall study found that air
pollution in the South Coast and San Joaquin Valley regions alone
costs the California economy $28 billion annually.  The swift
adoption of a strong regulation is vital to removing the health and
economic burdens of unhealthy air and can ensure that California
can meet federal air quality standards.  However, we ask the Board
to consider restricting the proposed exemptions for agricultural
trucks and provide a margin of safety for meeting SIP commitments.


We applaud ARB’s efforts to move forward with this ground-breaking
regulation that will reduce costly public health emergencies and
clean our air.  Our main concerns with the October 24, 2008
proposed regulations involve the agricultural exemptions.  These
exemptions are far too broad and compromise the health protections
of the regulation for those living or working near the agriculture
industry, especially the Central Valley.   We suggest reducing the
mileage threshold, requiring PM filters, limiting fleet size, and
not expanding the definition of agricultural vehicle to include
trucks owned by ancillary businesses.  This will still provide
special consideration to the agriculture industry, but will better
protect public health.

Finally, we hope that CARB will continue vigorous outreach to
truck owners to ensure incentive programs are understood and
accessible.  We will not see benefits from this regulation if
owners are unable to comply with the rules.  Ensuring owners are
aware of the multiple funding sources that can be leveraged to
assist individual truck and fleet owners, will maximize compliance
with the rule and minimize the economic impact on owners and
business.

Sincerely,

Susan White 
Program Director 
Solano Asthma Coalition 
1652 W. Texas St, Suite 102C
Fairfield, CA  94533
707-434-9685