Comment Log Display

Let me start in saying that I do believe that what this rule is
trying to accomplish I completly agree with and support. The issue
that I have:
1) Time frame/Deadlines- We are a a fleet in San diego with 46
onhighway power units. During the next 5 years the requirment of
replacing or updating all of these units in these ecomnomic times
is going to have a very signficante impact on our bottom line. We
have already like most companys had 1 round of layoffs and not
looking forward to others. If this rule was spead over along time
period to alow to spread out cost Would dastically soften the
impact. Our company postion is to replace trucks with new to
achieve the fleet average, Instead of throwing alot of monies at
older units that would normaly be replaced with in the next 2 or 3
years. The cost of a cab and chassis has go up 9% in 2008 alone.

2)Aftertreatment Devices- As it stands now if one was to keep a
older unit, say at 2000 chassis, By 2014 This would require 2
seperate updates in excess of 30k. Instead of rushing into this
ahead of proven availble technology, Would one not wait until these
manufatures could build and support a devices that is reliable at
resumable cost. As it is we the end user have payed for engines
over the course of say the last 10 years that are certifed by the
federal EPA that are not accutual, Now the end user again will be
require to buy from some of these same manufactures A
"Aftertreatment devices.