Comment Log Display

I started my business in 1976.  I have been one to for the last 32
years, to do my best to support and adopt all regulations be them
state or federal that intend to better our industry in regards to
safety or the well being of the motoring public.  What CARB is
attempting with the private fleet rule, I feel is well intended and
deserves my support and the efforts of all companies in the
trucking industry.

I own 101 trucks.  I operate in 11 western states, but 85% of what
I do is inside the state of California.  I primarily service some
extremely specialized areas of the transportation industry.  I have
been able to purchase 5 2008 power units so far in an effort to get
the ball rolling in the right direction in regard to my personal
situation. 

I am and have been aggressively as possible updating equipment and
planning in every way I can to move my fleet in the direction CARB
has outlined in the private fleet rule.  The issues that exist for
me and the problems that I face at the pace set forth by CARB are
as follows:

1)  The economy in its current state has slowed down my business
to the point where I am desperately struggling to continue to fund
my employees 401(k) and to maintain their benefits at there current
levels going forward. This leaves very little capital to allot to
more new equipment at this time or in the foreseeable future.

2)  I have tried to obtain grants of various types and have
learned that is has been pretty much a waste of time due to the
fact that my company doesn't qualify for one reason or another.
This being said it is extremely difficult to pass on the additional
cost of the newer trucks in any large volume to my customers in the
form of rate increases especially in this economy.  I have also
found it next to impossible to obtain a reasonable interest rate on
the equipment I have coming in due to the financial situation that
exists in our nation today.

3)  One of my biggest obstacles that is unique to my company is
the unique spec and unusual configuration of the majority of my
power units.  To do the kind of work I do properly my normal spec
truck is a cabover engine body style with an extremely long wheel
base and high horse power engines.   This makes my trucks
irreplaceable with what's available today in regard to the cab
design that I need for the many 80' to 140' loads that I haul on a
regular basis.  If I were to do away with all of my cabovers and
replace them with the trucks that are available through the
manufacturers today at the pace CARB has set forth in their plan I
would surely be unable to service the majority of my customers.

4)  A huge concern to me is my largest customer; a precast
concrete products manufacturer has installed on 30 of my trucks a
hydraulic crane for the purpose of off-loading their product at the
jobsite.  In order to maintain the load space on the truck in
addition to having the crane mounted as it is currently would not
only be impossible now that the cabover engine truck in unavailable
by any supplier, but in addition it would be astronomically
expensive to remove these permanently installed cranes and
re-install them on new chassis.

5)  Another large impact to my operation is going to be the fact
that no other state particularly cares what CARB is up to in
California and if I'm put into a position to conform and then try
to compete with all my competitors out of state that are not
burdened with the costs that I am subjected to, I would surely lose
that portion of my market share.

6)  I've seen no plan on how CARB is planning to tie this program
to any effective enforcement policy, leaving me to wonder will it
be like so many other regulations that exist in our industry where
legitimate companies are burdened with the costs of doing it right
while competing with others that don't even come close.

I do not see any way possible that my operation, that I have
worked very hard since I was 18 years old to build could possibly
survive the transition that I would have to go through to conform
to the private fleet rule as it is currently proposed. With all due
respect I sincerely ask that CARB and all concerned please take
into consideration the many obstacles that they are placing before
me and the many companies like mine as they finalize the private
fleet rule.  I strongly urge that the California Trucking
Association alternative is considered as we all try to achieve the
goals and good intentions for all of us that live in the State of
California, that CARB is trying to accomplish.