Comment Log Display

December 10, 2008

California Air Resources Board
1001 I Street
Sacramento, CA 95812-2815

RE: Strong Support for Truck and Bus Rule

Chair Nichols and ARB Members:

Diesel pollution is a highly toxic carcinogen, causing 24,000
premature deaths annually from particulate matter exposure,
including 4,500 annually due to trucks and buses.  In addition,
diesel truck pollution imposes costs on the California economy -
$28 billion annually in just the South Coast and San Joaquin Valley
regions. This regulation is desperately needed to protect public
health and ensure that California can meet federal air quality
standards.  

We recommend amending the regulation (1) to restrict the proposed
exemptions for agricultural trucks and (2) to provide a margin of
safety for meeting SIP commitments.  

The proposed agricultural exemption will still allow for local
exposure to unhealthy air.  To protect public health as much as
possible, we concur with the suggestions to (1) limit fleet size to
small fleets of three vehicles or lower, (2) reducing the mileage
threshold for delayed PM filter requirements (2015) and delayed
2010 NOx engine standards (2023) to vehicles driving under 10,000
miles a year, (3) not including chemical trucks, and (4) requiring
that replacement vehicles must have a PM filter.  

This rule is critical to meeting SIP commitments in the San
Joaquin Valley and South Coast region, but the commitments are so
heavily dependent on the emission standards in this regulation and
its enforcement, that there is no margin for error.  To ensure
compliance, the Board should adopt a rule that will obtain the
reductions needed to provide a margin of safety in meeting SIP
commitments, including requiring vehicle inspections and
third-party evaluations.  

This rule will save over 9,000 lives and prevent 150,000 asthma
attacks.  We urge the Board to adopt this critical rule to protect
public health.

Sincerely,
 
Andy Katz