Comment Log Display

The California Air Resources Board (CARB) is currently considering
the adoption of an on-road diesel truck and bus regulation that, if
implemented as presently drafted would have a profound, negative
impact on California’s economy.

At Andy’s Transfer and Storage, we are very supportive of reducing
particulate matter (PM) and NOx emissions from diesel engines. 
There is no disagreement 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, jeopardizes many of our members future viability in
the moving and storage industry, which is already reeling from
unprecedented financial turmoil.

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression.  California
moving companies are struggling to make ends meet in the face of a
massive slow down in the residential real estate market.  The
proposed legislation will require small businesses, such as ours,
to spend dollars that we don’t have, in a market where there is
virtually no access to capital for business, large or small.

Companies like ours are being asked to dispose of equipment and
assets before their useful life has been completed and purchase new
equipment before it would otherwise be acquired.  A combination of
this proposed rule and the state of the economy have left the
trade-in or resale value of our equipment worth pennies on the
dollar.  We simply don’t have the resources or access to capital to
retrofit our engines.  We will be forced to sell off our trucks at
a loss or shut their companies’ doors, ultimately costing jobs and
revenue to the state’s economy.

Many of California’s trucking companies have already begun the
process of retrofitting or replacing their fleets, 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.

We have many independent contractors who have invested the bulk of
their income into the equipment they operate.  These are one-truck
operators. They do not have the gross revenue volume of large
companies.  These men and women would be forced to sell their other
assets, most likely their homes or personal vehicles, in order to
purchase new commercial trucks.  Their entire livelihood is tied up
in this capital asset, and the CARB iniative would make it useless.
 DON’T DO THIS TO THE WORKING MEN AND WOMEN OF CALIFORNIA.  They do
not have the funds to survive a change like this.  

Given the multi-billion dollar cost of this regulation – and the
current volatile economic environment – I urge you to support the
alternative proposal proposed by the Driving Toward a Cleaner
California (DTCC) Coalition that would give companies the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions.

In fact, CARB’s own analysis of our DTCC alternative confirms that
the DTCC alternative proposal achieves roughly similar emissions
benefits to the proposed regulation in the long-term.

We must be careful not to forfeit California’s economy and ability
to move goods across the state, build construction projects and bus
our children to and from school for the sake of protecting our
environment.  I look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.

Sincerely,

Jill Longo
Ownder, Andy's Transfer and Storage
Glendale, CA