Comment Log Display

Shasta Union High School District
Transportation Department
2675 Eighth Street, Redding, CA  96001
Phone:  (530) 241-0416    Fax:  (530) 225-8470   
E-Mail:  tcarroll@suhsd.net
Director:  Tom Carroll
																																										
December 10, 2008


Subject: Agenda Item 08-11-3 School Bus Regulations


To Air Resources Board Chair Mary D Nicholas:

First, we would take this opportunity to congratulate the
Sacramento Air Quality District for recognizing the severe fiscal
difficulties that school districts are currently facing.  They
madethe wise decision to fund the ARB’s required 25% district match
for the Prop 1B school bus funds out of their own funds.  The
Sacramento area school districts appreciate that decision. Thank
you. Unfortunately the Shasta County Air Quality Management
District did not follow their lead.

Our district serves approximately 5,174 high school students in
rural Shasta County. Shasta Union High School District covers a
geographical area that is almost 1800 square miles or viewed
another way slightly larger than the State of Rhode Island. SUHSD
buses log double the annual mileage of the average California
school bus while traveling this expansive area. Additionally close
to 35% of our students qualify for free and reduced meals, the
poverty indicator established by the federal government.  The real
poverty measure is actually higher because many high school
students are ashamed to admit that they qualify for the federal
program. 

Our annual per student funding is approximately $6,700 and with
additional categorical funds provides our District an operational
budget of about $50 million dollars.  Approximately 80% of these
funds are used for employee salaries and benefits.  The balance is
used to support the educational program and the infrastructure
needs of the District.  

Our state approved school transportation budget for 2007-08 was
$1.48 million.  This funding does not include sporting events and
field trips. It only includes the approved cost of transporting
children to and from school. However, in 2007-08 our district only
received $747,000 from the state to operate our transportation
department.  Every year, we must take an additional $750,000 from
the classroom to support home-to-school transportation, curricular
and sports field trips are an additional expense.  In the last
seven years SUHSD has been very fortunate to qualify for funding
from the Lower Emission School Bus Program. We have used these
funds to replace older, less safe buses that produce greater
emissions. SUHSD used a significant portion of the money to
purchase and operate the largest fleet of natural gas buses in
Shasta County. However, the result is still a school transportation
fleet that is too old. The Department of Education has estimated
that the maximum age for school buses is fifteen years.
Unfortunately, over 34% of SUHSD buses exceed that maximum age.  We
do support the state’s attempts to provide additional funds for
school bus replacement.  We have seen some progress, but not
enough.

Almost all school districts are facing a horrendous budget crisis.
Even though this year has seen huge increase in fuel prices, our
school transportation program had to be reduced because the state
budget that was passed in September gave us the same amount of
funding as last year, 2007-08.  SUHSD has cut service to the bare
bones, walking distances of three miles, reduced service in rural
areas of our district creating riding times of over an hour and a
half, one-way, less funding available for training, supervision and
maintenance.

Now, both the Governor’s special session proposal and the
legislature’s alternative is going to make mid-year reductions
almost 5% or over $320 per child or almost $16 million.  These
reductions are based on proposed revenue increases.  If those
increases do not occur, the reductions will double.  Your
regulations do not take effect until 2010-11; however, the
Legislative Analyst in his most recent report has stated that it
will be until 2013-14 before the state general fund revenues
exceeds the levels in 2007-08.  Education is not only facing
incredible huge reductions this year that will take us years to
recover, but we will continue to face extremely difficult times
for the next five years.  That is the major problem that we have
with your proposed regulations.  

Your propose regulations will cost our public schools $500 million
in the next ten years for the trap requirement and for the school
bus requirement.  $500 million is the amount that the state or we
will have to pay for the mandated traps and for the mandated school
buses.  Your staff has made cost assumptions, many of which we do
not agree with, based on the current value of the school buses. The
most important part is that no matter what assumption one uses, our
school districts, or the state will have to come up with $500
million to pay for the cost of the traps and cost of the new school
buses.  We do not see where these funds are going to come from.

We firmly believe that the requirements your regulations will
impose on our public schools are a reimbursable mandate as defined
by Article XII B of the State Constitution and under Government
code section 17514.  That means we will be able to file claims to
the State Commission on Mandates and we will eventually be
reimbursed by the state.  We do not think it is appropriate at this
time to worsen the deteriorating fiscal condition of the state by
another $500 million.

Consequently, we would urge the ARB Board to make all their
requirements on school buses contingent on available funding.  We
would work hard with ARB to obtain that funding.

Our second and final issue with the ARB regulations is a long
lasting issue.  ARB’s priority has always been on the requiring
diesel retrofits or traps as oppose to the replacement of old
pollution school buses.  In this regulation, ARB is proposing that
all school buses manufactured between 1987 and 2006 be required to
have diesel retrofits or traps installed.  School buses
manufactured prior to 1987 are required to be replaced by 2018.  We
believe that ARB’s priorities are backward.  Pre-1987 school buses
contain no particulate controls.  The replacement of these school
buses should be the state’s highest priority.  Why do we want to
have over 120,000 children ride in these school buses for the next
ten years?

In regards, to diesel retrofits or traps, we are not opposed to
the requirement.  However, the state should set up several
long-term pilot studies to determine the true cost and the true
impact of the traps.  Our concern is that the state is being sold
a bill of untested goods.  The staff report state that the cost of
the traps is the only cost.  That is totally incorrect.  We know
the following cost must be included: installation, shipping,
cleaning machines, electrical infrastructure, spare cores, taxes,
electricity cost, cleaning cost, removing and replacing cost,
waste disposal cost, possible engine repair, cost of the bus being
out of service, and a possible fuel increase.  Many of these costs
are not one time cost, but will be regular costs.

We find it particularly distressing that ARB will be imposing
traps on very old school buses that were built before 1993.  The
cost of the traps may exceed the cost of the old school buses. 
These traps are the so-called active traps that are much more
expensive to purchase and to maintain.  We are extremely excited
about some of the new school bus technology that is currently
available or will be available in the very near future.  For
example, the new hybrid electric school buses may be cost
competitive with the CNG school buses.  A zero emission school bus
will be available in the very near future.  This is the direction
that California should be moving.  Requiring questionable traps on
old pre-1993 school buses is the wrong approach.  We should be
replacing these school buses with the newer exciting technology.ARB
should be helping us do it right, we cannot afford to do it wrong. 
Thank you.


Sincerely yours,



Tom Carroll