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MS Earthworks is 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 our future viability in the construction
industry, which is already reeling from unprecedented financial
turmoil. Companies like mine 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. My company and others like us simply don’t have the
resources or access to capital to retrofit our engines.  Some of us
may be forced to sell off our trucks at a loss or shutter our
companies’ doors, ultimately costing jobs and revenue to the
state’s economy. 
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 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.