First Name | Shellie |
---|---|
Last Name | Archer |
Email Address | archertrucking@hotmail.com |
Affiliation | Archer Trucking, Inc. |
Subject | CARB Truck Rules |
Comment | Governor Arnold Schwarzenegger Members of the California Legislature California Air Resources Board Dear Governor Schwarzenegger and Members of the California State Legislature or CARB: 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. I want to be clear: Archer Trucking, Inc., a Certified Small Business in California, is 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. However, in its current form, the Board’s proposed regulation places a significant economic risk on our business today, and jeopardizes our future viability in the "construction" trucking 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 truckers are struggling to make ends meet in the face of a massive slow down in the construction sector due to falling home prices and home foreclosures, declining consumer confidence and spending and a freeze in the credit markets. Today there is virtually no access to capital for my business. We have used the figures provided by CARB (estimated costs) and discovered it will cost almost $37,000 PER MONTH for the next six years to comply with the schedule that is being proposed. We own around 30 trucks and employ 20 people. There is NO WAY we can afford an extra $37,000 payment each month. The timing of the proposal is so unreasonable. 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. Because we are in a "clean" county, we do not even qualify for the funds that may be available for those in the Bay Area Corridor, the central California area, or Los Angeles. The unfair part of this is that we DO leave our county to work so we must comply like everyone else... we just don't get any money. Our Company has already begun the process of replacing our fleet in anticipation of these regulations by buying two new trucks. We felt we HAD to start sometime, so we did six months ago. However, the smaller owner/operators 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. These men and women usually have NO payment on their trucks, and simply cannot afford a three to four thousand a month payment on a new truck. 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 like mine the opportunity to comply in the most reasonable timeframe and flexible manner possible while still attaining aggressive emission reductions. In fact, I have been told that 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. We look forward to working with you, CARB, environmental organizations, the Legislature and other stakeholders to accomplish these goals. I will be at the hearing Thursday and Friday, and certainly hope things don't go forward as they are proposed right now. Sincerely, Shellie A. Archer Archer Trucking, Inc. 3480 N. State Street Ukiah, CA 95482 707-489-3091 |
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Date and Time Comment Was Submitted | 2008-12-08 14:59:08 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.