First Name | Craig |
---|---|
Last Name | Phillips |
Email Address | cphillips@ironmanparts.com |
Affiliation | President |
Subject | Comments from Ironman regarding proposed amendments |
Comment | April 14, 2014 As a leading California retrofit installer and emissions compliance company, Ironman works with many fleets and independent owner operators seeking CARB compliance. In the past year, Ironman has experienced a significant increase of Owner Operators seeking compliance due to the December 31st, 2013 deadline and also now the Good Faith Extension July 1st deadline. Due to the volume of Owner Operators seeking compliance, and the majority of these drivers also needing compliance information and financial assistance, Ironman needed to staff up quickly. Thereby, Ironman has staffed up an entire department in order to assist the IOOs with applying via lenders, helping with the documentation and communication process, and assisting with the lender approval process. However, with CARB’s proposed amendment to the regulation, to “defer compliance with the PM filter requirements for up to 3 vehicles for any owner that cannot get financing to comply” there is serious concern that now Owner Operators are more motivated to be declined by a lender than to actually seek CARB compliance. There are already unintended consequences cropping up in the industry as a result of the good intentions by CARB to offer flexibility. The motivating factor for Owner Operators is to simply obtain a decline letter from either the most conservative lender or even fraudulent lenders. For those Owner Operators that are truly in a dire situation and have genuinely been declined, the proposed CARB extension will allow these truck owners to meet compliance through a more flexible path. However many Owner Operators have trucks exclusively dedicated to a single large fleet and operation, thereby some financial assistance could possibly be sought from the mother fleet. Ironman proposes that CARB employ a methodology in order to weed out any suspect denial letters from the genuine ones by requiring the credit score to be provided with the denial letter. *Generally IOOs that are under 575 credit score will truly have a difficult time being approved by lenders. *IOOs with a credit score higher than 575 may also be genuinely declined, but there is higher chance of fraudulent reporting in this category. CARB should take a different approach with anyone claiming to be denied that has 575+ credit score and ask one of the CARB approved lenders to re-qualify the applicant. Another methodology CARB could consider is requiring Owner Operators to produce three denial letters, one being from a CARB backed lender in order to validate the claim of financing declination. This would significantly eliminate the possibility of fraudulent lenders handing out denial letters. To put some cause for concern of anyone possibly submitting fraudulent information, CARB may consider adding the following language to the documents required for submitting denial information “I certify under penalty of perjury under the laws of the State of California that the information on this document is true and correct.” Many small fleets (and large) have gone through the complete compliance process having faith that industry compliance was fair and all fleets alike were on their path to compliance. However, the possibility of any fraudulent-based extensions will give way to unfair competition, resentment from those that “did the right thing” and sought compliance, and another blow to CARB and industry compliance efforts. Ironman respectfully requests CARB to reconsider offering retrofit grants to small fleets as a means of assisting many that cannot afford to comply with the regulation, whether its retrofit expense or even new truck replacement. Some fleets with dedicated Owner Operators have taken the step to support their network of drivers and offered financial support. Ironman applauds this effort and encourages CARB and fleets alike to consider this as an avenue for industry compliance. |
Attachment | |
Original File Name | CARB letter - Ironman comments re amendments.pdf |
Date and Time Comment Was Submitted | 2014-04-14 16:27:44 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.