First Name | Robert |
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Last Name | Wheeler |
Email Address | robertdwheeler@verizon.net |
Affiliation | |
Subject | Drayage07 |
Comment | Dear CARB Board and CEO: For a number of years I lived near the Port of Long Beach so that I am particularly sensitive to the "Ports Issue", including drayage. I strongly concur with the Communities for Clean Ports position cited below. PROGRAM SHORTCOMINGS Overall, this is a decent "floor", but the rule is inadequate for areas with severe and growing air pollution problems -- like the South Coast Basin or the San Joaquin Valley. The CARB port trucks rule will not result in getting the cleanest commericially available trucks on our roads given their standards and timeline, which again include meeting EPA 2007 standards only and placing heavy emphasis on retrofitting old trucks. Instead, the goal of the program should be ensuring that the cleanest available trucks and technologies replace dirty diesel trucks, as soon as possible. Here are some additional recommendations to improve it: Close the 2004-2006 Loophole: CARB should require all trucks to meet 2007 standards by 2013; Make sure all major Inland and Central Valley rail yards are included; Enforcement & Accountability: Clean up the regulation's language to ensure adequate enforcement of the port truck rule; Funding: Currently, the Air Resources Board does not include any funding sources. It will rely on other sources that are as yet undetermined. This may prove to be a major stumbling block given the cost of retrofitting a truck, or purchasing a new, cleaner truck. Timeline: The CARB rule would not be enforced until the end of 2009 -- 2 years from now. Thank you for your consideration. Robert D. Wheeler, Ph.D. 29071 Calle del Buho Murrieta, CA 92563-5661 |
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Date and Time Comment Was Submitted | 2007-11-27 08:29:04 |
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