First Name | Anthony |
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Last Name | Teresi |
Email Address | atteresi@teresitrucking.com |
Affiliation | |
Subject | Retrofit Program |
Comment | Dear ARB Board Member: We are a California based trucking company operating in and around the ports and have been in business in California for over 40 years. Over the past couple of years we have been letting the California Trucking Association (CTA) represent us with regard to your Air Quality regulations, but considering the fact that your organization seems to be traveling down the same costly road regardless of CTA’s tireless efforts I can only conclude that you are ignoring them and I need to give you my situation in my own words. We recognize the air quality issues facing all of us. In fact, we believe our fleet has done a very good job at running the cleanest fleet we can, since we have a 5 year trade in cycle that regularly puts our drivers in trucks with the newest widely available technology. We are able to turn our fleet over often because we keep our trucks in very good condition and can command a high resale value when that 5 year period is up. You many think that with your new regulations we would not be hurt, since we will be able to “buy our way through” the time line. In other words we will sell our trucks and buy new ones before they need to be retrofitted. But who will we sell to, who will want to buy a truck that needs a $20,000 retrofit in a year or two. Therefore we will have to retrofit before we sell or sell at a discount. Either way we will be facing a loss of about $20,000 per truck. I am fairly certain that CARB would love it if all carriers in California were like us and turned over their fleets every 5 years, but if they were who would we sell our trucks to? And if we cannot sell our trucks for premium prices on the used market then our whole technique of turning over our fleet regularly does not work. We can only operate this way because we get enough on the used market to keep our equipment costs low. The regulations that you are proposing will make our resale values sink and sabotage our turnover program. So here we are, a carrier that is doing everything it can to operate new, clean burning equipment, and your pipe dream of a program puts a kibosh to our system. Our system really works, and it has for 20 years or more. Your proposal is just on paper, you cannot hope to think that you can forcast all of the possible problemst it may cause. Instead of demanding retrofit for all trucks on the road, why not demand improvement of all fleets on the road. If you have a pre-98 you have to buy up to the 98-2002 level or for 5 years or to the 03-04 level for 10 years. When that period is up you would have to again buy up to the next level in 5 years. In this way not only are you improving fleets you are stimulating commerce instead of messing up the used truck market. This method would put all California trucks at the 2007 level in 15 years. Your program does it 9 years sooner but destroys the trucking economy in the mean time. And face it, you could be fighting court battles over your new program for that long. Sincerely Anthony T. Teresi Teresi Trucking, Inc |
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Original File Name | |
Date and Time Comment Was Submitted | 2007-11-21 12:38:39 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.