Comment Log Display

Your proposal to expand the number of vehicles eligible for
scrappage is seriously flawed for several reasons.

1.	There are approximately 692 thousand Pre-1976 vehicles in a
California Fleet of 25 million vehicles (data courtesy of
Inspection and Maintenance Review Committee). That is about 2% of
the fleet.
2.	Pre-1976 vehicles are for the most part non-emission controlled
vehicles for which emission tests do not apply.  That is less than
7 tenths of 1% of the fleet….trivial. That makes for a high cost
proposal when calculating cost per ton of pollution removed.
3.	When looking at the makeup of this segment of the fleet, it
includes Horseless Carriage Vehicles, Hotrods and classic cars that
are trailered to Car Shows, classic cars under construction, and
cars that are garaged most of the year but brought out just for car
shows.
4.	It costs anywhere from $40K to $150K to put together a good
show car. These cars will never make it to scrappage. Many of these
vehicles never make it out of the project stage because it takes
much planning, research and problem solving to make these vehicles
roadworthy. I go to car shows a lot. The only vehicles that are
“CLUNKERS” as you call them are ones where they are characterized
by rust or fit the term “RATROD”. Of the group of 692 thousand
cars, I would estimate the number of “TRUE CLUNKERS” at maybe 5000
(most of which are only seen at shows). Contrary to CARB
assumptions they are for the most part NOT daily drivers. 
5.	I can speak from personal experience. I purchased my 1965
Mustang in 1998 and still have it today. Since 1998 that Mustang
has been on the road about 18K miles. That averages out to about
1800 miles per year on the road. That is not a lot when one
considers that the average Vehicle Miles Travelled per year is 16K.
My second hobby vehicle is a 1964 One Ton Panel Van. Since December
2008 (when I purchased it), the vehicle has chalked up maybe 150
miles. It has spent most of its time becoming roadworthy at
restoration shops. Neither will reach scrappage.
6.	My other two vehicles are a 1990 Chevy Van and a 1994 Toyota
Pickup (both of which are included in the Daily Driver Category).
These vehicles together get about 15 thousand miles per year.
7.	My conclusion is that your numbers on Total Vehicle Miles
Driven for the Pre-1976 vehicles are grossly over estimated. In
talking to other hobbyists I find that I am not alone but rather
the norm. If you calculate the cost per ton to implement targeting
Pre-1976 using real numbers (not the assumptions you current use) I
believe that you will find that the proposed regulation is
prohibitive in cost.
8.	Next, if you look at the proposal, the vehicles must be totally
scrapped which leaves nothing for dismantler parts to put the
restoration vehicles back together. This is something that I find
highly objectionable.
9.	Next, when these vehicles are scrapped they must be totally
crushed. Then an “Emission Reduction Credit” is issued that only
industry can buy (not the individual). These “Emission Reduction
Credits” are tradeable in the Commodities Market for anywhere from
$1000 to $25000. Only industry can buy these. It transfers “The
Right To Pollute” from the “Vehicle Owner” to industry. I find this
to be pure hypocracy.
10.	Using CARB Proposed Regulation Statements this would affect
15000 vehicles per year at a cost of possibly $2000 per vehicle.
This is an approximation of $30,000,000 per year….At a time when
the State cannot even meet their existing financial commitments.
For example the BAR CAP Program is going broke because so many
people have taken advantage of the Assistance Program as a result
of the economy. To help consumers that want to keep their car
running would make far more sense than scrapping cars and
transferring “The Right To Pollute” to industry. $30 million would
go a long way to keep the CAP program operating.
11.	This regulation is also duplication in that the function in
question is already covered by the CAP Program.
12.	Next, when following the news, California has a huge deficit
in case you weren’t aware. The Legislature is having a free-for-all
on the budget and trying to decide what are the least painful
spending cuts to implement. They and the Governor have made huge
cuts in essential services such as Public Safety, Fire, number of
state employees, college funding, etc. These are essential to daily
life. “CAR SCRAPPAGE” is NOT. “Car Scrappage” is at the bottom of
the food change in today’s economy.
13.	This Proposal is Entitled “Enhanced Fleet Modernization
Program” which means that you want to subsidize the “New Car
Industry”. This makes the assumption that the average person to
take advantage of this is a low income person. The average low
income person that takes advantage of this program most likely will
not be able to afford to buy a new car but will probably find
another low cost used vehicle. To believe you are helping the new
car industry by this proposal is hypocracy.


With these comments in mind I urge you to scrap the “Scrappage
Regulation” and use the money for something more productive.