Comment Log Display

I will be discussing only road construction trucks as that is our
area. First I would like to make a suggestion for a added
regulation. A exemption for trucks that are pre 2007 and are not
retrofitted. Make a ruling that the truck, regardless as to the Air
Quailty District they are based in, are only allowed to work in
that area. For years I watch dump trucks leave my area to go 60+
miles to work because a company has under bid a job in the fore
mentioned area. So you have 2 sets of trucks going to work in each
others districts simply based on the lowest bidder. This is more
then doubling emissions. require that contractors and brokers only
use trucks from their Air District. If you want to work out of your
area then you must comply with these regulations.

Second: Make a grandfather ruling for people with pre 2007 trucks.
Require them to comply with a smoke test at a state approved
facility every year to assure they are complying with their
emissions standards for the year of engine they have BEFORE they
are able to get their registration. This would put hundreds of
Californians to work, they would work at the smog stations, have to
go to classes to get certified which would employ teachers not to
mention all of these expenses would be going to the state of
California and getting hundreds of Californians off of government
aide. Sound familiar? This is the same regulation that applies to
older cars. You never required car owners to replace a 5 year old
car just that they continue to comply with that years regulation
and if they purchase a new car then it must have the latest
technology.

Now on to my questions and comments. 
First, as a broker. How do you expect us to keep up with and
enforce these regulations? With the new proposals, you have
regulation dates on top of regulation dates and "if he did this
then they don't need to do that". Its too much. Every time I
contact CARB I can not get a direct answer to my question. This
clearly tells me that the reps on the other side of the email
accounts don't understand these regulations either. 

Why has northern San Bernardino County been removed from the
proposed NOx area exemption list? This is a area that is largely
open and under inhabited. This is also a area that is subject to
high winds almost weekly. While dust is not the same as particulate
matter it does cause damage to the air. Not to mention all the wind
helps keep the air in the area clear. 

As I stated in the beginning I am concentrating on road
construction dump trucks. The state of California's infrastructure
or roads is in terrible repair in most areas. If you mandate that
LOCAL construction  trucks that travel more then 20000 miles a year
update or retro fit you are going to have 2 problems. Problem 1:
You will create a dump truck shortage which we are already on the
verge of now. This will in turn drive the price of trucking road
base and asphalt through the roof. Not to mention the price of the
materials will go through the roof. To make asphalt you need oil.
Oil comes on a truck. The oil trucks increase their pricing. Then
you need aggregate that is delivered on trucks. the aggregate
trucks raise their prices. All of this adds up to the State of
California paying higher cost to repair roads. This means less
roads can be repaired which leads to a public safety issue. 20000
miles is not enough to keep California's roads in good repair.
Raise the amount of miles for Bottom Dumps, transfers, Strong Arms,
etc. to at least 50000 miles a year. 
Problem 2: Forcing people to purchase new trucks or retro fit
trucks will again require then to raise their cost of
transportation.

While there seems to be some success with the retro fit filters on
trucks that travel on the highway for a extended period of time
there have been multiple problems with trucks that have retro
fitted and work in a small radius as dump trucks do. Working in a
small radius does not allow the engine to build enough heat to keep
the filter clean. This causes multiple problems. One is that the
truck can have a malfunction causing costly repairs and a lower
supply of trucks. Next if a driver realizes that the filter is
getting plugged they have been told by filter installers to get on
the freeway and drive approximately 60 miles in one direction and
back to clean out the filter. That a extra 120 miles per week that
trucks are having to drive that is putting pm into the air not to
mention wasting fuel. Keep in mind that this is on retro fitted
trucks.