Comment Log Display

Dear ARB Representatives,

It is my position as CEO of Starlite Trucking that any further
amendments to the Truck and Bus rules would be negligent and
punitive towards those that have already complied.  

We alone have invested hundreds of thousands of dollars to gain
compliance while we watch our competition wait for further
amendment and undercut market rates significantly.  Further
extension of the regulations for small operators creates the
opportunity for them to gain competitive advantage in the local
market, and it undermines the credibility of the Air Resource
Board.  

We are also seeing the creation of "umbrella" carriers, where a 3
tractor operator is working with a group of 3 tractor
sub-haulers....though illegal, ARB has now way to enforce this as
they all run separate books and have no direct physical
interaction.   What this does is allows a small operator to operate
as a large fleet at significantly lower rates.

I understand the financial predicament this puts some carriers in,
but this has been a known escalation for many years with many
opportunities for public funds.   Extending these regulations at
this point would be catastrophic to the compliant carriers within
the state.

I further wish to state I support the California Truckers
Association comment issued by Eric Sauer earlier this month.

I look forward to seeing you at the hearing.

Regards,
Colby Bell