Comment Log Display

Richard Corey
Executive Director California Air Resource Board

Re: On-Road Diesel Rule Amendments

Dear Mr. Corey,

These amendments being considered are a very good starting point.
Much more needs to be done for the rural counties that have the
cleanest air in the nation but lack the wherewithal to pay the bill
associated with these rules.

In a previous hearing, Chair Mary Nichols stated in regard to rural
California’s issues with the diesel rule package “it’s nothing that
money can’t solve”.  Unfortunately that was the case back then and
is still the situation faced by rural fleets. The following are the
issues:

•	Short operating seasons result in an inability to service loans
necessary to purchase new trucks.
•	Banks rightfully will not loan the money as there is no way for
the truckers to make their payments.
•	There is a demand for all the same trucks in rural California as
there is in the urban areas; but there is no opportunity to work
them enough to afford to replace low use trucks with new.
•	A minimum of 50% of the heavy duty trucks in rural California are
mechanically fuel injected trucks (the dirtiest of the bunch) as a
result of this rule these trucks that were worth $20,000 - $30,000
are now worth $5,000 to $10,000.  There are no PM filters available
that will work on this group of trucks in rural California!
•	All the Prop 1B money went to the transportation corridor trucks,
virtually none to rural California. The transportation corridor
trucks operate 150,000 miles a year and update their trucks every
5-7 years, this rule has no impact on them; in-fact it created a
windfall.  Rural California trucks operate 20,000 to 60,000 miles
per year their business models require them to keep a truck 15-20
years. They did not receive any 1B money and are being put out of
business by this rule!

The amendments are a good starting point, in order that this Diesel
Rule does not completely destroy trucking jobs in rural California
more needs to be done. A new heavy duty trucks costs about
$150,000, bottom line rural businesses cannot afford this, so back
to Chair Mary Nichols comment “it’s nothing that money can’t
solve”.   The following are some possible considerations.

•	This is a rule all Californians benefit from, all Californians
should subsidize these businesses rather than destroy them.
Vouchers in the range of $60,000 to $100,000 are a reasonable
consideration. The money generated by the purchase of Carbon
Credits should fund these vouchers!
•	There is a tremendous PM reduction when updating from a
mechanically fuel injected engine to an electronically fuel
injected engine. Consideration should be given to allowing NOx
exempt counties to upgrade to this technology rather than going all
the way to PM filters and 2010 engines. These trucks are readily
available and relatively affordable and could minimize job loses in
rural California.
•	Consideration needs to be given to allow very low use specialty
vehicles (10,000 miles and less) in the NOx exempt counties to
operate beyond 2023.

If not further amended, the cost of compliance with the Diesel Rule
in rural California will be paid by the local communities in lost
jobs, tremendously inflated prices and the destruction of our
fragile rural economy.

Mike Anderson 
Fort Bragg