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Comment 141 for Truck and Bus Regulation (truckbus14) - 45 Day.

First NameRon
Last NameFaulkner
Email Addressron@faulknertrucking.com
AffiliationFaulkner Trucking Inc
SubjectComments 4/21/14 Amendments
Comment
	Faulkner Trucking is against any modification in the current
regulations for 1 to 3 truck companies.  The original regulations
provided for an extended time frame to allow these companies an
opportunity to comply.  All other company’s accepted the added
financial burden and spent the necessary capital to comply with the
knowledge that the 1 to 3 truck companies were also being compelled
to comply.  The extended time frame has created an unlevel playing
which has squeezed margins for compliant companies.  Noncompliant
companies with a lower cost operation have been able keep lower
freight rates in place for far too long.	
	At Faulkner Trucking we have complied with the regulations since
day 1.  The cost of compliance has been steep.  First we
retrofitted 10 early to get an additional 10 trucks in compliance. 
The cost was $150,000 for the retrofits.  These retrofits reduced
fuel mileage, damaged several motors and required extra
maintenance.  The reduced fuel mileage amounted to $11,000 per
vehicle.  The required extra maintenance caused the trucks
additional time which decreased the annual truck revenue by $10,000
per year.  The 3 damaged motors caused by sub par engineering of
the retrofits Cost $15,000 per motor.  
Secondly the company spent $608,000 for new trucks and $650,000 for
compliant used trucks.  To achieve compliance until 1/1/17 the
company had to be refinanced over 10 years.  The extra refinancing
burden on the company puts Faulkner Trucking “at risk” of closing
doors its “any day” for the next 10 years simply because we
complied with the current regulations.  Faulkner Trucking employs
around 60 people whose life would be disrupted by this type of
event.  Many of our employees are older workers that would find it
impossible to find the same type of job.  
For the ARB to grant extensions would be unfair to the companies
that invested in compliance.  The small operators knew that they
had extended time to comply and are now trying to have the rules
changed for their gain at the expense of the companies who have put
their entire company’s on the line to comply.
	

Attachment
Original File Name
Date and Time Comment Was Submitted 2014-04-18 10:44:15

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