Comment Log Display

To Board and Staff,

I feel allowing the trucks that installed filters early, the
ability to operate for more time is good. The problem is it does
not address the 2007-2009 technology trucks. There are many of
those out on the road currently. Many companies purchased those
trucks to get into compliance. That was during the time which the
Truck and Bus rule was approved. Those trucks have a useful life of
a minimum 20 years. There is nothing wrong with those trucks. They
have a factory filter installed and operate relatively well. Not to
say they are trouble free, but they are filtered and cleaning up
the air. Currently those trucks sunset in 2023, which is only 15
yrs.  Not long enough in a Heavy duty trucks life. If you were to
allow those trucks to operate until 2029, those units could go to
the operators that are unable to purchase new trucks. This would go
a long way toward helping the one owner /operators get into
compliance. Maybe better than modifying the rule as proposed. 

I see nothing in these modifications that deal any further with
enforcement. I, as many I align with, feel that enforcement is
critical and lacking. On any day, I can drive down the freeway and
notice multiple non filtered trucks.  I feel we are lacking in a
mechanism to help enforcement. I have been told that involving the
DMV is unattainable. I find this hard to believe. I have to provide
my 2290 (heavy use tax) that is paid to the federal government in
order to license my trucks. On that form are the vehicle ID numbers
of each one of my trucks. There is a form that we fill out when
registering our trucks in the truck and bus rule each year.  That
form recognizes our trucks by their vehicle ID numbers also. Would
it be that difficult to match up the numbers on the 2290 and the
print out from the registration into the Truck and Bus rule? The
lack of enforcement is negligent and counterproductive to the
overall program. 

If we go through all of this time and effort to make changes to
this rule and have no enforcement, what good is any of this?

Chris Torres,
President,
F & L Farms Trucking Inc.