Comment Log Display

Honorable Mary Nichols
Chair, California Air Resource Board
1001 I Street
Sacramento, CA 95814

Dear Chair Nichols,

As a California beef producer I am writing to voice my strong
support for your staff's proposed revisions to the Truck and Bus
Regulation that would classify trucks that exclusively haul cattle
as specialty farm vehicles. The proposed revision will ensure
ranchers have access to enough trucks to move their cattle by
delaying retrofit and replacement requirements for dedicated
livestock haulers until January 1, 2023.

Livestock haulers typically travel far fewer miles annually
compared to other truckers but exceed the mileage threshold for the
agricultural provision currently included in the rule. The movement
of cattle in California is generally seasonal, taking place in the
spring and fall, the miles traveled by livestock haulers typically
occur in rural areas. Unfortunately, California ranchers are
already subject to a shortage of livestock haulers and depend on
both in state and out of state truck fleets to provide enough
trucks to move livestock when it is necessary. It has become clear
that the implementation of this rule has severely limited the
amount of truckers who are willing to continue to operate their
vehicles in California and resulting in a complete disinterest by
most out of state haulers to operate in California any longer.

Our ability to break even at the end of any given fiscal year is
subject to the whim of evolving market conditions, weather and
rising input costs. Ranching is not a job but lifestyle. The
economic returns associated with cattle ranching are small, but
risk is huge. For example, this year has been especially
devastating to beef producers as California enters the third year
of the worst drought in our history. Many ranchers have already
been forced to liquidate their herds due to the lack of feed and
many others are struggling to survive by feeding hay that has
doubled, and some varieties, tripled in price.

Many livestock haulers and ranchers with trucks are also not
eligible for funding under the Carl Moyer Program or Proposition
1B. Many of these vehicles do not travel through the goods movement
corridor as required by Proposition 1B and drive too few miles in
mostly rural air districts and are not competitive for funding
under the cost formula generated for the Carl Moyer Program.

Unfortunately, some truckers have voice their opposition to staff's
proposed livestock provision. While it is very important to provide
future forms of regulatory relief for those who have already spent
the money to install particulate matter filters, this cannot be
done at the expense of the proposed livestock provision. Bottom
line, this provision alleviates the economic suffering that is
currently taking place for many ranchers and is good for the
overall health of California beef cattle industry. It is strongly
supported by both ranchers and livestock haulers throughout the
state/including many who have spent money to retrofit their
trucks.

Please do not delay in supporting this important and critical
provision as proposed by staff at your hearing on April 24, 2014.

It is my personal view on the matter that there have been a lot of
new trucks repossessed since this matter started and time will tell
as to how many of the new livestock trucks will continue to be
owned and a lot of those owner do other things with their trucks
(flatbed, reefers, end dumps, etc.). My personal livestock truck
only is operated only around 30,000 miles a year and only hauls
livestock during the spring and fall. Occasionally a few loads will
be hauled to the livestock yards. 

With such few miles it is economically impossible to buy a new
truck.

Sincerely, 

Albert Andrew Batteate
Flyin' ~A~ Ranches
5600 Collier Canyon Rd.
Livermore, CA 94551