Comment Log Display

To Members of California Air Recourses board.

I disagree with parts of your modifications to the Truck and Bus
rule.
The allowing of individuals/companies that cannot qualify for loans
for new trucks or filters is unfair to those whose who took the
initiative to comply with the rule. These individuals are the ones
that keep pricing down for the balance of industry. They do that by
not having the initial investment into the industry. They run
without payments and owner operators do not pay workers
comprehensive insurance. They run substandard equipment that is
unsafe for the highway. I believe that these operators are
approximately 20-25% of the industry.

Why should these operators get a pass when the majority of the
industry, (75%) has spent hard earned money on updated equipment?

This is unacceptable! These people are protesting when they should
have been involved years ago! They knew this was coming, they
should have planned ahead. Do you really think they will save money
for a truck purchase? I doubt it, they live paycheck to paycheck.
Their inability to plan for the future should not affect those who
have. 
 
It is too late to do this type of change to the rule. This has been
a large mistake from the beginning. This will make it worse.
Enforcement is where the focus should be. How will you enforce
this? I can make my company not qualify for a loan if I want. So
can anyone else.

If modifications to the timeline are changed, owners who purchased
trucks/filtered units, should be able to operate them for a longer
period. The 2023 end date for 07-09’ engine model year trucks
should be extended. These trucks last for at least 20 years those
units should be able to have a useful life of that time period. Why
should those who put filters on get more time and people who
purchased the first generation filtered trucks be not be given more
time. Many operators have purchased those units or will be able to
purchase those to come into compliance. Why make the market for
purchasing compliant trucks smaller?

Here is everything in a nutshell. If you haven’t complied or on a
path to compliance, you will never comply.


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