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Comment 173 for Truck and Bus Regulation (truckbus14) - 45 Day.

First NameDouglas
Last NameMyovich
Email Addressmyovich@hotmail.com
Affiliation
SubjectProposed amendments to the Truck & Bus Rule
Comment
Our company has been compliant with CARB.  In order to be compliant
we have replaced 91% of our 45 truck fleet over the last 4-years. 
We along with every other trucking company in this state knew we
had to have a plan to reach compliance.  We in good faith believed
we would be able to compete in the market place as long as everyone
in the industry had to become compliant at the same time. We never
qualified for Prop. 1B money in this process.  Every purchase
transaction between Trade-In value and purchase price of a new
vehicle cost us an additional $25.000.00 per transaction. This is
an additional cost that can only be recovered through rate
increases. The reality is that a rate increase is not based on a
unilateral decision on our part. We can only increase rates as the
market will bear and giving others an extension will only put
further pressure to hold rates down.  This will ultimately have the
effect of putting compliant companies out of business and enabling
those who did not comply a free pass into our share of the market
when rates are able to increase.  Please do not allow those who are
not compliant be allowed to have any extension through any further
delays.  That puts every compliant company at risk. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2014-04-20 10:28:12

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