Comment Log Display

I am writing to voice my displeasure with the proposed amendments
to the Truck & Bus Regulations.  

Reliable Trucking has suffered with the business downturn like many
other trucking companies across the State of California.  Our
business has been saddled with low or non-existent margins brought
on to some degree by trucking companies that have failed to invest
in the proper equipment but rely on low prices to generate work. 
This lack of profitability in the business has caused the upper
management to question why we continue to operate this business as
the current economics do not justify continued investment in the
business.

When CARB announced the regulations to reduce emissions, Reliable
Trucking and its parent company made many decisions to proactively
comply.  Older equipment was retired, diesel particulate filters
were installed, and new trucks were purchased.  Our fleet was
registered with CARB using one of the phase-in methods and we are
proud to announce that we are well ahead of the compliance timeline
allowed under the rule.  The cost of this is in the millions of
dollars with no economic benefit.  Reliable made this investment
not based on current economic conditions but on the belief that
CARB regulations would cause some trucking companies that run poor
operations to either invest significantly in their equipment or
leave the business.  

Now CARB is contemplating to allow trucking companies additional
time to comply.  Many of the companies given this extra time have
made no effort to come in compliance.  Furthermore, the low mileage
exemptions will be difficult to enforce.  I would venture that some
of the more unscrupulous trucking companies will attempt to
manipulate this loophole to claim they are in compliance when in
fact they are not.

In closing, Reliable has made significant investment in equipment
at a time when it could least afford to do so.  Now these changes
proposed make that investment appear foolhardy.  Our maintenance
costs have skyrocketed as the DPF filters have proven to be
troublesome from the day they were installed.  How is CARB planning
to compensate all the trucking companies that played by the rules
and now appear to be penalized for doing so?