Comment Log Display

The Honorable Mary Nichols
Chair, California Air Resources 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 provisions 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 provisions currently included in the rule.   For
example, mileage limitations by CARB going retroactive for 3 years
has knocked many of us out of compliance for what would have
otherwise seen us through 2023.  Rural areas for us means Ranches
or mountain allotments that are on rough, steep, dirt roads often
going over river crossings.  Newer large semis cannot make the
turns required to reach these remote spots.  We have invested
extensive time and money modifying our existing trucks and trailers
so that they are able to manipulate the turns and have appropriate
ground clearance to get in and out of areas where new off the line
factory built haulers cannot even dream of going.  This again
emphasizes the “specialty” of livestock hauling vehicles.  We are
hauling livestock, which is a lot different from tomatoes. We need
to get deep into remote ranch sites and remote mountain allotment
sites in all kinds of weather at all times of the year.  Muddy,
steep dirt roads, washed out roads, and snow-covered roads are
obstacles that we face to get the cattle out of their summer
ranges.  We Indeed are a specialty unit that cannot be linked to
hauling on the highway routes or linked to hauling produce.  These
are live animals with specified time limits to either forest
service allotments grazing, or time limited sale weights.  Often
the time limits are in place to meet environmental regulations.  We
have a significant investment in these specialized trucks that we
cannot possible replace in this short notice.  There are no
manufacturers who sell trucks designed for the off road experience
that we face on a daily basis.  A loss of our specialized cattle
hauler for these mountain roads would be devastating.  The movement
of cattle in California is generally seasonal, taking place in the
spring and fall, and 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 resulted 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 a lifestyle. The
economic returns associated with cattle ranching are small, but the
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 for 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 voiced their opposition to
staff’s proposed livestock provision. While it is very important to
provide further 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 helps alleviate the economic suffering
that is currently taking place for many ranchers and is good for
the overall health of California’s 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.

Sincerely,

Gayle and Willie Ritts
Ritts Ranch
15105 Wards Ferry Rd.
Sonora, CA 95370
209.982.4949