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. 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.

I  am  livestock producer in Tuolumne Co. that seasonally move our
cattle to USFS grazing permits. These permits are located where the
roads are very narrow, steep and no longer maintained buy the USFS.
 Trucks to move these cattle is a big problem as there is a limited
amount of trucks that can haul on these roads. Most trucking fleets
in the valley will not and can not haul on these roads because of
length will not haul on the rocky roads.  On the Stanislaus NF
there are several thousand cattle that can only be moved by  cab
over truck and trailer only because of the narrow and windy roads.

This week alone there is a shortage of trucks with early cattle
moving because of the drought.

I've attached photos to narrow roads that typical cattle semi's
can't travel on.

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,
Signature

Bob Brennan
Brennan Ranch
20540 Shangra La
Sonora, ca 95370