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Dear ARB team/board-members,

I am writing these comments to shed light on my specific situation
(as a small fleet) and for other small carriers in the same
position. I hope you will read and hear the following with an open
mind to do what’s right for those genuinely trying in this
ever-more challenging industry, but need assistance and time. 

My comment(s) are intended for the “Economic Hardship Extension”
section for small fleets that are unable to receive the necessary
funding to comply. 

As a small fleet, I applied for funding from the two financial
institutions (US Bank & Chase) with whom I had a prior relationship
with hoping I would be approved for lending. However, I was
rejected by both parties. As a result, I attempted to seek
assistance by way of the “Economic Hardship Extension”, but there
too I was rejected.  I believe the “Economic Hardship Extension” is
intended to relieve smaller, financially incapable fleets from
compliance for the short term; however, does not dismiss the
expectations from these same carriers to become compliant, but yet
allows for a more methodical, planned out, financially lenient
manner the carrier can take advantage of rather than be set up for
failure. 
So with that in mind, if you ask why I was rejected by the ARB
team, simply due to the fact that I didn’t have my 2 trucks
register as of January 1st 2012. But forgive me, for I didn’t have
anything registered at that point in time because I started
business later on in the year (2012). With that said, as a small
fleet owner trying to steady his operation, I am asking the board
to please add an amendment that will allow me (and other carriers
like me) to continue operating (rather than cease) but with the
mutual understanding that a plan should be put in place to comply
by January 1st, 2017. (Fundamentally, small fleets that have been
in business for a longer period of time than I, one can argue
should be more mature and financial capable to absorb these costs
of bringing their fleet into compliance; however they have been
given the extension opportunity and I’d like to be given the same
chance.) 
(Note I have already invested in bringing both trailers and their
TRUs into compliance, but need further time to be at a financial
position to absorb the remaining costs of bringing both trucks into
compliance. And as you know, the regulatory and compliance
initiatives and their corresponding costs do not just end there…) 

Please help small fleets stand a chance to do what’s right within
their means.

Thank you for your time and understanding,
A.V.E. 


Note: Version of my comments in Microsoft Word document attached.