Comment Log Display

Auto transport trucks with head racks installed above the cabs must
operate as a matched set of tractor & trailer. Due to height
limitations, and the envelope available for engines and DPF
retrofits, it is impractical and costly to bring such trucks into
compliance with CARB regulations.  

The cost of a new matched tractor/trailer unit exceeds $250,000.
Since autos are carried on both the tractor and trailer, auto
transporters are unable to hand trailers off to compliant trucks at
the California border, as is the practice of many general freight
haulers today. Replacing or leasing a tractor isn't viable either
because of $20,000 cost of refitting a headrack from one tractor to
a newer one with a 2010 engine.

Our Arizona-based fleet is comprised of all Caterpillar engines
from 2004-2006 with miles ranging from 700,000 to 1,000,000.  Even
if we were able to raise the funds to cover an $18,000 retrofit,
none of our regular certified Caterpillar truck engine shops here
in Arizona are certified by CARB, nor willing to install a
retrofit, and in fact, have warned us of the consequences to
reliability of doing so.

Please add a waiver to the CARB Truck & Bus regulations for
specialty equipment.