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Comment 74 for Truck and Bus Regulation (truckbus14) - 45 Day.

First NameJim
Last NameEhoff
Email Addressjim.ehoff@yahoo.com
AffiliationTriple E Trucking
SubjectProposed Regulation of Cleaire Longmile
Comment
The Cleaire Longmile Proposed Regulation

In the mad rush to get clean air products on the market and in use,
proper testing in this case was seriously over looked and
underdone.  It seems the first few to comply were the unknowing
test subjects elected to discover which products worked and which
products did not.

In many cases the unknowing and assuredly unwilling participants
paid for this privilege with their own money. I am one of those,
one who did not receive any grants or incentive money of any kind. 
We did the retro fitting early and at great expense in 2011.  Soon
after, the Cleaire Longmile was discovered to be a catastrophic
failure and was recalled.  Cleaire ceased operations, January 18,
2013, and since has gone bankrupt leaving us and many other holding
the (empty) bag. 

Now I have discovered that the proposed regulation for the Cleaire
test subjects is to reduce the compliance date to (5) years from
the recall date.  This date would fall in 2017. THIS IS COMPLETELY
UNEXCEPTABLE!

To put this in proper perspective consider this:

1.	We did our retrofitting very early.
2.	We paid out of pocket, no grants.
3.	A portion of my tax dollars helped pay for other’s retrofits.
Those that received grants or other incentive monies. 
4.	Now you propose to graciously give us (5) years from the recall
date or, as you drive the last few feet of the dagger in our backs,
we get the privilege to pay again.

While on the other hand:

1.	Other companies got later compliance dates and did nothing to
comply.
2.	Then were given another year extension to comply and many still
did nothing.
3.	When and if, they did comply, were given the benefit of more
proven products. We who retro fitted early, had paid to test and
eliminate inferior designed PM Filters.
4.	Some, with the help of my tax dollars, received grants and
incentive money to pay for their retro fits. 
5.	As it is written in one of your proposed regulations.
(Additional time and a lower cost route for ALL SMALL FLEET OWNERS
to meet their PM compliance requirements, while reopening
opportunities for THESE FLEETOWNERS to apply for and receive Public
Incentive Funding. 
6.	Last but not least, to allow the few that did get their trucks
retro fitted, (many of whom received grants,) before 2014 to be
compliant until 2023.


It seems to me there is always enough money to pay for PM Retro
fits for those who have done nothing. 

It also seems that there is plenty of time to give extensions to
those fleets to comply.  Apparently, these trucks do not pollute,
it is only the ones that had the Cleaire Longmile that do.

This is what the Board should approve in regards to the Longmile
Fraud:

All Longmiles that were paid for with no grants or incentives
should be replaced free of charge.  If the Board can’t find funding
for this then see the enough money statement above and you will
find it.  

If funding is not made available they should be afforded the same
time and compliance that other retro fitted trucks are given. If
retrofitted before 2014 they are compliant until 2023. 

Mistakes were made and a wrong has happened.  The Board has the
power to make these things right. You as members of the Board have
been given virtually unlimited power in the decision making process
concerning air quality.  In a very popular movie a single statement
rings truer now than ever before. 

With great power comes great responsibility. It is your ethical
responsibility to right this wrong and as members of the California
Air Resources Board, it is your duty, your obligation to preserve
the integrity of the office by doing what is right.  Do not close
your eyes and turn your backs to those of us who tried and are
still trying.  The State and the Country is watching.  In previous
proposals a phrase (GOOD FAITH EFFORT) was used.  What better Good
Faith Effort is there than actually doing it as we have done?  

So now show all of us your Good Faith Effort and make things right
or simply stamp your approval on this proposal and lose any
integrity you may have also eliminating all faith any of us have in
the Air Resources Board all together.  

Attachment www.arb.ca.gov/lists/com-attach/78-truckbus14-AXMAYwdyVncCawZg.docx
Original File NameRetrofit Letter 04-02-14.docx
Date and Time Comment Was Submitted 2014-04-03 11:32:48

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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