Comment Log Display

Dear Board,

One of the parts of the existing Rule is that truck Brokers in
California must insure that Subhaulers working through their
Company are in compliance with the CARB rules and requirements, or
face paying the fines for said truckers if they are caught.

As a result, there are several Brokers doing their best to make
sure they have documentation to protect themselves from being fined
due to the NON Compliance of their Subhaulers.

If you implement the new proposed changes to the rule, WHAT BROKER
WILL BE ABLE TO DETERMINE IF A TRUCKER IS COMPLIANT OR NOT, AND WHY
SHOULD WE HAVE TO BE THE ONES FIGURING IT OUT?

Please put Compliance and Fines squarely on the shoulders of the
INDIVIDUAL TRUCKER OR TRUCKING COMPANY, and take it off of the
Broker's list of "stuff" we have to track. Think about it; you have
created a system that FORCES the Brokers to be BIG BROTHER for you.
Not good.

The easiest way for force compliance tracking for CARB is to
require a Certificate of Compliance to be shown each time one
registers a truck at DMV, just like showing the Form 2290 to prove
taxes have been paid. This was suggested years ago... please take
the compliance enforcement AWAY from the Brokers! We already have
enough regulations to keep us busy, and this one is too much.

Thank you,

Shellie A. Archer
President
Archer Trucking, Inc.
707-485-4500