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Comment 93 for Truck and Bus Regulation (truckbus14) - 45 Day.

First NameDebbie
Last NameFerrari
Email Addressdferrari@magtrucking.com
Affiliation
SubjectPROPOSED NEW CARB RULES
Comment
If Air Resources board was uncertain and this is a work in progress
they should not have imposed a law and told brokers specifically
and directly that we would be responsible for compliance or to face
stiff penalties. It’s too late to take that back.
      Responsible brokers have worked very hard to get small truck
owners to comply with the law based on the information given. These
small fleet or single truck owners have put out every effort,
leveraging their future based on demands by ARB that it was a
requirement, to meet the prior schedule.
     Brokers such as our firm were given the task to spread the
word on behalf of ARB and require compliance, or else we would face
stiff penalties. We were told this not just once or twice but many,
many times over a long period. When single truck owners would say
“I heard there will be an extension” We checked with ARB.  ARB
assured us that this would not be the case. The proposed new
changes look so watered down that I don’t see how compliance is
even possible.
     Based on improvements made, these small fleets and single
truck owners expected that pricing would increase so that they can
pay for the loans that they have received from various entities.
With the proposed extensions and watering down of the law,
especially the one where all you have to do is prove that you
cannot get a loan, these people are now going to face financial
hardship. They will now be getting penalized for trying to comply
with the law. No more will the projected escalation of pricing be
viable since any truck will do after all. What do we as brokers,
the enforcers, as appointed by ARB say to those that have given up
everything just to get that new truck and filter, while they look
at other truckers who didn’t bother to make an attempt and now will
be rewarded. 
    Please re read paragraph 1.
And on a separate note, the proposed changes give a further
extension for those that have a filter on by January of 2014.
However the law clearly stated that, as long as the filter was
ordered in 2013 it did not have to be installed as of that date.
This proposed extension for those that have gone through the
expense to get these filters needs to be amended to allow for the
proven order date rather than installation date. Once again, to
avoid penalizing those that have followed the rules.

 

                                                Debbie Ferrari
                                               
Estimator/Supervisor

Attachment
Original File Name
Date and Time Comment Was Submitted 2014-04-08 13:17:59

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