Comment Log Display

On behalf of the National Federation of Independent Business’
(NFIB) more than 20,000 California members, we respectfully request
that the California Air Resources Board (CARB) Members move to
suspend the Truck and Bus Regulation (“Truck Rule”).  This is the
minimum appropriate course of action given recent news regarding
the failure of Board staff to disclose relevant information, as
well as the continuing California economic recession. 

California maintains a position as a leader in the area of
environmental regulations pertaining to the air we breathe.  To say
that clean air is critical to our economy much less our lives, is
an understatement.  Despite California’s already strict air quality
regulations, the new Truck Rules are an attempt to push even
farther to be on the cutting edge.  Unfortunately, California and
its businesses simply cannot afford that luxury right now.  CARB
must not ignore the economic consequences or the need to maintain
the integrity of the implementation process.  

Dr. John Telles’ recent uncovering of Hien Tran’s falsified
academic credentials and the failure of CARB officials to properly
and necessarily disclose that issue in an appropriate and timely
manner calls into question the integrity of the Truck Rule
development process.  The lack of disclosure to the other Board
members and the public represents a major break of the trust
assumed by CARB officials when promulgating these stringent and
costly regulations.  

CARB should be particularly concerned with maintaining the
public's trust and its own credibility since it is developing these
landmark regulations during tough economic times. As California’s
economy continues to struggle through the worst economic recession
in recent history with an unemployment rate over 12 percent and
nearly one million Californians losing their jobs in just the past
year, we cannot afford for CARB to rush forward with a rule that
carries an estimated cost of more than $4.5 billion.  While some
assistance is proposed for small businesses as a part of the rule,
California’s economic situation has undermined the ability of
businesses to finance hundreds of thousands or millions in mandated
costs.  

If, as CARB maintains, the science is sound and without question,
then it does no harm to set aside the current regulations and start
a new public process free from questions of integrity and with an
improved understanding of the economic impact to California small
businesses.  Both the need to maintain credibility and take into
account the nearly unprecedented economic challenges demand that
the Truck Rule undergo the most critical of reviews.

NFIB respectfully requests that you take immediate action to set
aside the existing Truck Rule and start over.  

Sincerely,

Michael D. Shaw
Legislative Director 
NFIB-California