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Two ARB Board members have asked that the Truck Rule be set aside
due to ethical and legal implications surrounding the development
of that report/regulation and the qualifications of a key
individual who authored the report. 

This regulation will put many small and medium-sized businesses
out of operation due to its expense. Businesses like ours have
spent over 1 million in compliance actions in the past year
compiling with requirements like Enhanced Vapor Recovery. The
additional layering of compliance of On-Road Regulation, Large
Spark Ignition, AB32 and our Customer’s loss of business and income
form compliance of Off Road and stationery engine requirements
leave our future bleak. 

Additionally significant problems and issues regarding the
so-called $2 billion assistance package have arisen, further
heightening the probability that small firms like mine, especially,
may have not any option but to cease operations. 

All of this has occurred at a time when Director Nichols has
penalized/fined businesses in California over 65 million dollars
since 2007. The regulatory climate is overwhelming and for even the
simplest of businesses requires professionals to determine
compliance. ARB’s outreach to inform business of regulatory
compliance is a failure.

Delay of the regulation will not adversely affect air quality, the
economic downturn has already significantly reduced diesel
emissions through reduced trucking and construction in the state.
This was verified by CARB staff recently at a public workshop
where, with no action, the state will meet 2011 SIP commitments for
NOX and PM2.5. 

The Board must address the real cost of this regulation. There has
been no revision or study on the economic consequences of this
regulation or the effect of LAYERING from all the other regulations
gone wild. This is needed in light of our current economic
condition and any hope of recovery for jobs and business. 

Thank You for your Consideration
Ed Ward
JB Dewar Technical Services
PO Box 3059
San Luis Obispo, CA 93403
805 540-7106