Comment Log Display

November 20, 2007


Dear ARB Board Member: 

Thank you for taking the time to read this letter.  I am President
of a California trucking company and affiliated with family owned
companies operating in and around the ports that have been in
business in California for 72 years. Tiger Lines is part of the
California Trucking Association (CTA), which represents over 2,300
member companies who operate in and out of California, and who’s
Southern and Northern Intermodal Conferences make up the largest
block of intermodal carriers nationwide. 

As a business operating in California we recognize the air quality
issues facing all of us. Many of our employees live and work in and
around the port complexes and are currently working to assist in
finding sustainable solutions that not only improve air quality
but also help sustain a growing goods movement industry. 

My concern is with the recently released regulatory proposal aimed
at controlling emissions for in-use on-road heavy duty drayage
trucks within California Ports. Currently the proposed regulations
require all drayage trucks to be equipped with a 1994-2003 model
year engine certified to California or federal emissions standards
and a level 3 VDECS for PM or 2004 or newer model year engines
certified to California and federal standards by December 31,
2009. Phase 2 creates even more burdensome provisions requiring
trucks to meet or exceed 2007 model year engine standards by
December 31, 2013. 

Our concerns are that some of what the CARB staff is proposing
will have devastating effects on the current and future economy. 
We, the CTA have looked for and can not find a comprehensive or
even cursory economic impact study.  Issues such as new engine
costs, rate increases needed to cover the cost of the technology
and the lack of competitive pricing of the VDECS, will all
adversely impact the California GDP.

An additional issue includes residual values of new vehicles at
disposal time.  As new or currently operated vehicles age, there
will be no resale value as they will not be legal to run in
California.  No resale value will be a problem for the banks
funding the leases on the new vehicles.  They must amortize the
entire vehicle in an extremely short period of time driving the
price of the lease payments up. 
  
Another concern would be in the verification of compliance.  The
CARB does not have enough inspectors to police compliance.  Even
if they did, they are only prepared to police for installation of
VDECS.  There does not appear to be a budget set for actually
testing the emissions.  As a result two events are possible and
highly probable.  First, the device could malfunction and as long
as it is on the truck no one would know it is allowing harmful
emissions.  Second, without emissions testing as a verification
method, counterfeiting will spring up.  

We are committed to working to find attainable and sustainable
solutions to emissions reductions; we just ask you take into
consideration the potential effects on the overall industry.  If
this new version could be delayed and rolled into the private
fleet rule proposed for October 2008 we would offer our assistance
in achieving a proposal that works for industry as well as
government. 

In earnest, we are not looking to thwart the efforts of the staff
assigned to creating the rules and you who are tasked with
achieving a cleaner California.  We simply would like to ensure
the economy which is ever so fragile currently will not be set on
a coarse it can’t recover from.

The current housing and sub prime loan debacle combined with
record high fuel prices have California in an extremely precarious
position.  Is it possible we can join forces to find a cleaner path
that will support California’s prosperity as well as cleaner air? 
We hope so and would welcome a chance to participate in that
common goal. 

Sincerely, 



Dennis Altnow
President
Tiger Lines
PO Box 1120
Lodi, CA 95241