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Dear ARB Board Member: 

We are a California based trucking company operating in and around
the ports and have been in business in California for over 40
years.  Over the past couple of years we have been letting the
California Trucking Association (CTA) represent us with regard to
your Air Quality regulations, but considering the fact that your
organization seems to be traveling down the same costly road
regardless of CTA’s tireless efforts I can only conclude that you
are ignoring them and I need to give you my situation in my own
words.  

We recognize the air quality issues facing all of us.  In fact, we
believe our fleet has done a very good job at running the cleanest
fleet we can, since we have a 5 year trade in cycle that regularly
puts our drivers in trucks with the newest widely available
technology.  We are able to turn our fleet over often because we
keep our trucks in very good condition and can command a high
resale value when that 5 year period is up.   

You many think that with your new regulations we would not be
hurt, since we will be able to “buy our way through”  the time
line.   In other words we will sell our trucks and buy new ones
before they need to be retrofitted.  But who will we sell to, who
will want to buy a truck that needs a $20,000 retrofit in a year
or two.  Therefore we will have to retrofit  before we sell or
sell at a discount.  Either way we will be facing a loss of about
$20,000 per truck.   

I am fairly certain that CARB would love it if all carriers in
California were like us and turned over their fleets every 5
years, but if they were who would we sell our trucks to?   And if
we cannot sell our trucks for premium prices on the used market
then our whole technique of turning over our fleet regularly does
not work.   We can only operate this way because we get enough on
the used market to keep our equipment costs low.   The regulations
that you are proposing will make our resale values sink and
sabotage our turnover program.

So here we are, a carrier that is doing everything it can to
operate new, clean burning equipment, and your pipe dream of a
program puts a kibosh to our system.   Our system really works,
and it has for 20 years or more.  Your proposal is just on paper,
you cannot hope to think that you can forcast all of the possible
problemst it may cause.   

Instead of demanding retrofit for all trucks on the road, why not
demand improvement of all fleets on the road.  If you have a
pre-98 you have to buy up to the 98-2002 level or for 5 years or
to the 03-04 level for 10 years.  When that period is up you would
have to again buy up to the next level in 5 years.   In this way
not only are you improving fleets you are stimulating commerce
instead of messing up the used truck market.

This method would put all California trucks at the 2007 level in
15 years.  Your program does it 9 years sooner but destroys the
trucking economy in the mean time.   And face it, you could be
fighting court battles over your new program for that long.

Sincerely



Anthony T. Teresi
Teresi Trucking, Inc