Comment Log Display

12/13/10 

California Air Resources Board P.O. Box 2815 Sacramento, CA
95812-2815 

RE: Proposed Amendments to the Truck and Bus Rule 


I would like to thank the Staff of CARB for working hard for some
very helpful amendments to the rule, they will greatly help rural
operations and Log Truck Companies achieve compliance. Even with
the proposed amendments this rule will dramatically impact
employment in rural California. There simply is not the money
available for the updates even with the amendments in this rule,
for rural operations to continue with seasonal constraints as they
have for multiple generations. These companies have provided jobs
in rural California for generations and today these same areas are
listed in the top ten cleanest air districts in the Country. 

Even though these districts are ranked high nationally for clean
air, businesses within them will suffer greater impacts and higher
costs to comply when compared with companies operating in San
Joaquin and South Coast air basins. The inequity in this regulation
is due to seasonality of operation and access to public funding. A
majority of the trucks operating in rural California are pre 1994
mechanical engines; no current filter will bring them into
compliance. These trucks are still being utilized because seasonal
operations take decades to exhaust the useful life of a truck, not
to mention the cost to purchase a replacement truck or engine using
a rural business model, State agencies have no concept of the
burden this puts on small business in the current financial
situation. 

There is no public funding for truck/engine replacement in rural
California, Mendocino County has turned down Carl Moyer funding the
last 3 years because they have no matching funds. There are no
other direct funding opportunities in our County as with most of
rural California. Even with the matching funds no more than 3
trucks would be replaced assuming the county did not use the funds
to replace their own engines first. Industry only receives funds
once municipalities have turned it down, and seldom is there any
funding left. Mendocino County with its clean air is still going to
face significant job losses due to their employer’s inability to
replace trucks in compliance with the amended rule. This scenario
will play out in multiple rural counties facing the exact same
problem. 

Replacing a pre 1994 mechanical engine with a post 1994 electric
engine is something that can be done at a reasonable cost or
hopefully no more than the fair market value of the original truck
itself. In NOx compliant rural California the result of taking
mechanical engines out of service and replacing them with
electronic versions would have an astronomical impact on the
reduction of Particulate Matter. Replacing mechanical engines with
electric engines and no further requirements could save jobs in
rural clean air districts while providing significant PM reduction.
Instead the PM reduction will come from business’s closing their
doors and eliminating jobs because of the cost of this rule.
Everyone would like to have a new truck however spending money that
the business does not have makes no sense. Requiring local trucking
firms to run the cleanest diesel technology in the low use areas of
the state that currently have the cleanest air in the nation makes
little sense either. Only Government agencies with no practical
experience of living within their means would come up with an idea
like this and make it law. 

The NOx exempt boundaries leave a lot to be desired, boundaries
should coincide with impaired air districts not county lines. A
perfect example is the Northern Sonoma air quality district where
the air is not impaired, however NE trucks cannot operate there
because of a line on a Map. Southern Sonoma air district is the
impaired district where the air quality problem exists and that is
where the exclusion to NE trucks should take place. If lines are to
be drawn restricting access it should be done by actual air quality
conditions not abstract boundaries set up over 100 years ago for a
different purpose. In order to minimize the impact on jobs in rural
California this rule must be as flexible as possible; otherwise it
is an all out recipe for disaster. 

Sincerely, 

Myles Anderson 
Anderson Logging, Inc.