Comment Log Display

The Honorable Governor Arnold Schwarzeneggar
State Capitol Building
Sacramento, CA 95814

Dear Governor Schwarzeneggar:

The California Air Resources Board (CARB) is currently considering
the adoption of an on-road diesel truck and bus regulation that, if
implemented as presently drafted would have a profound, negative
impact on California’s economy.

As a company with agency representation in California we are very
supportive of reducing particulate matter (PM) and NOx emissions
from diesel engines.  There is no disagreement that we need to work
collectively to improve the state’s air quality and all of us want
to provide as healthy an environment as possible for our families,
our employees and all Californians.  However, in its current form,
the Board’s proposed regulation places a significant economic risk
on our business today, jeopardizes many of our members future
viability in the moving and storage industry, which is already
reeling from unprecedented financial turmoil.

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression.  California
truckers, particularly moving companies, are struggling to make
ends meet in the face of a massive slow down in the residential
real estate market.  The proposed legislation will require small
businesses to spend dollars that they don’t have, in a market where
there is virtually no access to capital for business, large or
small.

Our company and the small businesses in California that represent
us are being asked to dispose of equipment and assets before their
useful life has been completed and purchase new equipment before it
would otherwise be acquired.  A combination of this proposed rule
and the state of the economy have left the trade-in or resale value
of our equipment worth pennies on the dollar.  Many of us simply
don’t have the resources or access to capital to retrofit our
engines.  We may be forced to sell off our trucks at a loss or shut
their companies’ doors, ultimately costing jobs and revenue to the
state’s economy.

Many of California’s trucking companies have already begun the
process of retrofitting or replacing their fleets, whether in the
normal course of their business cycle or in anticipation of these
regulations.  However, the smaller owner/operators – those with
fleets of five trucks or less – who make up more than 55 percent of
all trucks registered in the state, will be severely hampered by
the costs of retrofitting or replacing trucks that, in some cases,
are the sole assets of their family-owned businesses.

Given the multi-billion dollar cost of this regulation – and the
current volatile economic environment – I urge you to support the
alternative proposal proposed by the Driving Toward a Cleaner
California (DTCC) Coalition that would give companies the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions.

In fact, CARB’s own analysis of our DTCC alternative confirms that
the DTCC alternative proposal achieves roughly similar emissions
benefits to the proposed regulation in the long-term.

We must be careful not to forfeit California’s economy and ability
to move goods across the state, build construction projects and bus
our children to and from school for the sake of protecting our
environment.  I look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.

Sincerely,




Joseph A Biskner
President
Stevens Worldwide Van Lines
www.stevensworldwide.com