Comment Log Display

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. 

My company supports improving the state’s air quality.  However,
the Board’s proposed regulation places a significant economic risk
on our business today, which is already under stress from the
recent financial crisis. 

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression, and small
businesses are struggling to make ends meet. Companies like mine
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. My company and others
like us simply don’t have the resources or access to capital to
retrofit our engines.  Some of us may be forced to sell off our
trucks at a loss or shutter our companies’ doors, ultimately
costing jobs and revenue to the state’s economy. 

Given the multi-billion dollar cost of this regulation and the
current volatile economic environment, please support the
alternative proposal proposed by the Driving Toward a Cleaner
California Coalition that would give companies like mine 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 the DTCC alternative
confirms that the DTCC alternative proposal achieves roughly
similar emissions benefits to the proposed regulation in the
long-term.

Our problem is further compounded by California DOT regulations
relating to vehicle length on certain roads.  These regulations
have forced us to purchase custom, short cabover tractors to meet
the length requirement.  Freightliner was the last company to offer
a cabover tractor.  Shortly after we purchased our current ones,
Freightliner discontinued the product.  Your proposed regulations
would effectively require us to buy new tractors but the DOT rules
would limit us to buying a model that does not exist.  

Thank you for your consideration.

Robert Shirey
Plant Manager
American Welding and Tank LLC