Comment Log Display

To Whom It May Concern:

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.

There is no disagreement that we all 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
moving and storage business. 

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression.  Moving companies
like ours 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 us to spend dollars that we don’t have, in
a market where there is virtually no access to capital for
business, large or small.

CARB is asking that we 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 and we
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 and
reduce our operations that would cost jobs and revenue to the
state’s economy.

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.


Sincerely,



Joseph Hammer
President