Comment Log Display

December 8, 2008

Governor Arnold Schwarzenegger
Members, California Legislature 
California Air Resources Board

Dear Governor Schwarzenegger and
Members of the California State Legislature and CARB:

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. 

I want to be clear: Burns and Sons Trucking is 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 our future viability in the
construction trucking 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 and construction companies are struggling to make ends
meet in the face of a massive slowdown in the construction sector
due to falling home prices and home foreclosures, declining
consumer confidence and spending and a freeze in the credit
markets.  Today there is virtually no access to capital for
businesses, large or small.

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. California cannot afford any decrease in revenue
from out taxes or increased costs of unemployed drivers and staff.

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, many of these businesses are family owned
concerns and have limited funds available for this purpose under
the time constraints being proposed by the regulations. This is
possibly the absolute worst time in our history to add expensive
regulations to the already overburdened California construction
industry. 

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. We look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.

Sincerely, 

Tom McFarlane
General Manager
Burns and Sons Trucking, Inc.