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Comment 78 for Truck and Bus Regulation (truckbus14) - 45 Day.

First NameJim
Last NameEhoff
Email Addressjim.ehoff@yahoo.com
Affiliation
SubjectThe Amendment regarding the scraping of retired trucks
Comment
The Amendment regarding the scraping of retired trucks


I would like for the Board to consider an amendment regarding
scraping of retired trucks.

As it stands now a company must turn in its retired truck to an
approved recycler in order to qualify and receive incentive funding
for a new replacement truck. 

The approved recycler must then cut the frame in half behind the
cab and cut a hole in the engine block.  This is to assure that the
engine can never be reused again.  

My problem with this is that there are still hundreds of usable
parts left on the now inoperable truck.  These parts do not
pollute. However, they can and will help to reduce pollution.  Now
you’re wondering how this could be possible.  How can a simple
switch, gauge, mirror or any one of the hundreds of other parts
possibly reduce pollution?  The answer is simply to leave the
inoperable retired truck with the owner if he elects to keep it. 
The frame is still cut, the engine is still destroyed just leave
the truck with the company.

Pollution would be reduced in several ways:

1.	The Dismantler doesn’t have to send out a tow truck or lowbed
(both of which pollute) to pick up the retired truck.  Fewer
pollutants in the air. WIN!
2.	The company now can get good parts off of these inoperable
retired trucks.  This will reduce the need for a delivery truck to
bring a new part out for the company.  Fewer pollutants in the air.
 WIN!
3.	If the parts supplier doesn’t deliver the new part it will in
turn reduce the need of a larger delivery truck from the parts
warehouse to replenish the parts suppliers’ inventory.  Fewer
pollutants in the air.  WIN!
4.	The warehouse now will reduce orders from parts manufacturers
that deliver to them.  Fewer pollutants in the air.  WIN!



5.	The company already has and owns the inoperable trucks.  All the
parts are readily, available and free for the taking.  This cuts
costs and now the company can invest more money in less time to
purchase new clean air trucks.  Instead of new parts for older
trucks.  This simple step will have a huge impact and with zero
cost and zero effort. This step alone puts NO pollutants in the air
and with new clean trucks keeps future pollutants to near zero. 
That’s a double WIN!


The last but by no means the least important impact will be that it
shows trucking companies the California Air Resources Board is
willing to implement real world solutions to this real world
problem. This in turn will help to change the perception of the
Board from one of being the biggest bully on the block, to one of a
team member interested and willing to work together and solve a
problem that affects us all.

Attachment www.arb.ca.gov/lists/com-attach/82-truckbus14-BnRdPlEkACEAaQZg.docx
Original File NameRetrofit Letter 04-03-14.docx
Date and Time Comment Was Submitted 2014-04-04 14:01:19

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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