| Comment | I urge the ARB to consider the current economic climate and adopt
the Driving Toward a Cleaner California (DTCC) coalition’s
alternative proposal. DTCC’s proposal is a balanced solution. It
will keep truck and bus companies afloat in this fragile economy,
avoid further layoffs and keep goods and services moving in
California. The alternative proposal would give companies the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions. In fact, ARB’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. Under ARB’s current proposal, every diesel truck and
bus operating in California would have to be replaced or
retrofitted starting in 2010 at a cost of at least $5.5 billion –
at a time when there is little to no access to capital for
financing engine retrofits or replacements. Please consider the
DTCC proposal carefully and seriously.
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