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The proposed diesel retrofit rules have never been analyzed for the
direct negative economic impact they will have on working class
families here in California. Studies to date have only been cursory
estimates of dollars needed to pay for the equipment based upon DMV
registration numbers. The fact that the credit market is none
existant, Prop 1B money is none existent, and that the industries
regulated have been heavily impacted by the current depression,
have been completely ignored.

The only option available to many medium and small fleet owners (
mostly family businesses), is to sell off equipment into a heavily
depressed market and layoff the workers associated with this
equipment. This loss of jobs heavily impacts the economic status of
working class families. These are the same folks that can least
afford to lose their primary income source. The negative health
impacts of job loss, especially among the working class, are well
documented, and are far greater than the impact of PM2.5.

At the last ARB meeting on this subject in Diamond Bar, the Board
asked that such an analysis be done, but at the workshop last week,
there was little effort to collect data from the industries
affected by the proposed rules.

It is imperative that any intervention in Public Health be
analyzed for possible negative consequences prior to its
implementation, these rules are no exception.

John Reed MD

Encinitas, CA

760.815.9768