Comment Log Display

I am a local Sales Trucking co. operating in and around the ports
and have been in business in Ca. for 15 years.  I am a part of the
California Trucking Assoc. which represents over 2,300 member
companies who operate in and out of CA.  As a business operating
in CA we recognize the air quality issues facing all of us. I have
concerns with the recently released regulatory proposal aimed at
controlling the proposed regulations require all drayage trucks to
be equipped with a 1994-2003 model year engine certified to CA of
federal emaissions standards and a level 3 VDECS for PM or 2004 or
newer model year engines certified to CA and federal standards by
December 31, 2009.  Phase 2 creates even more burdensome
requirements required trucks to meet or exceed 2007 model year
engine standards by 12-31,2013.  To date the CARB has yet to
provide any information as to the overall potential cost
associated with these changes, specially:
1.  In order to fully evaluate the physical impact CARB would need
to first take into account the availability of engines trucks and
retrofit devices necesary to bring fleets into compliance.
2.  The potential of excessive price increases levied on new model
trucks.
3.  The impacts of forcing 2003 and older year model trucks out-
what happens to the used truck market and those who purchase those
trucks.
4.  The future impact of increasing initial costs for those
entering the port trucking business will ultimately have econonmic
consequences on the industry, as these regulations can and will
lead to driver shortages as trucks will no longer be afforable.
I am comitted to working to find attainable and sustainabkle
solutions to emissions reducts and ask you to take into
consideratiion the potential effects on the overall industry
before putting potentially damaging regulations in place.
Sincerely, Dick Vogel Commerce Truck & Equip. Sales