Comment Log Display

November 20, 2007

RE: Proposed Port Drayage Truck Regulation

Dear ARB Board Member: 

I am a local trucking company operating in and around the ports
and have been in business in California for 31 years.  Mountain
Valley Express is part of the California Trucking Association
(CTA), which represents over 2,300 member companies who operate in
and out of California, and who’s Southern and Northern Intermodal
Conferences make up the largest block of intermodal carriers
nationwide. 

As a business operating in California we recognize the air quality
issues facing all of us. Many of our employees live and work in and
around the port complexes and are currently working to assist in
finding sustainable solutions that not only improve air quality
but also help sustain a growing goods movement industry. 

I have concerns with the recently released regulatory proposal
aimed at controlling emissions for in-use on-road heavy duty
drayage trucks within California Ports. Currently the proposed
regulations require all drayage trucks to be equipped with a
1994-2003 model year engine certified to California or federal
emissions standards and a level 3 VDECS for PM or 2004 or newer
model year engines certified to California and federal standards
by December 31, 2009. Phase 2 creates even more burdensome
requirements requiring trucks to meet or exceed 2007 model year
engine standards by December 31, 2013. 

To date the California Air Resources Board (CARB) has yet to
provide any information as to the overall potential cost
associated with these changes, specifically: 
  
•	In order to fully evaluate the physical impact CARB would need
to first take into account the availability of engines trucks and
retrofit devices necessary to bring fleets into compliance. 
•	The potential of excessive price increases levied on newer model
trucks. 
•	The impacts of forcing 2003 and older year model trucks out –
what happens to the used truck market and those who purchase those
trucks?
•	The future impact of increasing initial costs for those entering
the port trucking business will ultimately have economic
consequences on the industry, as these regulations can and will
lead to driver shortages as trucks will no longer be affordable. 

We are committed to working to find attainable and sustainable
solutions to emissions reductions and ask you take into
consideration the potential effects on the overall industry before
putting potentially damaging regulations in place. We hope to
continue working towards a common goal. 

Sincerely, 



Robert Alberti
Dedicated Logistics Manager
Mountain Valley Express
Manteca, Ca