Comment Log Display

I am a consultant advising trucking companies in and around the
ports in Los Angeles harbor and in the San Francisco Bay area.  I
have previously been 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
nationalwide.  

I too am concerned about air quality issues facility all of us,
but this is the wrong approach.  It's nothing but a "tail wagging
the dog" effort in and around the port complexes. 

Currently, the proposed regulations required all drayage trucks to
be equipped with a 1994-2003 model year engine certified to
California or federal emissions stndards and a level 3 VDECS for
PM or 2004 or newer model year engines certified to CA and federal
standards by 12/31/2009.  Phase 2 creates even more burdensome
requirements requiring trucks to meet or exceed 2007 model year
engine standards by December 31, 2013.  

By promoting the proposed port dryage truck regulations you are
effectively tackling only about 5% of the problem with air quality
issues. How about the pollution from the ships themselves plus the
number of automobiles in the harbor areas.  That's where you
should be directing your attention.  How about some real efforts
to control air quality in CA and not just tackle the easy targets,
e.g. trucks.  

Thank you for the opportunity and I respectfully request these
proposed port drayage truck regulations not be inacted at this
time. 

Angel E. Arzaga, CDS
3252 Landess Ave
San Jose, CA 95132