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Comment 38 for Greenhouse Gas Heavy Duty Vehicles (SmartWay) (ghghdv08) - 45 Day.

First NameDonald
Last NameNielsen
Email AddressNielsentrucking@aol.com
AffiliationCTA
SubjectTruck & Bus proposed ruling
Comment
I am commenting because there are no one size fits all for the
transportation industry. 
  I am a small fleet owner who operates 10 trucks mostly in
California.  We are based on the central coast in Salinas, CA.  My
business employs 14 people and has been operating continuously for
38 years.
  We are an on call business who loads & delivers fresh produce
for railroad intermodal companies (piggybacks)we load & deliver
block ice for small produce companies into the central valley for
shipping corn & broccoli.  This is a valuable service for small
shippers who cannot afford to own or lease ice generating machines.
 We also haul ice for construction companies making structural
concrete for bridges & buildings throughout CA.  We haul ice during
the holidays for cities & business' for snow days for children as
well as sporting events (X Games skiing exhibitions).
  We haul heavy equipment for produce companies & refrigeration
equipment that requires drivers with haz mat endorsements. We are a
diversified, service oriented company that has vans, reefers,
flatbeds & low beds.  We do not have steady, everyday routs.  Our
trucks average less than 35,000 miles per year.  Our equipment is
mid 1990's to early 2000's.  Our Equipment is well maintained,
smoke tested & is in compliance with all current regulations.  
  If the proposed regulation is passed in it's current form our
company quire simply couldn't continue to operate.  Much of our
equipment would have to be disposed of before it's useful life, and
expensive retrofits would be required for the balance.  Paying for
the replacement of disposed units as well as retrofit of other
units would not be possible due to current financial conditions. 
To pay for the added investment we would require more work & it is
currently not available in our sector of business.  We would cease
to exist, denying the public a valuable service oriented company
that has paid taxes & provided jobs for over 38 years. 
 Trucking companies purchasing new trucks generally expect to run
these vehicles in excess of 120,000 miles per year & generally have
dedicated routes that they can put these trucks on.  While
replacement of these vehicles may impose a financial burden on
these companies they will be able to recover this because of
dedicated routes.  I believe an alternative method or exceptions
for companies who run their equipment under 40,000 miles per year
would allow for smaller business, such as myself, to continue to
operate.
  Thank you for your consideration on this matter.

Sincerely,
Donald Nielsen
Nielsen Trucking Co., Salinas, CA

Attachment
Original File Name
Date and Time Comment Was Submitted 2008-11-22 14:18:51

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