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Comment 39 for Greenhouse Gas Heavy Duty Vehicles (SmartWay) (ghghdv08) - 45 Day.

First NameWilliam
Last NameUpfold
Email Addresswupfold@aol.com
Affiliation
SubjectDiesel regulations
Comment
I am a one truck owner operator leased to KNIGHT TRANSPORTATION.
They WILL NOT allow me to adopt any of these so called energy
effiecent technologies as long as I am leasing the truck from them.
When the truck is paid for in 2010, its value will not be worth the
estimated $30,000 it would cost to get these upgrades. And with the
economy in the shape that it's in, it would not be cost effective
to upgrade. Nor, would I be able to make enough money in the 11
month period that I would have before 2012 required replacement of
the engine to purchase a newr truck that would meet these
requirements. Cost effective solution for me would be to sell my
property in CALIFORNIA and move some place else and avoid operating
in CALIFORNIA.

Now, lets look at the added expenses that the CARB has not taken
into consideration of these purposed regulations.

1) Super single/wide based tires: 
   a)More trucks sitting on the shoulder of roads and highways 
     waiting for the repair trucks to fix a flat. This would
     cause an increase of potiential accidents. Plus, if the 
     wheel is damaged due to a blow out, it would cost 
     estimated  $900 for new wheel and tire, plus the cost
     of up to $200 to the repair truck to even come out there.
     Plus the cost of any damage done to the equipment before
     it would be legal to operate on the road again.

2) Aerodynamic kits:
   a) The only kit that I have seen to date that is smart way
      approved would add another 3 feet to the overall lenght
      of the operating units. Which in my case would be a total
      of 76 feet from the front bumper of the truck to the
      protruding edge of the kit. CALIFORNIA currently has a
      65 foot overall lenght restriction on all state and local
      highways. 

I would ask that the panel please look into all of the extra and
potentially extra costs of adopting these purposed changes. 

Thank you,
William A Upfold

Attachment
Original File Name
Date and Time Comment Was Submitted 2008-11-23 11:07:33

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