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Comment 81 for Greenhouse Gas Heavy Duty Vehicles (SmartWay) (ghghdv08) - 45 Day.

First NameLarry and Dianne
Last NameLong
Email Addressldt@npgcable.com
AffiliationL & D Transportion (Sole Proprietorship)
SubjectStatewide Trck and Bus Reglation 2008
Comment
Larry and Dianne Long do support the state's efforts to improve air
quality.  Our problem with the proposal is the timing and the cost
factors.

We are a single-truck sole proprietorship in San Bernardino
County, California.  We purchased our 2000 Freightliner in 2004 and
replaced the engine (Cost $30,000) in late 2006.  Because we had
good personal and business credit, we have been able to stay in
business to this point and because we know how to manage money and
control costs.  

During the year 2008, the trucking industry saw the highest fuel
prices in history.  No one at the state or federal government level
did anything to help us and many owner-operators stopped operating
in California, many refused to come to California because of the
anti-idling laws, and now they will refuse because of the impending
regulations that will require expensive changes for all truck
owners.

Right now, the economy of the entire country is in a mess.  Things
are not going well in California either.  Since every resident and
visitor breathes the same air, why isn't there a fee for
breathing?

We can understand the need to reduce pollution.  So, why not test
individual trucks to see just how much pollution they are
producing?  Using those results, create programs that will assist
the owners of the polluting equipment make the needed changes.  

We are not currently in a position to make expensive changes. The
SmartWay program refers us to lenders that want 12% or more as the
interest rate for APU equipment that avoids the idling of the
truck's engine while parked for US Dot’s REQUIRED 10-hour rest
period.  Between the cost of the equipment and the cost of the loan
on it, there will be no saving to the equipment owner, at least,
not now, when the fuel prices have come down again.

Why is it that there are no sole operators represented on the CARB
committees when the CARB's plans directly affect them?  The CARB
has chosen to ignore our pleas from the beginning.

Individual drivers have no control over the rules under which they
much operate.  Air quality is important, but so is driver safety. 
A tired driver, whether driving a car, motorcycle, bus, or truck)
is a dangerous driver.

The CARB and other concerned branches of government need to
consider more than only what they want.  They also need to take
into consideration the impact these rapid changes and new
regulations will have on the sectors affected.  In other words,
let's use some common sense.

For the most part, the trucks that are producing the most
pollution are those that run short-haul from the ports to
distribution centers outside of the port areas.  The trucks going
into the ports are very old, not maintained to the same degree as
most over-the-road trucks are; and they are subject to fewer
in-depth inspections because they rarely cross a scale where they
can be inspected periodically.

In an ideal world everyone would always have the money needed to
make desirable changes as soon as possible.  This is not that time.
 Inadequate thought about the consequences for small fleets and
individual truck owners is the big problem for us who are trying to
stay in business in a failing economy in an industry that is
over-regulated anyway.

Please use some common sense and create more and better
opportunities for those of us who want to comply to do so without
having to face bankruptcy in the process.  Even postponing these
changes for another five years would allow those of us who reside
and have a business in California to make preparation and put more
money aside for the required changes.

Thank you for your consideration of our comments.

Larry & Dianne Long
Owners
L & D Transportation
(A California Sole Proprietorship)
PO Box 1080
Earp, CA 92242-1080
760-665-8131
ldt@npgcable.com


Attachment
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Date and Time Comment Was Submitted 2008-12-07 22:40:02

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