Comment Log Display

The Board should consider the adverse economic effect to the
carrier's business planning regarding the sale of used equipment (
both trucks and refrigerated trailers ). Prospective buyers of this
equipment reduce the purchase price to compensate for the retrofits
that the Board will require. As an example--- a reefer unit on a
trailer costs about fifteen thousand dollars. Retrofitting the unit
cost about seven thousand dollars. This translates to a loss to the
seller of nearly the current value of the equipment when adjustment
is made by the buyer anticipating the cost of upgrading to current
regulations. The net result will be that the functionally and
economically obsolete pieces of equipment will be kept on the
road---the Board will have invested much needed capital in an
obsolete piece of equipment. The sellers of the equipment will have
to increase freight rates to compensate for the loss in trade-in
value.
 Is it not wiser to regulate in a fashion so that the
manufacturers of the equipment will initiate the improvements to
the diesel engines to accommodate the buyers need to comply with
regulation? These will then be purchased and introduced into the
cycle---resulting in reductions in emissions and removal of
substandard equipment as a result of the economic cycle. We trade
at three years and most over the road trucking companies do
likewise. Local truckers are able to purchase our used equipment
which is functional for local use. The result will be an upgrading
which occurs in a timely manner and thru innovation and engineering
by the manufacturers that already have the personnel and expertise
in house. 
It is almost never wise to expend new money in a functionally and
economically obsolete piece of equipment.