Comment Log Display

California Air Resources Board
1001 I Street
P.O. Box 2815
Sacramento CA 95812

RE:  Proposed Regulation to Mandate Certain Aerodynamic Equipment
for Heavy-Duty Vehicles

Dear Chairman Nichols and Members of the Board:

The Arizona Trucking Association (AzTA) has reviewed the
California Air Resources Board’s (ARB) Regulation to Reduce
Greenhouse Gas Emissions from Heavy-Duty Vehicles.  While Arizona
Trucking Association agrees on the need to reduce fuel use and
greenhouse gas emissions, we must respectfully oppose a rule that
mandates unproven and costly technologies. 

Arizona Trucking Association’s opposition to the proposed
regulation is based upon the following concerns:

1.   The emission-reduction benefits of the technology mandated by
the regulation are questionable.  Few fleets utilize either the
trailer aerodynamic retrofits or the specified low rolling
resistance tires that would be required under the regulation. 
There are far less costly and more reliable ways to reduce fuel use
and emissions, including reductions in truck speeds.  Most fleets
have learned that the single most significant factor in fuel use is
driver technique and behavior.  Effective driver training programs
can do as much to improve fuel efficiency as any of the
technologies outlined by ARB.
2.   Selection of technologies is arbitrary.  While AzTA does not
advocate mandating any retrofit  technologies, it is difficult to
understand the rationale behind the selection of certain types of
equipment and not others, given the lack of data and experience
with these technologies.
3.   Maintenance.  Most trucking companies have had little or no
experience with retrofitted trailer skirts and fairings, even less
with these items as original equipment enhancements.  How will
retrofitted trailer skirts and fairings hold up under normal
wear-and-tear?  How often will they need to be replaced during the
average useful life of a trailer?  (For example, the average age of
trailers in revenue operation throughout the U. S. today is
approximately 7.5 years, depending upon type and utilization.)  How
will retrofits affect trailer warranties?
4.   Safety.  What are the potential safety consequences of
trailer retrofits that may become disconnected and fall off?   
5.   Size and weight conflicts.  Current California and federal
laws do not allow a weight or length tolerance to accommodate the
trailer equipment.  Carriers that comply with the proposed ARB
regulation are at risk for violating the state and federal weight
and length restrictions.
6.   Availability of technologies.  According to ARB’s own
research, more than one million trailer retrofit devices will be
needed to meet the requirements of the proposed regulation.  Yet we
are aware of only two manufacturing entities that currently produce
these devices.  How will ARB ensure sufficient manufacturing
capacity to produce these devices within the deadlines envisioned
by the regulation?
7.   Cost.  A majority of the trucks hauling freight into and from
California are not based in the state, meaning that the bulk of the
$10.4 billion cost (ARB’s estimate) will be borne by non-domiciled,
long-haul carriers. All but a small percentage of these trucks and
trailers are operated by small businesses with fewer than 20
trucks.  These small carriers will likely not have the capital
resources to comply.  Yet, those limited funds allocated by
California to retrofit equipment are largely not available to
non-domiciled fleets.  
8.   The regulation exempts some of the higher-polluting trucks
operating in CA.  While the use of trailer skirts and fairings
offers little benefit at lower speeds, by exempting many short-haul
trucks from the requirements, ARB is unfairly discriminating
against long-haul trucks.
9.   Federal Pre-emption.  AzTA believes that California does not
have the authority to impose these or any other state-specific
equipment requirements on interstate vehicles.  The interstate and
global nature of commerce today requires U. S. motor carriers to
operate equipment compliant with the laws and regulations of all
the states, Canada and Mexico.  Having to dedicate a fleet or
portion of a fleet to one state’s requirements is extremely costly
and inefficient.  In today’s economic environment, the regulation
imposes unacceptable costs on the businesses least able to absorb
these increases.

Arizona Trucking Association respectfully requests that the Board
vote “no” on this proposed regulation.  Thank you for your
consideration.

Sincerely,

Karen Rasmussen
President & CEO

David Williams
Vice President, Knight Transportation
Chairman of the Board of Arizona Trucking Association