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I operate a vehicle dealership selling trailers to the trucking
industry and businesses using trailers to transport their product. 
After 49 years in business, I am concerned about the viability of
our customers and of dealerships in these difficult times. 
Business will be made more difficult by the recent proposed rules
to mandate equipment changes.

Mandating SmartWay type equipment will further devalue used
trailers in this poor economy.  With financing more difficult to
obtain for new purchases or retrofits many operators will retire
their existing equipment and not replace it - trailers that will be
virtually useless as they don't meet the new requirements.

While we all support reducing greenhouse gasses, we must also be
concerned about movement of goods and our state's economy. 
Allowing the SmartWay program to operate as intended, a personal
choice and incentive, will see older, less efficient equipment
gradually retired with less hardship to truck and trailer operators
and our state's economy.

Thank you for your consideration.

Respectfully,

Roger M Simon
Pioneer Trailer Sales
Santa Ana, California