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Comment for Statewide Truck and Bus Regulation 2008 (truckbus08) - 45 Day.

First NameToby
Last NameRobinson
Email Addresstrobinson@suburbanpropane.com
Affiliation
SubjectDiesel Truck Proposal
Comment
CARB is currently considering the adoption of an on-road diesel
truck and bus regulation that if implemented as presently drafted
would have a profound, negative impact on California's economy.

My company supports improving the state's air quality. However,
the Board's proposed reulation places a significant economic risk
on our business today, which is already under stress from the
recent financial crisis.

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression, and small
businesses are struggling to make ends meet. Companies like mine
are being asked to dispose of equipment and assets before their
useful life has been completed and purchase new equipment before it
would otherwise be acquired. A combonation of this proposed rule
and the state of the economy have left the trade-in or resale value
of our equipment worth only pennies on the dollar. My company and
others like us simply don't have the resources or access to capital
to retrofit our engines. 

Given the multi-billion dollar cost of this regulation and the
current volatile economic environment, please support the
alternative proposal proposed by the Driving Toward a Cleaner
California Coalition that would give companies like mine the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emision
reductions. In fact, CARB's own analysis of the DTCC alternative
confirms that the DTCC alternative proposal achieves roughly
similar emissions benefits to the proposed regulation in the
long-term.

Thank You for your consideration.

Attachment
Original File Name
Date and Time Comment Was Submitted 2008-11-26 13:56:15

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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