Comment Log Display

The California Air Resources Board (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 struggling economy. 

I want to be clear: the Don Chapin Co. Inc. is very supportive of
reducing particulate matter (PM) and NOx emissions from diesel
engines.  There is no disagreement that we all need to work
collectively to improve the state’s air quality and all of us want
to provide as healthy an environment as possible for our families,
our employees and all Californians.  However, in its current form,
the Board’s proposed regulation places a very significant economic
risk on our business today, jeopardizes our future viability in the
construction industry, which is already suffering from
unprecedented financial turmoil. 

CARB is proposing this multi-billion dollar regulation during the
worst economic crisis since the Great Depression. California
truckers, construction companies and bus operators are struggling
to make ends meet in the face of a massive slow down in the
construction sector due to falling home prices and home
foreclosures, declining consumer confidence and spending and a
freeze in the credit markets.  Today there is virtually no access
to capital for businesses, large and small.

Companies like ours 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 required. A combination of
this proposed rule and the state of the economy have left the
trade-in or resale value of our equipment worth pennies on the
dollar. My company and others like us simply don’t have the
resources or access to capital to retrofit our engines.  Some of us
may be forced to sell off our trucks at a loss or shutter our
companies’ doors, ultimately costing jobs and revenue to the
state’s economy. 

Many of California’s trucking companies have already begun the
process of retrofitting or replacing their fleets, whether in the
normal course of their business cycle or in anticipation of these
regulations.  However, the smaller owner/operators – those with
fleets of five trucks or less – who make up more than 55 percent of
all trucks registered in California will be severely hampered by
the costs of retrofitting or replacing trucks that, in some cases,
are the sole assets of their family-owned businesses.  

We feel that CARB staff grossly under estimated the true cost
impact of the proposed regulation on the trucking industry and that
this should reevaluated prior to board approval. Maybe CARB staff
should take into consideration that due to the downturn in the
economy our trucks are being used much less than they were when
staff made the emission reduction estimate? We think that this fact
alone might have inadvertently made they emission reduction goal
come to fruition, so is the proposed regulation really necessary? 

Given the multi-billion dollar cost of this regulation – and the
current volatile economic environment  - I urge you to support the
alternative proposal proposed by the Driving Toward a Cleaner
California (DTCC) Coalition that would give companies like ours the
opportunity to comply in the most reasonable timeframe and flexible
manner possible while still attaining aggressive emission
reductions. 

In fact, CARB’s own analysis of our DTCC alternative confirms that
the DTCC alternative proposal achieves roughly similar emissions
benefits to the proposed regulation in the long-term.

We must be careful not to forfeit California’s economy and ability
to move goods across the state, build construction projects and bus
our children to and from school for the sake of protecting our
environment. We look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.

Sincerely, 

Andrew A. Recalde
Equipment Manager
The Don Chapin Co. Inc.
Salinas CA.