Comment Log Display

December 2, 2008

Governor Arnold Schwarzenegger
State Capitol
Sacramento, CA 95814

Members, California Legislature 
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812

Dear Governor Schwarzenegger and
Members of the California State Legislature and CARB:

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 economy. 

We want to be clear: Wardlaw Trucking is very supportive of
reducing particulate matter (PM) and NOx emissions from diesel
engines.  There is no disagreement that we 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 significant economic risk
and jeopardizes the future viability of our aggregate (rock and
sand) delivery business which is very closely tied to the
construction industry, which is already reeling 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 acquired. 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. Our 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, we are among the smaller owner/operators –
those with fleets of five trucks or less – who make up more than 55
percent of all trucks registered in the state.  

We will be severely hampered by the costs of retrofitting or
replacing our truck which is the sole asset of our family-owned
businesses.  

Given the multi-billion dollar cost of this regulation – and the
current volatile economic environment  - we 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.  Even the DTCC’s alternative proposal will be difficult
for us, but we believe it is a fair compromise in this economy.

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, 

Corey & Hilary Wardlaw
Wardlaw Trucking
P O Box 6102
Napa, CA 94581
(707) 226-1336