Comment Log Display

LETTER TO THE CALIFORNIA AIR RESOURCES BOARD

12/5/08

California Air Resources Board

Dear CARB:

You are 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. 

I want to be clear: Valley Pacific 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 on our
business today, jeopardizes our future viability in the trucking
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 bank loans for businesses, large and small.

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 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 the state, 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.  

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 mine 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. I look forward to working with you, CARB,
environmental organizations, the Legislature and other stakeholders
to accomplish these goals.

Sincerely, 

Nathan Crum
Valley Pacific Petroleum Services
188-A Frank West Circle
Stockton, CA 95206