Comment Log Display

Governor Arnold Schwarzenegger
Members of the California Legislature 
California Air Resources Board


Dear Governor Schwarzenegger and
Members of the California State Legislature or 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. 

I want to be clear: Archer Trucking, Inc., a Certified Small
Business in California, is 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. However, in its current form, the Board’s
proposed regulation places a significant economic risk on our
business today, and jeopardizes our future viability in the
"construction" 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 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 my business.

We have used the figures provided by CARB (estimated costs) and
discovered it will cost almost $37,000 PER MONTH for the next six
years to comply with the schedule that is being proposed. We own
around 30 trucks and employ 20 people. There is NO WAY we can
afford an extra $37,000 payment each month. The timing of the
proposal is so unreasonable. 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. 

Because we are in a "clean" county, we do not even qualify for the
funds that may be available for those in the Bay Area Corridor, the
central California area, or Los Angeles. The unfair part of this is
that we DO leave our county to work so we must comply like everyone
else... we just don't get any money.

Our Company has already begun the process of replacing our fleet
in anticipation of these regulations by buying two new trucks. We
felt we HAD to start sometime, so we did six months ago.  However,
the smaller owner/operators 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. These men and women
usually have NO payment on their trucks, and simply cannot afford a
three to four thousand a month payment on a new truck.  

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, I have been told that 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. I will be at the hearing Thursday and
Friday, and certainly hope things don't go forward as they are
proposed right now.

Sincerely, 


Shellie A. Archer
Archer Trucking, Inc.
3480 N. State Street
Ukiah, CA  95482
707-489-3091