Comment Log Display

Dear Sirs,

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 and our business.  

Therefore, we opposed the implementation of the CARB regulation as
drafted.  We support an alternative proposal by the Driving Toward
a Cleaner California (DTCC) Coalition.

I want to be clear: Sierra Bay Transport Inc. strongly supports
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.  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.  Fourth
Quarter 2008 has been one of the worst quarters we have seen in our
business in decades.  Fourth quarter is normally one of the best
quarters of the year.

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.  

Moreover, the CARB proposed regulation works against the efforts
of our Federal and State governments by consuming both public and
private resources that are not available.

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 do not 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 shut our
companies’ doors, ultimately costing jobs and revenue to the
state’s economy.  

Our State and Country cannot afford these losses at this time.

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



Sincerely, 

Robert Grigas
President,
Sierra Bay Transport Inc.

(916) 223-1394