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Ad Hoc Industry Working Group Letter to CARB


Ad Hoc Industry Working Group CARB On-Road Diesel Truck Regulations January 4, 2010 Members of the Air Resources Board: Ms. Mary D. Nichols, Chair Dr. John Balmes Ms. Sandra Berg Ms. Dede D’Adamo Ms. Lydia H. Kennard Mr. Ron Loveridge Mrs. Barbara Riordan Mr. Ron Roberts Mr. Dan Sperling Dr. John Telles Executive Director James Goldstene California Air Resources Board P.O. Box 2815 1001 "I" Street Sacramento, CA 95812 Subject: CARB On-Road Diesel Truck Regulation; Industry concerns and requests regarding review of options, data, analysis and scientific studies. Members of the Board and Executive Director Goldstene: This letter, co-authored by a number of affected trucking firms and trade associations, is provided to help staff in their tasks relating to a comprehensive review of the On-Road Diesel Truck Rule. We believe it is important for the Board to know the expectations of numerous trucking interests that are directly and adversely affected by the Rule in its current form. It is our firm resolve that the Board needs a thorough and comprehensive understanding of rule options and their potential consequences. And, the Board needs quality, up-to-date economic and emissions analysis to assure proposed options provide the necessary flexibility for the industry to comply. We cannot emphasize strongly enough that we want to be a constructive part in cleaning California’s air. That was evidenced in the Driving Towards a Cleaner California proposal that provided equivalent emission reductions to the CARB rule, at the end of the compliance period. So with that under-pinning we want to make sure the CARB Board is sufficiently, openly and well advised to make appropriate decisions when it again considers the rule. Noted, following, are our specific concerns and general suggestions for additional or revised supporting information – we will be providing more detailed recommendations regarding several areas in separate communications: − Tran science report – We believe an independently commissioned analysis is necessary. We believe it should be subjected to full and new peer review by scientists that have no research or economic conflicts of interest with CARB or the state of California. − Open science discussion – We believe CARB should host a full and open debate on the studies and science used to make its health risk assessment findings. This should include a health risk analysis using an only-California data set. − Affordability analysis – We strongly urge CARB to compile an affordability analysis, not just a mass industry cost estimate, on various sectors of the trucking industry. This analysis should evaluate, under a realistic economic recovery scenario, whether the current 2014 SIP commitments on PM 2.5 and NOx are achievable through this rule, if industry sectors are unable to afford needed improvements. − Financial assistance – A full disclosure of the amount of financial assistance actually available to the industry and, importantly, elements of the industry that will have no assistance available. It would be appropriate to use this information to determine if affordability issues can be resolved, and to what degree. − Emissions estimates – We suggest a fully work-shopped review of the emission estimates provided by staff to the Board regarding recession decreases in PM 2.5 and NOx. We are also requesting all models, databases, spreadsheets, inputs and any other relevant information created or used by staff in developing their estimates – see letter from California Trucking Association. − Technology review – A thorough emission particle trap technology review should be performed, especially regarding problems reported by short-haul or low-mileage vehicles. − A full suite of rule options including such ideas as: o More even distribution of compliance dates between 2011 and 2023. The more gradual compliance paths for fleets travelling under 30,000, 15,000, and 7,500 miles--as recommended by DTCC last year--would be meet this goal. o Change the baseline year from 2008 to a 3 year average. o A credit for reduced activity and emissions (similar to what was granted in the off-road rule), which would also allow fleets to keep any non-PDF trucks beyond 2014. o Allow the early retirement credit to apply to all 3 compliance paths. o Adjust mileage and hour use requirements to more accurately reflect low use vehicles in a slow economy. o Higher Level of Proof for Retrofits. Prior to requiring a retrofit on a local-use vehicle, require particulate filter manufacturers to demonstrate the effectiveness of their product under actual, short term haul conditions using actual operator demonstration installations. o Exemptions or alternate compliance schedules based upon a company’s need to comply with other CARB rules. o Ideas presented by staff at the December 9th hearing. We are prepared to interact with staff as needed in accomplishing this list of tasks. We must emphasize, however, that it is our considered opinion that anything less than what is requested in this letter will lead to our strong, vocal concerns that the Board is not receiving adequate information to make well-informed, carefully-crafted decisions. Signed, Jay McKeeman, VP of Government Relations & Communications California Independent Oil Marketers Association Julie Sauls, Vice President Legislative Affairs California Trucking Association Becky Stolberg, Vice President California Beer and Beverage Distributors Bryan Bloom, Owner Priority Moving, Inc. Charley Rea, Director of Communications & Policy CA Construction & Industrial Materials Association (CalCIMA) Steve Weitekamp, President The California Moving & Storage Association Sean Edgar, Executive Director Clean Fleets Coalition Lee Brown, President Calif. Dump Truck Owners Association (CDTOA) Mike Lewis, Senior Vice President, Construction Industry Air Quality Coalition (CIAQC) Bill Davis, Executive Vice President Southern California Contractors Association Skip Brown, Owner Delta Construction cc: Fred Aguiar, Deputy Chief of Staff, Governor’s Office Linda Adams, Secretary, Cal/EPA CARB Ombudsperson The Honorable Sam Blakeslee, Republican Leader, State Assembly The Honorable Dennis Hollingsworth, Republican Leader, State Senate Members of the Ad Hoc Industry Working Group To respond to this letter, please address correspondence to: Jay McKeeman, CIOMA VP of Government Relations & Communications 3831 N. Freeway Blvd. #130 Sacramento, CA 95834 916-646-5999 (offc) 916-646-5985 (fax) jaymck@cioma.com 

Ad Hoc Industry Working Group CARB On-Road Diesel Truck Regulations January 4, 2010 Members of the Air Resources Board: Ms. Mary D. Nichols, Chair Dr. John Balmes Ms. Sandra Berg Ms. Dede D’Adamo Ms. Lydia H. Kennard Mr. Ron Loveridge Mrs. Barbara Riordan Mr. Ron Roberts Mr. Dan Sperling Dr. John Telles Executive Director James Goldstene California Air Resources Board P.O. Box 2815 1001 "I" Street Sacramento, CA 95812 Subject: CARB On-Road Diesel Truck Regulation; Industry concerns and requests regarding review of options, data, analysis and scientific studies. Members of the Board and Executive Director Goldstene: This letter, co-authored by a number of affected trucking firms and trade associations, is provided to help staff in their tasks relating to a comprehensive review of the On-Road Diesel Truck Rule. We believe it is important for the Board to know the expectations of numerous trucking interests that are directly and adversely affected by the Rule in its current form. It is our firm resolve that the Board needs a thorough and comprehensive understanding of rule options and their potential consequences. And, the Board needs quality, up-to-date economic and emissions analysis to assure proposed options provide the necessary flexibility for the industry to comply. We cannot emphasize strongly enough that we want to be a constructive part in cleaning California’s air. That was evidenced in the Driving Towards a Cleaner California proposal that provided equivalent emission reductions to the CARB rule, at the end of the compliance period. So with that under-pinning we want to make sure the CARB Board is sufficiently, openly and well advised to make appropriate decisions when it again considers the rule. Noted, following, are our specific concerns and general suggestions for additional or revised supporting information – we will be providing more detailed recommendations regarding several areas in separate communications: − Tran science report – We believe an independently commissioned analysis is necessary. We believe it should be subjected to full and new peer review by scientists that have no research or economic conflicts of interest with CARB or the state of California. − Open science discussion – We believe CARB should host a full and open debate on the studies and science used to make its health risk assessment findings. This should include a health risk analysis using an only-California data set. − Affordability analysis – We strongly urge CARB to compile an affordability analysis, not just a mass industry cost estimate, on various sectors of the trucking industry. This analysis should evaluate, under a realistic economic recovery scenario, whether the current 2014 SIP commitments on PM 2.5 and NOx are achievable through this rule, if industry sectors are unable to afford needed improvements. − Financial assistance – A full disclosure of the amount of financial assistance actually available to the industry and, importantly, elements of the industry that will have no assistance available. It would be appropriate to use this information to determine if affordability issues can be resolved, and to what degree. − Emissions estimates – We suggest a fully work-shopped review of the emission estimates provided by staff to the Board regarding recession decreases in PM 2.5 and NOx. We are also requesting all models, databases, spreadsheets, inputs and any other relevant information created or used by staff in developing their estimates – see letter from California Trucking Association. − Technology review – A thorough emission particle trap technology review should be performed, especially regarding problems reported by short-haul or low-mileage vehicles. − A full suite of rule options including such ideas as: o More even distribution of compliance dates between 2011 and 2023. The more gradual compliance paths for fleets travelling under 30,000, 15,000, and 7,500 miles--as recommended by DTCC last year--would be meet this goal. o Change the baseline year from 2008 to a 3 year average. o A credit for reduced activity and emissions (similar to what was granted in the off-road rule), which would also allow fleets to keep any non-PDF trucks beyond 2014. o Allow the early retirement credit to apply to all 3 compliance paths. o Adjust mileage and hour use requirements to more accurately reflect low use vehicles in a slow economy. o Higher Level of Proof for Retrofits. Prior to requiring a retrofit on a local-use vehicle, require particulate filter manufacturers to demonstrate the effectiveness of their product under actual, short term haul conditions using actual operator demonstration installations. o Exemptions or alternate compliance schedules based upon a company’s need to comply with other CARB rules. o Ideas presented by staff at the December 9th hearing. We are prepared to interact with staff as needed in accomplishing this list of tasks. We must emphasize, however, that it is our considered opinion that anything less than what is requested in this letter will lead to our strong, vocal concerns that the Board is not receiving adequate information to make well-informed, carefully-crafted decisions. Signed, Jay McKeeman, VP of Government Relations & Communications California Independent Oil Marketers Association Julie Sauls, Vice President Legislative Affairs California Trucking Association Becky Stolberg, Vice President California Beer and Beverage Distributors Bryan Bloom, Owner Priority Moving, Inc. Charley Rea, Director of Communications & Policy CA Construction & Industrial Materials Association (CalCIMA) Steve Weitekamp, President The California Moving & Storage Association Sean Edgar, Executive Director Clean Fleets Coalition Lee Brown, President Calif. Dump Truck Owners Association (CDTOA) Mike Lewis, Senior Vice President, Construction Industry Air Quality Coalition (CIAQC) Bill Davis, Executive Vice President Southern California Contractors Association Skip Brown, Owner Delta Construction cc: Fred Aguiar, Deputy Chief of Staff, Governor’s Office Linda Adams, Secretary, Cal/EPA CARB Ombudsperson The Honorable Sam Blakeslee, Republican Leader, State Assembly The Honorable Dennis Hollingsworth, Republican Leader, State Senate Members of the Ad Hoc Industry Working Group To respond to this letter, please address correspondence to: Jay McKeeman, CIOMA VP of Government Relations & Communications 3831 N. Freeway Blvd. #130 Sacramento, CA 95834 916-646-5999 (offc) 916-646-5985 (fax) jaymck@cioma.com

Ad Hoc Industry Working Group CARB On-Road Diesel Truck Regulations January 4, 2010 Members of the Air Resources Board: Ms. Mary D. Nichols, Chair Dr. John Balmes Ms. Sandra Berg Ms. Dede D’Adamo Ms. Lydia H. Kennard Mr. Ron Loveridge Mrs. Barbara Riordan Mr. Ron Roberts Mr. Dan Sperling Dr. John Telles Executive Director James Goldstene California Air Resources Board P.O. Box 2815 1001 "I" Street Sacramento, CA 95812 Subject: CARB On-Road Diesel Truck Regulation; Industry concerns and requests regarding review of options, data, analysis and scientific studies. Members of the Board and Executive Director Goldstene: This letter, co-authored by a number of affected trucking firms and trade associations, is provided to help staff in their tasks relating to a comprehensive review of the On-Road Diesel Truck Rule. We believe it is important for the Board to know the expectations of numerous trucking interests that are directly and adversely affected by the Rule in its current form. It is our firm resolve that the Board needs a thorough and comprehensive understanding of rule options and their potential consequences. And, the Board needs quality, up-to-date economic and emissions analysis to assure proposed options provide the necessary flexibility for the industry to comply. We cannot emphasize strongly enough that we want to be a constructive part in cleaning California’s air. That was evidenced in the Driving Towards a Cleaner California proposal that provided equivalent emission reductions to the CARB rule, at the end of the compliance period. So with that under-pinning we want to make sure the CARB Board is sufficiently, openly and well advised to make appropriate decisions when it again considers the rule. Noted, following, are our specific concerns and general suggestions for additional or revised supporting information – we will be providing more detailed recommendations regarding several areas in separate communications: − Tran science report – We believe an independently commissioned analysis is necessary. We believe it should be subjected to full and new peer review by scientists that have no research or economic conflicts of interest with CARB or the state of California. − Open science discussion – We believe CARB should host a full and open debate on the studies and science used to make its health risk assessment findings. This should include a health risk analysis using an only-California data set. − Affordability analysis – We strongly urge CARB to compile an affordability analysis, not just a mass industry cost estimate, on various sectors of the trucking industry. This analysis should evaluate, under a realistic economic recovery scenario, whether the current 2014 SIP commitments on PM 2.5 and NOx are achievable through this rule, if industry sectors are unable to afford needed improvements. − Financial assistance – A full disclosure of the amount of financial assistance actually available to the industry and, importantly, elements of the industry that will have no assistance available. It would be appropriate to use this information to determine if affordability issues can be resolved, and to what degree. − Emissions estimates – We suggest a fully work-shopped review of the emission estimates provided by staff to the Board regarding recession decreases in PM 2.5 and NOx. We are also requesting all models, databases, spreadsheets, inputs and any other relevant information created or used by staff in developing their estimates – see letter from California Trucking Association. − Technology review – A thorough emission particle trap technology review should be performed, especially regarding problems reported by short-haul or low-mileage vehicles. − A full suite of rule options including such ideas as: o More even distribution of compliance dates between 2011 and 2023. The more gradual compliance paths for fleets travelling under 30,000, 15,000, and 7,500 miles--as recommended by DTCC last year--would be meet this goal. o Change the baseline year from 2008 to a 3 year average. o A credit for reduced activity and emissions (similar to what was granted in the off-road rule), which would also allow fleets to keep any non-PDF trucks beyond 2014. o Allow the early retirement credit to apply to all 3 compliance paths. o Adjust mileage and hour use requirements to more accurately reflect low use vehicles in a slow economy. o Higher Level of Proof for Retrofits. Prior to requiring a retrofit on a local-use vehicle, require particulate filter manufacturers to demonstrate the effectiveness of their product under actual, short term haul conditions using actual operator demonstration installations. o Exemptions or alternate compliance schedules based upon a company’s need to comply with other CARB rules. o Ideas presented by staff at the December 9th hearing. We are prepared to interact with staff as needed in accomplishing this list of tasks. We must emphasize, however, that it is our considered opinion that anything less than what is requested in this letter will lead to our strong, vocal concerns that the Board is not receiving adequate information to make well-informed, carefully-crafted decisions. Signed, Jay McKeeman, VP of Government Relations & Communications California Independent Oil Marketers Association Julie Sauls, Vice President Legislative Affairs California Trucking Association Becky Stolberg, Vice President California Beer and Beverage Distributors Bryan Bloom, Owner Priority Moving, Inc. Charley Rea, Director of Communications & Policy CA Construction & Industrial Materials Association (CalCIMA) Steve Weitekamp, President The California Moving & Storage Association Sean Edgar, Executive Director Clean Fleets Coalition Lee Brown, President Calif. Dump Truck Owners Association (CDTOA) Mike Lewis, Senior Vice President, Construction Industry Air Quality Coalition (CIAQC) Bill Davis, Executive Vice President Southern California Contractors Association Skip Brown, Owner Delta Construction cc: Fred Aguiar, Deputy Chief of Staff, Governor’s Office Linda Adams, Secretary, Cal/EPA CARB Ombudsperson The Honorable Sam Blakeslee, Republican Leader, State Assembly The Honorable Dennis Hollingsworth, Republican Leader, State Senate Members of the Ad Hoc Industry Working Group To respond to this letter, please address correspondence to: Jay McKeeman, CIOMA VP of Government Relations & Communications 3831 N. Freeway Blvd. #130 Sacramento, CA 95834 916-646-5999 (offc) 916-646-5985 (fax) jaymck@cioma.com

Ad Hoc Industry Working Group CARB On-Road Diesel Truck Regulations January 4, 2010 Members of the Air Resources Board: Ms. Mary D. Nichols, Chair Dr. John Balmes Ms. Sandra Berg Ms. Dede D’Adamo Ms. Lydia H. Kennard Mr. Ron Loveridge Mrs. Barbara Riordan Mr. Ron Roberts Mr. Dan Sperling Dr. John Telles Executive Director James Goldstene California Air Resources Board P.O. Box 2815 1001 "I" Street Sacramento, CA 95812 Subject: CARB On-Road Diesel Truck Regulation; Industry concerns and requests regarding review of options, data, analysis and scientific studies. Members of the Board and Executive Director Goldstene: This letter, co-authored by a number of affected trucking firms and trade associations, is provided to help staff in their tasks relating to a comprehensive review of the On-Road Diesel Truck Rule. We believe it is important for the Board to know the expectations of numerous trucking interests that are directly and adversely affected by the Rule in its current form. It is our firm resolve that the Board needs a thorough and comprehensive understanding of rule options and their potential consequences. And, the Board needs quality, up-to-date economic and emissions analysis to assure proposed options provide the necessary flexibility for the industry to comply. We cannot emphasize strongly enough that we want to be a constructive part in cleaning California’s air. That was evidenced in the Driving Towards a Cleaner California proposal that provided equivalent emission reductions to the CARB rule, at the end of the compliance period. So with that under-pinning we want to make sure the CARB Board is sufficiently, openly and well advised to make appropriate decisions when it again considers the rule. Noted, following, are our specific concerns and general suggestions for additional or revised supporting information – we will be providing more detailed recommendations regarding several areas in separate communications: − Tran science report – We believe an independently commissioned analysis is necessary. We believe it should be subjected to full and new peer review by scientists that have no research or economic conflicts of interest with CARB or the state of California. − Open science discussion – We believe CARB should host a full and open debate on the studies and science used to make its health risk assessment findings. This should include a health risk analysis using an only-California data set. − Affordability analysis – We strongly urge CARB to compile an affordability analysis, not just a mass industry cost estimate, on various sectors of the trucking industry. This analysis should evaluate, under a realistic economic recovery scenario, whether the current 2014 SIP commitments on PM 2.5 and NOx are achievable through this rule, if industry sectors are unable to afford needed improvements. − Financial assistance – A full disclosure of the amount of financial assistance actually available to the industry and, importantly, elements of the industry that will have no assistance available. It would be appropriate to use this information to determine if affordability issues can be resolved, and to what degree. − Emissions estimates – We suggest a fully work-shopped review of the emission estimates provided by staff to the Board regarding recession decreases in PM 2.5 and NOx. We are also requesting all models, databases, spreadsheets, inputs and any other relevant information created or used by staff in developing their estimates – see letter from California Trucking Association. − Technology review – A thorough emission particle trap technology review should be performed, especially regarding problems reported by short-haul or low-mileage vehicles. − A full suite of rule options including such ideas as: o More even distribution of compliance dates between 2011 and 2023. The more gradual compliance paths for fleets travelling under 30,000, 15,000, and 7,500 miles--as recommended by DTCC last year--would be meet this goal. o Change the baseline year from 2008 to a 3 year average. o A credit for reduced activity and emissions (similar to what was granted in the off-road rule), which would also allow fleets to keep any non-PDF trucks beyond 2014. o Allow the early retirement credit to apply to all 3 compliance paths. o Adjust mileage and hour use requirements to more accurately reflect low use vehicles in a slow economy. o Higher Level of Proof for Retrofits. Prior to requiring a retrofit on a local-use vehicle, require particulate filter manufacturers to demonstrate the effectiveness of their product under actual, short term haul conditions using actual operator demonstration installations. o Exemptions or alternate compliance schedules based upon a company’s need to comply with other CARB rules. o Ideas presented by staff at the December 9th hearing. We are prepared to interact with staff as needed in accomplishing this list of tasks. We must emphasize, however, that it is our considered opinion that anything less than what is requested in this letter will lead to our strong, vocal concerns that the Board is not receiving adequate information to make well-informed, carefully-crafted decisions. Signed, Jay McKeeman, VP of Government Relations & Communications California Independent Oil Marketers Association Julie Sauls, Vice President Legislative Affairs California Trucking Association Becky Stolberg, Vice President California Beer and Beverage Distributors Bryan Bloom, Owner Priority Moving, Inc. Charley Rea, Director of Communications & Policy CA Construction & Industrial Materials Association (CalCIMA) Steve Weitekamp, President The California Moving & Storage Association Sean Edgar, Executive Director Clean Fleets Coalition Lee Brown, President Calif. Dump Truck Owners Association (CDTOA) Mike Lewis, Senior Vice President, Construction Industry Air Quality Coalition (CIAQC) Bill Davis, Executive Vice President Southern California Contractors Association Skip Brown, Owner Delta Construction cc: Fred Aguiar, Deputy Chief of Staff, Governor’s Office Linda Adams, Secretary, Cal/EPA CARB Ombudsperson The Honorable Sam Blakeslee, Republican Leader, State Assembly The Honorable Dennis Hollingsworth, Republican Leader, State Senate Members of the Ad Hoc Industry Working Group To respond to this letter, please address correspondence to: Jay McKeeman, CIOMA VP of Government Relations & Communications 3831 N. Freeway Blvd. #130 Sacramento, CA 95834 916-646-5999 (offc) 916-646-5985 (fax) jaymck@cioma.com






Ad Hoc Industry Working Group CARB On-Road Diesel Truck Regulations January 4, 2010 Members of the Air Resources Board: Ms. Mary D. Nichols, Chair Dr. John Balmes Ms. Sandra Berg Ms. Dede D’Adamo Ms. Lydia H. Kennard Mr. Ron Loveridge Mrs. Barbara Riordan Mr. Ron Roberts Mr. Dan Sperling Dr. John Telles Executive Director James Goldstene California Air Resources Board P.O. Box 2815 1001 "I" Street Sacramento, CA 95812 Subject: CARB On-Road Diesel Truck Regulation; Industry concerns and requests regarding review of options, data, analysis and scientific studies. Members of the Board and Executive Director Goldstene: This letter, co-authored by a number of affected trucking firms and trade associations, is provided to help staff in their tasks relating to a comprehensive review of the On-Road Diesel Truck Rule. We believe it is important for the Board to know the expectations of numerous trucking interests that are directly and adversely affected by the Rule in its current form. It is our firm resolve that the Board needs a thorough and comprehensive understanding of rule options and their potential consequences. And, the Board needs quality, up-to-date economic and emissions analysis to assure proposed options provide the necessary flexibility for the industry to comply. We cannot emphasize strongly enough that we want to be a constructive part in cleaning California’s air. That was evidenced in the Driving Towards a Cleaner California proposal that provided equivalent emission reductions to the CARB rule, at the end of the compliance period. So with that under-pinning we want to make sure the CARB Board is sufficiently, openly and well advised to make appropriate decisions when it again considers the rule. Noted, following, are our specific concerns and general suggestions for additional or revised supporting information – we will be providing more detailed recommendations regarding several areas in separate communications: − Tran science report – We believe an independently commissioned analysis is necessary. We believe it should be subjected to full and new peer review by scientists that have no research or economic conflicts of interest with CARB or the state of California. − Open science discussion – We believe CARB should host a full and open debate on the studies and science used to make its health risk assessment findings. This should include a health risk analysis using an only-California data set. − Affordability analysis – We strongly urge CARB to compile an affordability analysis, not just a mass industry cost estimate, on various sectors of the trucking industry. This analysis should evaluate, under a realistic economic recovery scenario, whether the current 2014 SIP commitments on PM 2.5 and NOx are achievable through this rule, if industry sectors are unable to afford needed improvements. − Financial assistance – A full disclosure of the amount of financial assistance actually available to the industry and, importantly, elements of the industry that will have no assistance available. It would be appropriate to use this information to determine if affordability issues can be resolved, and to what degree. − Emissions estimates – We suggest a fully work-shopped review of the emission estimates provided by staff to the Board regarding recession decreases in PM 2.5 and NOx. We are also requesting all models, databases, spreadsheets, inputs and any other relevant information created or used by staff in developing their estimates – see letter from California Trucking Association. − Technology review – A thorough emission particle trap technology review should be performed, especially regarding problems reported by short-haul or low-mileage vehicles. − A full suite of rule options including such ideas as: o More even distribution of compliance dates between 2011 and 2023. The more gradual compliance paths for fleets travelling under 30,000, 15,000, and 7,500 miles--as recommended by DTCC last year--would be meet this goal. o Change the baseline year from 2008 to a 3 year average. o A credit for reduced activity and emissions (similar to what was granted in the off-road rule), which would also allow fleets to keep any non-PDF trucks beyond 2014. o Allow the early retirement credit to apply to all 3 compliance paths. o Adjust mileage and hour use requirements to more accurately reflect low use vehicles in a slow economy. o Higher Level of Proof for Retrofits. Prior to requiring a retrofit on a local-use vehicle, require particulate filter manufacturers to demonstrate the effectiveness of their product under actual, short term haul conditions using actual operator demonstration installations. o Exemptions or alternate compliance schedules based upon a company’s need to comply with other CARB rules. o Ideas presented by staff at the December 9th hearing. We are prepared to interact with staff as needed in accomplishing this list of tasks. We must emphasize, however, that it is our considered opinion that anything less than what is requested in this letter will lead to our strong, vocal concerns that the Board is not receiving adequate information to make well-informed, carefully-crafted decisions. Signed, Jay McKeeman, VP of Government Relations & Communications California Independent Oil Marketers Association Julie Sauls, Vice President Legislative Affairs California Trucking Association Becky Stolberg, Vice President California Beer and Beverage Distributors Bryan Bloom, Owner Priority Moving, Inc. Charley Rea, Director of Communications & Policy CA Construction & Industrial Materials Association (CalCIMA) Steve Weitekamp, President The California Moving & Storage Association Sean Edgar, Executive Director Clean Fleets Coalition Lee Brown, President Calif. Dump Truck Owners Association (CDTOA) Mike Lewis, Senior Vice President, Construction Industry Air Quality Coalition (CIAQC) Bill Davis, Executive Vice President Southern California Contractors Association Skip Brown, Owner Delta Construction cc: Fred Aguiar, Deputy Chief of Staff, Governor’s Office Linda Adams, Secretary, Cal/EPA CARB Ombudsperson The Honorable Sam Blakeslee, Republican Leader, State Assembly The Honorable Dennis Hollingsworth, Republican Leader, State Senate Members of the Ad Hoc Industry Working Group To respond to this letter, please address correspondence to: Jay McKeeman, CIOMA VP of Government Relations & Communications 3831 N. Freeway Blvd. #130 Sacramento, CA 95834 916-646-5999 (offc) 916-646-5985 (fax) jaymck@cioma.com