CALIFORNIA AIR RESOURCES BOARD letter to UHCA regarding AB 1675 October
3, 1996 Mr. David Barnes, President United Highway Carriers 1817 South
Fresno Avenue Stockton, California 95206 Dear Mr. Barnes: I wish to express
my personal gratitude to the United Highway Carriers Association (UHCA)
for the vital role played by the Association, many individual UHCA members
and your tireless legislative advocate, Deborah Mattos, during the final
critical days of the 1996 Legislative Session. Without your assistance,
a well intentioned, but disastrous bill almost certainly would have been
approved by the Legislature. That bill, AB 1675, would have banned the
operation and registration of pre-1987 trucks in California beginning in
2004. Because there was so much confusing and contradicting information
concerning AB 1675, I want to take this opportunity to set the record straight.
For example, it was believed by many that AB 1675 would shield trucking
companies from local air quality district regulations including so-called
fleet rules. This simply was not the case. AB 1675 had no provisions
that restricted local air quality district authority. With or without AB
1675, local air quality districts must fulfill their legal obligation to
develop and manage air quality programs that meet federal and state clean
air goals. The sponsors of AB 1675 stated that the proposal was intended
to deliver a significant improvement in air quality in accordance with
the federally-mandated State Implementation Plan (SIP) that was adopted
in 1994. However, after careful and exhaustive analysis of the emission
reducing impact of AB 1675, the Air Resources Board (ARB) staff determined
that the bill would fall far short of achieving the pollution reductions
that would be necessary to offset the need for other efforts to reduce
emissions from trucks. Specifically, the ban on pre-1987 trucks would provide
only 1.18 tons per day of emission reductions where more than 10 tons are
needed. The principal reason for the meager emission-reducing effect of
the bill is that natural attrition will result in relatively few pre-1987
trucks that will be in significant use in 2004 and thereafter. Furthermore,
the confirmation of vehicle mileage for exempt trucks as well as verifying
the adequacy of modified and repowered trucks would make the ban difficult
to enforce. The bills uncertain impact on interstate and international
trucks further complicated enforcement and administrative issues. The short-fall
in emission reductions coupled with the high administrative and enforcement
burdens that would be necessary to effectively implement the bill, lead
to the inevitable conclusion that AB 1675 would not be cost-effective,
and should not become a part of the States strategy to satisfy the SIP.
For these reasons, the ARB opposed AB 1675. I recognize that both state
and local air quality programs can be a burden on the trucking industry.
However, I also believe that we all share the common goal of achieving
healthful air quality for all Californians. I pledge to you and UHCA members
that I am sensitive to your concerns and interested in hearing your views
and suggestions on developing and implementing air quality programs that
make the most sense. I you or your members have any questions or comments
on this issue, please do not hesitate to contact me or my Legislative Director,
Mr. Chris Reynolds, at (916) 322-8520. Sincerely, John D. Dunlap III Chairman,
CARB
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