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Diesel Comments Needed |
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Diesel truck and bus rules Thanks to those who filed comments
Thanks to those individuals who submitted comments to the California Air Resources Board's December 11 hearing on the proposed "Regulation to Reduce Emissions from In-Use On-Road Diesel Vehicles". Read summaries of the diesel rules by clicking here.
The letter below (approved by the Monterey County Farm Bureau Board of Directors) was submitted together with those letters from local growers. The material was delivered to CARB by Traci Roberts, Environmental Resources Coordinator.
Here is the text of Farm Bureau comment letter:
Begin Farm Bureau approved comment letter
November 20, 2008
Clerk of the Board
Air
Resources Board
Reference: Proposed Regulation to Reduce Emissions from In-Use On-Road Diesel Vehicles.
To Whom It May Concern:
First, we want to thank your staff for travelling to the Central Coast for a workshop with farmers and ranchers and providing an opportunity for questions and answers about this proposed regulation. We greatly appreciate Tony Brasil’s responsiveness to our request for that workshop.
It is important to note that the farmers and ranchers of Monterey County are located in an air basin that does not exceed emission standards for oxides of nitrogen (NOx) though we would be subject to a statewide standard under this proposed regulation. Monterey County Farm Bureau represents farmers and ranchers in the fourth most productive farming county in the nation.
Our farming and ranching families want clean air for the state of California and are willing to participate in programs that provide flexibility that allow us to meet the standards and fulfill our role as responsible citizens.
We appreciate that the Air Resources Board (ARB) does recognize the importance of agricultural vehicles and the functions they perform. We strongly encourage you to increase the mileage thresholds for vehicles 1995 and older in the final rule. You have provided extra time for compliance for agricultural vehicles that operate below specific mileage thresholds. But the proposed thresholds are not going to help us keep our carefully maintained, older vehicles that we actually use for day to day farming activities. Without more miles these agricultural vehicles will become unusable and make it impossible for smaller, family-based farming operations to keep going.
An irony that must be pointed out is that so many people say they would prefer to buy their food from the small, local farmer. Unlike almost all other industries, farmers and ranchers can never pass on increased costs to their customers. Regulations like this one, supported by well-meaning but unaware folks, will get rid of small farmers faster than any corporate take-over.
Ultimately, the requirement for particulate matter (PM) traps is a no-win situation for more than just agricultural vehicles in California, a no-win for businesses and jobs, and a no-win toward a cleaner, safer environment, here’s why.
PM traps will cause our engines to burn more diesel fuel rather than less. With PM traps, our engines will burn hotter and less safely. This is not a good scenario for trucks performing jobs in and around farm fields and near potentially flammable materials such as crops and other vegetation. Who will be liable when an ARB-required and ARB-verified PM trap causes a fire and harms life and property?
Most of the vehicles that this proposal would require to have a PM trap could not be sold for as much as the cost of the PM trap itself - $12,000 to 20,000 for each vehicle! With reduced fuel economy and higher maintenance costs with a PM trap than without, are we really doing California any favors? It just doesn’t make sense for independent operators and it doesn’t make sense for California. Public assistance funds are appreciated, but will be in high demand throughout the state especially in these hard economic times.
We ask that you not require us to add an expensive PM trap onto an older, but well-maintained vehicle and then also require us to purchase a 2010 vehicle to meet the NOx standards. We ask that you fund research into the use of bio-fuels and come up with a way to encourage their use that actually addresses the air quality issues of concern1. This is clearly not a request to obtain an exemption from regulation but rather the flexibility that will help us all do our part in this state. 1 A Biodiesel blend reduces particulate matter emissions by as much as 18% and overall tailpipe emissions by 45%. (Source: EPA and US Dept of Energy studies & National Biodiesel Board)
We appreciate that ARB staff and Board have recognized that agricultural vehicles allow farming to take place in California. We hope that California consumers will take the time to understand how their food is safely brought to market. v Delivery of farming inputs: including these vehicles under the agricultural vehicle provision is critically important to ensure the safe and efficient transport of these inputs. Rather than hundreds of individual farmers driving to a central location to pick up their fertilizers, compost, and crop protection products, quantities of these inputs are brought to a farming region and local distributors make more efficient trips to deliver to multiple farmers. These distributors are licensed and trained in the safe transport of these inputs. v Transport of harvest farm produce to the first point of process: packing sheds, coolers, and processing plants are the first points to which harvested produce is delivered from the field. In Monterey County, as in many of our farming areas statewide, these points of process are most often located in less populated areas and have more than one entry/exit point spreading out the movement or emissions from these trucks.
Finally, we do not understand why the CA Air Resources Board is being asked by its staff to over-reach the requirements of the U.S. Environmental Protection Agency. We are concerned for the California economy if the businesses that support our communities are pushed too hard, too fast. We are also concerned that this Board could be left open to valid challenges.
We encourage you to use a phased-in approach treating diesel engines the same way California treated cars. That is, only require vehicles to meet the standards in effect the year of manufacture. A phased-in approach will lead all Californians toward cleaner engines in just a few years more than with this proposed regulation. As it is now written, this proposed regulation : · will not reduce diesel fuel use · will not make our environment safer and cleaner · will jeopardize small businesses that depend on a few vehicles · will be unfriendly to independent operators, and · will cost California jobs and money. Who can afford that?
Thank you for the opportunity to comment on this proposed regulation.
Sincerely,
(signature)
CC: Mary Nichols, Chair, CA Air Resources Board Dorene D’Adamo, Chair, Agricultural Advisory Committee, CA Air Resources Board Jeff Denham, U.S. Senate Abel Maldanado, U.S. Senate Bill Monning, California Assemblymember Ana Caballero, California Assemblymember Cynthia Cory, Director of Environmental Affairs, Govt Affairs Division, California Farm Bureau Federation Ed Kendig, Interim APCO, Monterey Bay Air Pollution Control District Simone Salinas, Director MBAPCD and County Supervisor Lou Calcagno, Director MBAPCD and County Supervisor Fernando Armenta, Director MBAPCD and County Supervisor Mike Sewell, Air Quality Engineer, Monterey Bay Air Pollution Control District Lance Ericksen, Air Quality Engineer, Monterey Bay Air Pollution Control District Nick Papadakis, Executive Director, Association of Monterey Bay Area Governments
End Farm Bureau approved comment letter
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