2171 Juniper

BREATHE CALIFORNIA

Bay Area

1469 Park Avenue

San Jose, CA 95126-2598

(408) 998-5865

Margo Leathers Sidener, MS, CHES, CEO

Thomas M. Dailey, MD, FCCP, Chair

Central Coast

550 Camino El Estero

Suite 100

Monterey, CA 93940-3231

(831) 373-7306

Gabriella Tagliacozzo, CEO

Robert Carr, Chair

Golden Gate Public Health Partnership

2171 Junipero Serra Blvd.

Suite 720

Daly City, CA 94014-1999

(650) 994-5868

Linda Civitello-Joy, CEO

Andrea Cope, Chair

Los Angeles

5858 Wilshire Blvd.

Suite 300

Los Angeles, CA 90036-4521

(323) 935-8050

Enrique Chiock, CEO

Michael Arlen, Chair

Sacramento- Emigrant Trails

909 12th Street, Suite 100

Sacramento, Ca 95814-2997

(916) 444-5900

Jane Hagedorn, CEO

Roni Abacherli, Chair

Andy Katz, MCP,

State Government Relations Director

(510) 848-5001

Since the beginning of the 1900s,

Breathe California has fought for

clean air, healthy lungs

and the elimination of lung disease

in California.

December 10, 2008

California Air Resources Board

1001 I Street
Sacramento, CA 95812-2815

RE: Strong Support for Truck and Bus Rule

Chair Nichols and ARB Members:

Diesel pollution is a highly toxic carcinogen, causing 24,000 premature deaths annually from particulate matter exposure, including 4,500 annually due to trucks and buses. In addition, diesel truck pollution imposes costs on the California economy - $28 billion annually in just the South Coast and San Joaquin Valley regions. This regulation is desperately needed to protect public health and ensure that California can meet federal air quality standards.

We recommend amending the regulation (1) to restrict the proposed exemptions for agricultural trucks and (2) to provide a margin of safety for meeting SIP commitments.

The proposed agricultural exemption will still allow for local exposure to unhealthy air. To protect public health as much as possible, we concur with the suggestions to (1) limit fleet size to small fleets of three vehicles or lower, (2) reducing the mileage threshold for delayed PM filter requirements (2015) and delayed 2010 NOx engine standards (2023) to vehicles driving under 10,000 miles a year, (3) not including chemical trucks, and (4) requiring that replacement vehicles must have a PM filter.

This rule is critical to meeting SIP commitments in the San Joaquin Valley and South Coast region, but the commitments are so heavily dependent on the emission standards in this regulation and its enforcement, that there is no margin for error. To ensure compliance, the Board should adopt a rule that will obtain the reductions needed to provide a margin of safety in meeting SIP commitments, including requiring vehicle inspections and third-party evaluations.

This rule will save over 9,000 lives and prevent 150,000 asthma attacks. We urge the Board to adopt this critical rule to protect public health.

Sincerely,

Andy Katz