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