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PUBLIC TESTIMONY

Testimony by Felice Farber, Executive Director of Subcontractors Trade Association

2:28:40

·

134 sec

Felice Farber, representing the Subcontractors Trade Association, expressed concerns about the Citizens Air Complaint Program, particularly regarding due process, evidence accessibility, and the impact on the trucking industry. She urged for reforms to make the program more fair and efficient while still addressing air quality concerns.

  • Highlighted issues with delayed summons issuance and hearings, recommending more timely processes
  • Called for better access to evidence before hearings to facilitate fair adjudication
  • Suggested adjusting penalties based on vehicle type, with reduced penalties for cleaner, more efficient vehicles
  • Noted that Intros 747 and 941 address some issues but do not go far enough in reforming the program
Felice Farber
2:28:40
Thank you.
2:28:41
Good afternoon, Chair Genero.
2:28:42
I'm Felice Barber, Executive Director of the subcontractors Trade Association.
2:28:47
STA represents 350 Union Specialty Trade Contractors, and I'd like to highlight that a number of our members are small mechanical electrical and plumbing contractors, and the reporting receiving violations oftentimes while waiting to make deliveries at job sites.
2:29:02
Our primary concern with the Citizens Air complaint program is the lack of due process that's been mentioned 6 to 12 months to get the the summons and 18 to 24 months to actually get a hearing.
2:29:14
So we urge the counsel to require timely issuance of summonses and timely hearings to ensure fair proceedings.
2:29:20
In addition, as mentioned, we're very concerned about the lack of access to evidence.
2:29:25
Oftentimes, they don't get the the video or specific details in advance, and it makes it very difficult to present depends on a follow-up.
2:29:34
We strongly recommend the counsel mandate the availability of evidence well before hearings to facilitate a fair and efficient adjudication process.
2:29:42
Again, as as mentioned, we're very concerned about vehicle operator safety.
2:29:46
And temperature requirements of OSHA and efforts on the state legislature to pass a temperature control act as well.
2:29:54
So public Republican driver safety must remain a top priority.
2:29:58
We ask that these be considered.
2:30:01
Green vehicles was mentioned well on something that we support.
2:30:05
We believe penalties should be adjusted based on the type of truck with reduced penalties for cleaner, more efficient vehicles.
2:30:12
Such as clean idle vehicles, trucks equipped with regeneration systems.
2:30:16
We've also had members complain about getting ticket violations for trucks that had automatic shut off features as well.
2:30:25
So in conclusion, while the system air complaint program aims to address air quality concerns, it currently does so in a manner that undermines due process, lacks transparency, and unfairly penalizes certain parties.
2:30:37
Insurance 747 and 747 address some of the issues I raised, but do not go far enough.
2:30:43
We believe that with thoughtful reforms, the program can better achieve its environmental goals without unduly burdening the trucking industry.
2:30:50
Thank you.
James F. Gennaro
2:30:51
Thank you, Felise.
2:30:52
Good to see you.
Felice Farber
2:30:53
Good to see you.
James F. Gennaro
2:30:54
Yeah.
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