| Comment | I would again ask that the Board consider increasing the Short Haul
Exemption to mirror the DOT to 150 mile radius versus the 100 mile
radius as stated and or consider that trailers hauled by tractors
that return to their local haul base within a 24 hour period are
exempt form the rule. As a short haul/regional with excess trailing
equipment (3 trailers for every 1 tractor), there is no return on
investment or fuel savings due to the limited miles hauled. Our
tracking devices will support that our average miles per hour per
day are approximately 45 mph. This GHG rule for the 53' trailers
coupled with simultaneously complying with the Truck Bus Rule is
impossible in today's economic climate.
Your amending this regulation is imperative for our continued
operation.
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