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Comment 109 for Greenhouse Gas Heavy Duty Vehicles (SmartWay) (ghghdv08) - 45 Day.

First NameRon
Last NameHall
Email Addressronh@crengland.com
AffiliationC.R. England, Inc.
SubjectC.R. England comments on the Private Fleet Rule and the SmartWay Regulation
Comment
December 10, 2008

To:  California Air Resources Board

C.R. England comments on the Private Fleet Rule and the SmartWay
Regulation


Hello, my name is Ron Hall.  I am the Director of Business
Strategy for C.R. England, the largest refrigerated carrier in the
nation, and Transport Topics 36th largest for-hire carrier.  Before
providing an opinion, I’d like to mention that C.R. England is
currently a SmartWay Certified Partner, with the maximum compliance
score of 1.25.  We are committed to reviewing and implementing new
technologies as a core strategy for fuel efficiency management, as
evidenced by our recent purchase of planning optimization software
for deadhead reduction and un-tethered trailer tracking and control
for reefer fuel management.  

Thank you for giving me the opportunity to comment on both the
Private Fleet Rule and the Smartway Regulation.  As a statement of
position, C.R. England is opposed to both regulations.  We fully
support the written statements submitted by the California Trucking
Association on October 3rd and December 4th that challenge CARBs
assumptions on both proposed regulations.  Of particular concern
for us, are the implementation and maintenance costs of the
required equipment modifications and the full fleet implementation
that will be required for fleets that operate only partially in
California.

CARB is assuming that fleets operating occasionally in California
will be able to segregate their equipment, both tractor and
trailer, and install upgrades to only that subset.  That assumption
is flawed for several reasons.  First, the freight destined for
California (because of the size of it’s economy) originates out of
virtually every part of the nation.  To position tractor and
trailer equipment with the necessary density and dispersion so
equipment is available at origin for California destined loads
would require full fleet implementation.

Second, trans-loading at the California border onto certified
equipment is not an option, especially with loads consisting of
food products, because the seal requirements many customers now
have does not allow carriers to open the load until it arrives at
destination.  Even if seal requirements were not an issue, the
trans-load expense and exposure to claim from temperature variation
or damaged cases would make this option unfeasible.

Finally, even if equipment could be positioned in advance, the
lack of isolated trailer pools in most one-way trucking
applications prohibits reserving certified equipment for California
destined loads.  In many trailer pool locations, carriers rely on
customer loading processes, third party loading services and driver
decisions to determine which load ends up on which trailer.  Those
decisions are often difficult for the carrier to control, resulting
in the probability that a portion of the California destined loads
will end up on non-certified equipment.

In summary, these regulations, as proposed, have impacts that
reach much farther than just California state borders.  Fleets with
partial activity in California will be faced with full fleet
implementations of these requirements if they wish to continue to
operate in California.  To recover costs, it’s feasible that some
fleets could start implementing a “California Surcharge” that will
result in higher costs of goods to California consumers.  We urge
CARB to consider the farther reaching impact of these regulations
for carriers that operate only partially in California.  Again,
thank you for giving me the opportunity to comment on behalf of
C.R. England.

Sincerely,


Ron E. Hall, Director of Business Strategy
C.R. England, Inc.
4701 West  2100 South
Salt Lake City, Utah  84120

Attachment www.arb.ca.gov/lists/truckbus08/831-carb_statement.doc
Original File NameCARB Statement.doc
Date and Time Comment Was Submitted 2008-12-10 08:26:53

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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