First Name | Ron |
---|---|
Last Name | Hall |
Email Address | ronh@crengland.com |
Affiliation | C.R. England, Inc. |
Subject | C.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 Name | CARB 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.