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Comment 10 for Greenhouse Gas Heavy Duty Vehicles (SmartWay) (ghghdv08) - 15-1.

First NameRandal
Last NameMullett
Email Addressmullett.randy@con-way.com
AffiliationCon-way, Inc
SubjectComments to GHGHDV08
Comment
Clerk of the Board
Air Resources Board
1001 I Street
Sacramento, CA  95814

October 1, 2009

COMMENTS RE: MODIFIED REGULATORY LANGUAGE OF THE CALIFORNIA CODE
OF REGULATIONS, TITLE 17, SECTIONS 95300-95311

The following comments are being submitted on behalf of Con-way,
Inc. in response to the modified regulatory language for public
comment pertaining to the regulation to reduce greenhouse gas
emissions from heavy-duty vehicles.

Con-way, Inc. is a $4.7 billion freight transportation and
logistics services company headquartered in San Mateo, CA.  Con-way
companies operating in CA include Con-way Freight, Con-way
Truckload, and Menlo Worldwide.  These operating units provide
high-performance, day-definite less-than-truckload (LTL), full
truckload and intermodal freight transportation; as well as
logistics, warehousing and supply chain management services. 
Con-way Inc. and its subsidiaries employ over 2000 people in CA
operating from 42 locations throughout the state.

Con-way operates equipment in California that is subject to these
regulations and we are pleased with many of the modifications made
to the regulatory language.  We do, however, have several
concerns:

1.	 It is our understanding that trailer requirements have been
modified to split the 5% required aerodynamic improvement from the
low-rolling-resistance tire requirement of 1.5% into two parts
wherein neither improvement can be counted toward the other. 
Please clarify that this interpretation is accurate.

2.	We request that the modified language include confirmation that
low-rolling-resistance tires that have been recapped are in
compliance so long as the tire casing originally qualified as a LRR
tire.

3.	The rule seems to have conflicting definitions of short-haul
tractors; those that operate less than 50,000 miles annually as
well as those that operate within a 100 mile radius.  Federal DOT
regulations for maintaining duty-logs specify a 100 air-mile
radius.  This is already well established within the trucking
industry and the enforcement community.  We request that the
modified language specify that tractors qualify as “short haul” if
they meet either of these requirements and that the 100 mile radius
conform with the Federal statute as air miles.

4.	We agree with the deletion or the requirement to provide a copy
of each trailer’s registration.

5.	Lastly, it is our interpretation that Subsection 95303 (b) now
states that trailers no longer have to adopt trailer skirts, nose
cones or boat tails as the only approved technology for improving
fuel savings by the required 5% and that any combination of EPA
SmartWay technologies achieving that goal will qualify the trailer
as CARB compliant. Please clarify this interpretation in the
modified language.


Respectfully submitted,

C. Randal Mullett
Vice President Government Relations
Con-way, Inc
2855 Campus Drive
San Mateo, CA  94403



Attachment www.arb.ca.gov/lists/ghghdv08/217-comments_1_.10.01.09.doc
Original File NameComments[1].10.01.09.doc
Date and Time Comment Was Submitted 2009-10-02 13:43:53

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


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