Comment Log Display

   Under the current proposal storage trailers that are being
hauled empty to a location to be used as product storage trailers
are required to have "Low-rolling resistance tires".  Would it be
possible to add a "Storage Trailer" category to the submitted
trailer fleet list.  Any trailer found to be on the road with
freight would be out of compliance and a citation could be issued. 
If the trailer is empty and in route to the storage destination or
back to "local-haul base" the trailer would be considered in
compliance.  
Our business supplies several 53' trailers for storage purposes.
The cost of changing all the tires for compliance would be cost
prohibitive while the fuel savings would be minimal.  Not all
storage trailers will be hauled by a designated "Local Haul
Tractor" and therefore under the current (Smartway Rule) proposal
would be out of compliance.

Thank you