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Our company is a short haul truckload carrier that has serviced the
State of California only for 63 years. With inventories being
managed and JIT (Just In Time) deliveries being the norm,
we now have over 3 trailers for every one power unit. These
trailers are used as a "mobile" warehouses while the customer
unloads the trailers over a period of days. Sometimes these
trailers make only one or two trips per week. While our industry
supports emissions reduction, the cost burden of replacing power
units and retrofitting the trailers simultaneously is a cost that
cannot be justified. Our trailers do not travel enough miles to
justify a savings in fuel because of their limited time on the
road. Safeway, Raleys, Savemart and some many others that have
excess trailing equipment will be unfairly burdened by a cost that
cannot be justified. If the law is to have new trailers be
manufactured with Smartway technology, we would support that. But
to have to retrofit older trailers with 
these aerodynamic devices is not a prudent business decision.
Thank you and I would appreciate your consideration.
Regards,
John Yandell
Yandell Truckaway, Inc.
Oakland, CA.