Comment Log Display

- As a result of the Green House Gas (Smartway) proposal, we are
delaying the purchase of new trailers.
- While only 5% of our trailer fleet (25units) is 53', we had
planned on replacing a number of the older smaller trailers with
53' to increase effciencies.  The efficiencies I speak of are in
reduced trips by carrying more product on fewer trailers.  On a
quarterly review of onw of our divisions we can reduce the number
of loads by 1,000 which saves 281,000 miles and 37,492 gallons of
fuel or 149,968 gallons a year.
- Under the proposed regulation, 53' trailers will not work in our
environment.  Dise fairings will not allow us to get into many of
the pits at our stores without substantial damage to the fairings. 
The estiamted additional cost of these Smartway trailers will not
be offsett by added fuel savings as has been suggested.  Smartway
fuel savings are calculated on an average speed of 62 mph.  The
legal speed in CA is 55 mph and our average fleet speed is 45.7 mph
based on on board computers
-  Our company has a very aggresive fuel savings program not only
to benefit the environmebnt but also to help offsett expenses.  WE
govern the top speed of all tracctors to the legal limit in CA.  We
monitor and enforce minimal idling, long before it was mandated. 
We spec cruise control on our equipment and encourage its use.  We
continually test new tire designs for fuel economy and longevity.
-  I encourage the Board to seriously consideer voting against
this regulation as it will not achieve the fuel savings and cost
offsetts as proposed for trucks operating in CA.  Thanks you for
your consideration of this.