Letters: ELDs and Fleet Size, Innovation Needed

ELDs and Fleet Size

The last paragraph of the story “ELD Comments Pour Into FMCSA; Support Splits Along Carrier Size” incorrectly referenced comments I filed on behalf of five companies located in Pleasant Prairie, Wisconsin, and engaged in truck-transport operations via saddle-mounted vehicle transporter combinations.

Besides oversimplifying the driveaway business segment of the transportation industry, it said that “the truck actually being driven should have an ELD, but the empty vehicles being pulled as freight should not.” This is false.

To quote the second paragraph of the comments I filed with FMCSA: “Due to the unique nature of driveaway operations, and the resulting fact that there are requirements of the proposed rule that driveaway operations cannot comply with, we respectfully request that this Proposed Rule be amended to provide an exception for the mandated use of ELDs in driveaway operations.”

I then went on to detail several aspects of the driveaway business segment that would make complying with specific portions of the proposed rule almost impossible. In driveaway operations, the vehicle being driven is also the commodity being delivered. We drive it once, from its point of origin to its destination, and we never see that vehicle again. We do not own it, we are not leasing nor renting it, and we are expected to deliver it in the exact same condition as when we received it. These conditions of truck transport make the mandated use of an ELD problematic.

Nowhere in my comments did I say or suggest that an ELD should be in the driven vehicle of a saddle-mount combination, and the notion that an ELD would be required in the saddle-mounted trucks of a combination is ludicrous on its face, and there would be no need to comment on it.

Mahlon Gragen

Director of Safety and Compliance

ATC Transportation

Innovation Needed

The freight transportation system in the United States is at capacity with no room for traditional expansion. More than ever, affected communities are raising their voices to protest the paradigm that has sickened our environment with toxic air and freight congestion.

However, with this reality also comes great opportunity — the opportunity for innovative solutions to bring about change on

various levels, including social, economic and environmental. These solutions will need to increase port productivity and environmental awareness at the same time. These innovations will bring the United States to the forefront of freight innovation with projects increasing economic prosperity through international trade, while creating jobs and reducing the carbon footprint of the industry.

Pressure is growing on the private sector to take measures that will reduce their footprint. More often than not, these measures also bring increased costs and lost productivity.

However, it does not have to be this way. By taking initiative and incorporating clean technologies that are already proven and available, companies can take charge of their own destiny.

Innovation is not just the creation of new technologies, it can also be the reconfiguration of existing systems to bring about new efficiencies.

Companies must prepare for the inevitable transition to efficient and clean freight transportation by creating the opportunity to profit from business innovation. As the volume of freight in my home city of Los Angeles is expected to triple by 2035, those involved within the industry will need to address looming issues across many sectors that will drastically affect not only their business operations, but also the freight corridor communities disproportionately.

This situation will continue to worsen if innovative solutions are not implemented to move freight cleanly and efficiently, beyond the traditional paradigm that has proliferated for the past 50 years.

The time is now for sustainability to become the culture in freight movement. By offering solutions that profit from environmental awareness, businesses may not only achieve increased bottom-line results, but also improve their public perception as environmental business innovators. Moving freight in a more sustainable direction is good not only for business, but also for national and international competitiveness.

Sherwood Egbert

Vice President of Business

Development

GRID Logistics Inc.

Los Angeles