TCA Advocacy Efforts Ensure Equipment Stability By Helping Defeat Twin 33 Trailer Legislation
TCA Voices Opposition - February 2, 2017
TCA sent a letter voicing opposition to the the leaders of the House Committee on Transportation and Infrastructure and Subcommittee on Highways and Transit.
Thanks to significant advocacy efforts by TCA, all proposed language in the recent highway funding and appropriations bills supporting federal approval of twin 33-foot trailers on federal-aid highways has been defeated and removed from the bills. This successful advocacy effort will benefit all truckload carriers by ensuring regulatory stability regarding trailer size configurations.
This stability is critical at a time when carriers are already absorbing the costs of regulatory changes related to trailer aerodynamics, safety technologies and brakes, amongst others.
Allowance Becomes Mandate
Given the trucking industry’s experience with previous regulatory-driven changes in trailer configurations, TCA contends that the shipping community would not support equipment that did not accommodate the maximum allowable volume. When our industry experienced the previous conversion from 48-foot to 53-foot trailers, the financial burden was dramatic.
Although the change from 48-foot to 53-foot trailers was originally lauded as voluntary, it rapidly evolved into a de facto mandatory change that fleets were expected to make, with none of the financial burden shared by the shipping community.
TCA contends that a regulatory change allowing twin 33-foot trailers would not go into practice any differently.
Replace, Not Retrofit
Allowing twin 33-foot trailers would require carriers currently operating single 51 to 53-foot trailers, to rapidly switch over to the twin 33-foot configuration in order to remain competitive on a basis of volume per load. Unlike the change from the 48-foot maximum length to the 53-foot maximum length, the change to twin 33-foot trailers could not be accomplished by retrofitting existing equipment, but rather, would require replacement with new equipment.
Negative Capital Impact To Carriers
The abrupt shift to the new trailer configuration would severely distort the trailer market in two key areas. First, the huge excess of suddenly obsolete single trailers would artificially depress the value of these trailers, resulting in huge capital losses for carriers. Second, the rapid increase in demand for the twin 33-foot trailers in a market with fixed production capacity would artificially inflate the price of those trailers, further exacerbating the capital impact on carriers.
Added Operating Costs
While the change to twin 33-foot trailers would provide an incremental increase in cargo volume, that increase in productivity would be more than offset by increased operating costs. A decrease in our industry’s fuel efficiency and increased tire costs are just some of the examples of expenses that we would incur and never be able to recoup.
Driver Shortage Worsened
The change to twin 33-foot trailers would have also had an adverse effect on our shrinking population of professional truck drivers. While the demand from shippers to change equipment would be great, the immediate demand for drivers with the specialized skills and proper license endorsements for twin 33-foot trailers would be far greater.
Already experiencing a growing driver shortage, what would our industry do when faced with drivers who lack the proper training and license endorsements? Fleets would incur expenses of training or retraining drivers to obtain these endorsements, again, a cost that could not be recouped.
Driver Safety Concerns
Operating and assembling a tractor-trailer is physically demanding work and the strain of this work increases greatly with the size of the truck. Although our drivers have weathered many changes over the years, requiring them to break up a set of twin trailers four times on each load and manhandle a 3,000-pound converter-dolly is simply too much to ask. As our workforce ages, the last thing we can afford as an industry is a setback to our efforts to improve the job and enhance our drivers’ quality of life.
Insufficient Truck Parking
As our industry endeavors to comply with myriad regulations while providing customer service on flexible and irregular routes, our drivers must always be able to find places to park and obtain adequate rest. Any changes to trailer length by adding a minimum of ten extra feet will exacerbate an already troublesome truck-parking problem.
The allowance of twin 33-foot trailers will instantly antiquate the vast majority of usable parking spaces that our industry normally reserves for a tractor and its 53-foot trailer, thus creating a parking lot full of trucks that could interfere with the flow of lot traffic.
Evolution, Not Revolution
While TCA strongly supports a thoughtful, evolutionary pace for the development and deployment of productivity innovations that benefit the entire trucking industry, the revolutionary change of allowing twin 33-foot trailers on federal-aid highways would have only benefited a small minority of the trucking industry, while the nature and pace of such a change would have been detrimental to the trucking industry in general, and to the truckload carrier segment specifically.
TCA will continue to advocate for long-term stability in equipment regulations, a realistic and predictable schedule for development and implementation of those regulations, and a balanced distribution of the costs and benefits of those regulations across the entire trucking industry.