Dale E. Ballard - Comment

As a 30 year transportation equipment professional, the last 2 years specifically in aerodynamic fuel efficiency devices, it's with great amusement that I read the referenced document. First, you folks wouldn't be so bewildered about why fleets haven't adopted seemingly financially advantageous technologies if anyone in Smartway or Clean Diesel Initiatives would ever return phone calls. Haven't seen it happen yet. Two important points. First, by not addressing the issue of trailers in this rulemaking, you are sidestepping the area where you could actually make a whole lot of progress without wasting a lot of money. While it's not ideal, by adopting the CARB regs and schedules you'd actually be making some real and substantial progress without breaking the bank. Do it. Second, on pages 316-321 you muse about why fleets haven't adopted. I'll tell you. The first devices were really crappy, and the forward looking fleets that bought them felt burned. The companies that put them out cooked up all kinds of snake oil claims for their products, and lost credibility with the fleet managers. The second part of the equation is that usually the purchase decision is made by the fleet maintenance manager, and his primary responsibilty is control of maintenance costs rather than control of fuel cost. If you want to discuss this stuff with someone that has been in front of the largest fleets in the country for the last two years, don't hesitate to reach out to those of us in the industry. Looks like I'm out of time...