methodology to determine percentile scores. They have different safety event groups, so there could be some difference though it is unlikely to be significant. The result was exactly 178 interstate


motor carriers who would fail two BASICs at those thresholds.


STEP 3: REMOVE VIOLATION CODE 391.11 (b) (2) The SFD requires this viola- tion, which deals with English-speaking drivers, be removed from the calculation of percentile scores for the driver fitness BASIC under SFD. The result of removing the violation


code was a remaining total of 67 interstate motor carriers who would be labeled unfit after the three steps are completed and SFD is applied to the industry. Note that 100 per- cent of the carriers removed due to the non- English violation are domiciled in Mexico. Once we analyzed the data and


applied the SFD methodology to the DOT regulated trucking industry over the most recent two-year period, it is clear that Unfit Method 1 of the SFD brings no value in identifying a meaningful number of motor carriers as unfit. SFD identifies exactly 67 interstate


NATURAL GAS Continued from page 19


the major infrastructure requirement of LNG dispensing stations, production plants and transportation facilities. The tank cost to store CNG or LNG


isn’t insignificant by any means. J.B. Hunt Transport has been looking


at natural gas extensively for at least five years and published a white paper “Natural Gas in Transportation” in 2014 on the fea- sibility and growing popularity of alterna- tive fuel sources. The publication states J.B. Hunt is making progress on several fronts to overcome the hurdles slowing down the adoption of natural gas vehicles. “It definitely starts with the econom-


ics,” said Jerrod Mounce, director of fuel management for J.B. Hunt Transport. Mounce explains that diesel is stored


in “two big aluminum cans bolted to the side of the truck, and those cans that hold


36 Issue 3, Fall 2016


FMCSA SHOULD FOCUS ITS EFFORTS ON TRUE CSA REFORM WHERE THE PROGRAM WOULD FULFIL ITS ORIGINAL GOAL OF IDENTIFYING AND DEALING WITH CARRIERS WHO ARE ACTUALLY UNSAFE—BASED ON REAL SCIENCE.


motor carriers as unfit if the SFD were applied to the industry as it existed when our study was conducted. This is a .4 percent improvement above and beyond the 15,000 identified by the current rating system. Does the percentage improvement


justify the proposal?


1. If I weighed 250 pounds and lost .4 per- cent of my weight, I’d weigh 249 pounds.


2. If I ran a marathon in 260 minutes (average time globally in 2014) and improved by .4 percent, I’d run it in 258.9 minutes.


3. If I worked 40 hours a week and was asked to put in an extra .4 percent, I’d


all the energy as a component of that truck’s cost are only a few hundreds dol- lars.” In contrast, Mounce said the expense can be between $20,000 and $60,000 to store liquid or compressed natural gas on the truck. According to Mounce, the economics


will start to make more sense when equip- ment manufacturers—the truck manufac- turers and the fuel tank manufacturers— come together to make the vehicles more affordable. The price of the fuel itself is already


competitive. Goreham said the presence of natural gas and the overall fuel glut in the U.S. is driving prices in a positive direction for consumers. “The good news for the trucking


industry is it means low cost fuel” for at least the near run, Goreham said of the natural gas impact, which will allow com- panies to spend their money on other investments and improvements.


work 40 hours and 9 minutes.


4. If we reduced the headcount of Federal Government employees of 2.7M by .4 percent, we’d still have 2.7M.


Based on this data—and the lack of


benefit—our response to FMCSA’s request for comments was emphatically opposed to the proposed rule. FMCSA should focus its efforts on true CSA reform where the pro- gram would fulfil its original goal of iden- tifying and dealing with carriers who are actually unsafe—based on real science. r


Steve Bryan is founder and CEO of Vigillo, LLC, a data management company specific to the trucking industry.


Count The Ways Why is natural gas becoming popu-


lar? Goreham cites four factors. The first is simple cost. It was just a


few years ago that diesel fuel was selling for $3.50 to $4 a gallon while a gallon of natu- ral gas was priced around $1.50. “We went through a couple years


when the price of natural gas was very low and the price of petroleum was high,” Goreham said. That led people to consider comparatively cheaper natural gas as an alternative. Second, while he says it is not neces-


sarily a sustainable energy source, Goreham said natural gas’ popularity is also enhanced by its reputation as a cleaner fuel.


“[There is] a lot of public relations


that natural gas is a cleaner fuel, and in part, that’s true,” Goreham said. He explained that natural gas con-


tains low levels of EPA “criteria pollutants”


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