Hello, my name is Tilden Curl. I'm an Independent Owner/Operator from Olympia, WA currently nearing 25 years as a truck driver with over 2 million safe miles

. I'm a life member of OOIDA and I'm here to help others understand the challenges truck drivers face

. I want to thank you for this opportunity to speak to you today. As we look ahead to successfully preserve our environment, I would like to take a moment to look back at where we came from and where we are now
. To do this, I have assembled some figures from my own business records over the past 18 years
. I purchased a 1995 pre-emissions Peterbilt in 1998 for about $65,000. I operated that truck for just over a million miles. Over the lifetime ofthe Peterbilt I invested just short of $95,000 in maintenance and repairs, including an engine rebuild and transmission replacement. The last full year of operation I averaged 6.58 mpg
. from that very Non-Aerodynamic body style

. In October of 2008 I traded the Peterbilt in for a new aerodynamic and emissions compliant 2009 Kenworth that had a purchase price of$140,000

. I operated that truckjust over 752,000 miles over nearly 7 years
. Over the lifetime ofthe Kenworth , I invested just short of $105,000 in maintenance and repairs

. That does not include the $6000 extended warranty on the emissions systems or the covered repairs during that time, not to mention the impact to my income or my reputation for reliability which was caused by the unscheduled downtime

. During my ownership ofthis truck the fuel economy dropped from 6

.62 mpg to only 6

.15 mpg in the first 6 months of 2015

. In 2014, I invested nearly $15,000 in repairs

. In the last 4 months of ownership, I invested just shy of$10,000 in repairs related to the emissions system

. It became very clear that ownership ofthat technology was no longer cost effective for my business. The technology did not have enough durability to achieve a reasonable return on investment in a real world application

. Claims oftechnology paying for itself in a few years were extremely over estimated. It became evident that it was less expensive to purchase a new truck even though it only had 752,000 miles on it. The new replacement truck, a 2016 model Kenworth of like features cost $167,000

. I had originally planned to pay the 2009 off and apply the payment amount toward my retirement forthe duration of my time on theroad

. As I see it, these regulations, and a rush to push technology beyond tested capabilities, have cost me my retirement. There is no mechanism in place to compensate small business truckers forthe costs ofthese mandates

. Small business truckers cannot afford for this pattern to continue. With years of experiences dealing with unplanned maintenance and repairs such as thosejust previously mentioned, there is a great deal of skepticism in promises oftechnology that will not cost much more and ultimately provide a savings. With this broad background of experiences from small business truckers such as myself, many find it hard to believe that a mandate from EPAINHTSA will truly benefit them. While the agencies proposal of Alternative 3 mostly pushes fortechnology which is largely in use today there are still concerns to be recognized. Ifthe agencies pursue Alternative 4 there are many more concerns about again thrusting unproven technology into the marketplace. This would result in more truckers choosing to keep their current trucks on the road even longer

. I want to stress, the agencies approach must allow for ample time for the OEMs to develop the new technology

. There are other un-mandated alternatives to achieve good fuel economy. My pre-emissions truck worked more efficiently partly dueto my driving skills

. Ifthose skills were taught to others, fuel economy would improve. Highway congestion is another under-addressed, proven waste offuel every year. I estimate that in one day of a recent trip I burned an extra 10 gallons of fuel do to congestion

. The point being, these two suggestions do not involve concerns of unproven technology or unknown costs ofthe new technology. Small business truckers that purchase this equipment to start up will be challenged to exist ifthis regulation proceeds without a reality check. The agencies are seemingly using facts they prefer with little regard for the actual burdens it places on small business operations. Technology must have durability

. That is crucial for success. We all want a clean environment. The question is, "Is your focus in the right place?" I welcome any questions you may have

. Thank you.