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 of the 

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 truck just over 752,000 miles over nearly 7 years. Over the 

lifetime of the 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 of this 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 of that 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 of technology 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 for the duration of my time on the 
road. 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 for the costs of these 

mandates. 

Small business truckers cannot afford for this pattern to continue. With 

years of experiences dealing with unplanned maintenance and repairs such 

as those just previously mentioned, there is a great deal of skepticism in 

promises of technology 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 for technology which is largely in use today 

there are still concerns to be recognized. 

If the 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 due to my driving 

skills. If those skills were taught to others, fuel economy would improve. 

Highway congestion is another under-addressed, proven waste of fuel 

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 of the new 

technology. 

Small business truckers that purchase this equipment to start up will be 

challenged to exist if this 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.