Statement of
Brian L. Fielkow
President
Jetco Delivery, LLC
Before the Federal Maritime Commission
At The
Gulf Coast Port Congestion Forum
New Orleans, LA

November 3, 2014


Thank you Commissioner Dye for the opportunity to participate in this relevant
and important Forum. International Supply Chain Efficiency: Challenges facing
Gulf Coast Ports is a critical topic not only for the International shipping
community but also worldwide commerce. Projections have been widely
publicized that future growth of the world’s chemical production will focus on the
Gulf Coast region. The reason is quite simple, economical and abundant energy.
The challenges to succeed with transporting these new products are many and
vast; labor, environment, political regulation, infrastructure, just to name a few.

This being the fourth and final forum many comments have been filed with varied
perspectives by industry experts across the intermodal spectrum. Topics such as
terminal congestion, vessel bunching, infrastructure, driver shortages, chassis
ownership and management are just a few that is relevant to my industry,
intermodal trucking. While | could speak for hours on end about these and other
troubling issues we have been asked to discuss innovative ways to:

Prevent port congestion
Promote global trade
Increase International supply chain efficiency

Some of my comments may present new ideas, most will probably not. My
forthcoming comments like many in the preceding forums have been
communicated for MANY years by industry stakeholders with little or no
advancement. By definition, Intermodal Transportation, involves multiple modes
of transportation; ship, rail, and truck. Even in its definition, truck, is last. In my
speech, | will take the privilege of putting the “truck” first.

As background to my thoughts, | am a third generation trucker. My family’s
business started in 1945 in New Orleans and today is one of the oldest trucking
companies still owned in Louisiana. We employ teamster union drivers paid by
the hour. Our second trucking company utilizes independent contractors and



provider. The job should not be pushed onto the drivers to go
to M&R thus causing driver delay.

The second choice is to wait until a driver shows up who is
turning in a pool chassis. Those delays can be lengthy. Again,
that is time that a driver does not get compensated for and
further frustrates drivers.

4. Infrastructure — “No new taxes” is irresponsible when it comes to
developing a vibrant multimodal infrastructure. This is particularly
important in a state like Texas, which is benefitting from rapid
growth. | support increasing and indexing the fuel tax as the most
equitable means of building and improving our roads. We also need
to think long term about our needs. We can no longer wait for
highway funds to run out, pass an emergency funding bill and then
ignore the issues until funds run out again. This is a long term
national issue and must be treated as such, without partisan political
concerns.

5. Safety and regulations — Let me be clear — | believe that nothing is
more important than safe operations. No load is more important
than the safety of the public and my employees. However, we must
come to the realization that a flood of unnecessary regulations will
not automatically make us safer.

a. | recommend that the FMCSA devote some of its resources to
helping trucking companies institute behavior-based safety
programs. Many companies desire to improve and simply need
the tools.

b. The new hours of service rules (effective 07/2013) have

adversely impacted production without any measurable impact



As a former trade negotiator and U.S. trade official, | know that the
United States does a lot of things very well in terms of successfully
advancing open markets. But with more and more of the world’s
goods and services moving in international commerce, we clearly
have work to do if we want to be in top competitive form in an
increasingly highly competitive world.

How do we begin to do this, and where does this work start?

| might suggest, Commissioner Dye and colleagues, that we start with
this forum, but recognize that this is only a start— we should take the
insights and guidance developed here and use them as a baseline,
that is, we should broaden and deepen the conversation started here,
and carry it forward throughout this coming year, and the years after
that, especially in light of the major trade policy developments on the
horizon, such as the prospect of a successfully completed Trans-
Pacific Partnership regional trade agreement.

As we know, a successfully concluded TPP agreement may, at some
point, become more than a regional trade arrangement for the current
12 nations participating in the talks. The TPP may become a platform
for a broader, hopefully even more comprehensive, regional

economic cooperation regime.

By itself, a successfully concluded TPP agreement will likely present
new challenges and opportunities for the United States, and for the



Commissioner Dye, | want to thank you for the opportunity you have
given us to discuss issues impacting the port drayage industry today.

My name is Brian L. Fielkow. | am the president of Jetco Delivery, LLC,
based in Houston, TX. Jetco has been in business since 1976 and |
purchased the business in 2006. We operate approximately 100 trucks.
Our fleet is about 70% company-owned and 30% owner operator.

In addition to owning Jetco, | also speak across the country about
company culture. When | speak to high consequence industries, | focus
on behavior-based safety and safety culture as the best means to prevent
and reduce accidents. This year, | published Driving to Perfection:
Achieving Business Excellence By Creating A Vibrant Culture.

| am chairperson of the Texas Trucking Association (TXTA) Intermodal
Committee. In this role, | work closely with the port, trucking companies
and other key stakeholders. My comments today however are my own
and have not necessarily been endorsed by TXTA.

1. Collaboration — In Houston, the trucking industry and the port are
fortunate to share an excellent relationship. We speak often and
hold a quarterly “open-line” conference call so that issues and
opportunities may be addressed. Creating open lines of
communication is the first and only way to begin to properly address
the issues that affect all of us.

2. Driver Shortage — This is the most important issue affecting our
industry. Attracting new drivers into port drayage is particularly
difficult. In my view, here are the most significant issues affecting
our drivers:

a. Non-compensable activities — From the time spent looking for
suitable pool chassis to paperwork delays to gate delays



resolution to immigration reform. The communities being
forced to unfairly live in the shadows of our society should be
granted a pathway to citizenship and opportunity. Third, if an
individual commits a crime, he/she is punished appropriately;
yet the punishment continues long after release from
incarceration. Often, we cannot hire from the penal system
due to insurance concerns or due to litigation fears of that
person being involved in an accident.

3. The chassis situation — Most steamship lines migrated to a “trucker
choice” chassis model. This means that the trucker pays for the
chassis. In theory, the trucking company should be able to arrive at
the port with any chassis to pick up any container. It doesn’t always

work this way.

a. If a steamship line has stopped providing chassis, they must no
longer have the ability to dictate which chassis provider that
the trucking company must use. Terminating one 40’ chassis
for another is an example of non-compensable, wasted effort.

b. | firmly support the development of a gray chassis pool. The
“Gray Pool” model can be beneficial and help with port
congestion. If a provider does not have enough chassis to cover
all of a line’s containers who are still providing chassis, this
could mean delays for drivers.

Where shortages of chassis exist, the drivers have the following
options. One option is to get a red tagged chassis if no good
order chassis’ are available. The driver must spend time getting
repairs done before they can exit the port. Red tagged chassis
and timely repairs should be the responsibility of the chassis



| have asked for additional ingress/egress routes — to no avail. If International
Commerce is as important as this City, State, and Nation has stated, make the
commitment to support the infrastructure we so desperately need.

Commissioner Dye, thank you very much for allowing me to communicate issues
that are so critical to the Intermodal Industry of the Gulf South.



authorities and politicians about the introduction of “big ships” after the Panama
Canal expansion. That can’t happen without critical infrastructure development,
starting with the ports.

Terminal Operators need to invest in container handling equipment to ensure
they can grow their operations to eliminate congestion and empty container
rejection. They also need to invest in necessary resources to timely repair chassis
in terminals that are perceived to have more equipment out of service than in
service. Terminals cannot simply rely on solutions such as Pier pass, which have
only pushed gate congestion at facilities to peak periods. Equipment investment
needs to be considered in order to ease congestion and to keep the terminals
fluid.

Motor Carriers need to invest in their drivers to ensure there is a future for
drayage and inland trucking. Motor carriers also need to invest in equipment and
taking responsibility for chassis in line with the model followed elsewhere in the
world. The owner operator has been squeezed for years on rates to a point where
the driver living wage is unsustainable. The driver population average age has
grown from 41 to 55 over the last decade. This trend is obviously unsustainable
and the entire supply chain needs some corrective action taken.

Shippers (NVOCCs and BCOs) need to invest in the service levels they demand.
Shippers are demanding the best service, while driving rates down. Cargo is
compressed into seasonal windows, straining peak capacity. Warehousing hours
do not meet the demand of cargo surges, so shippers are holding equipment and
asking for more free time. Carriers are usually willing to grant the additional free
time to secure the business, but this just contributes further to the equipment
shortages. The cycle of service demands and rate erosion is not stable.

Railroads & TIX need to invest in equipment and infrastructure and also look at
operational practices that add to the congestion and equipment shortages. For
example, the wheeled chassis operation required by railroads to minimize
operational costs has a negative impact on already over utilized chassis capacity.
Also, there is insufficient rail car supply in the network, causing rail car shortages
and delays throughout the network. While railroads want to protect their



The availability and quality of inland transport of cargo is such an
enormous factor affecting trade growth through our ports.

This is not just a Gulf port problem, it is a national problem.

Some reports indicate that we have 30,000 fewer truck drivers than
we need. The American Trucking Association expects the estimated
U.S. truck shortage to swell to 239,000 by 2022.

The costs associated with insufficient truck capacity cascade
throughout the steel supply chain: there are increases in port
charges, costs associated with the delay in delivering the cargo to the
final customer, such as interest costs due to invoicing and payment
delays, and, of course, disgruntled customers and their costs for
delayed production.

It is practical issues such as this that help explain how the United
States ends up with an overall Logistics Performance Index score of
14, an ease of shipment score of 20, and an even worse LPI ranking

of 144 out of 150 for domestic logistics costs.

The good news is that this and related issues are not intractable
problems. We know that things like improved transportation
capability, human capital improvements like upgrading manpower
skills, and innovation like new information and communication
technology, all facilitate the movement of trade through our ports.



Gulf region, given the enormous significance of our Gulf region ports
to our export and import -dependent economy.

The new trade relationships and trade patterns that would flow from a
broader TPP-based trade platform would likely have even more
significant consequences for the economy of the Gulf region, and we
should start to think now about and prepare for these developments
by taking a clear, hard look at the Gulf region’s trade-related
infrastructure, our Customs procedures, our supply chain logistics
services and performance, the availability and the quality of transport
services, and the other factors addressed by the World Bank study—
and by other international and domestic entities.

One of the reasons | would suggest the World Bank’s analytic
framework is so useful is because it does something suggested in a
2012 World Economic Forum analysis of the logistics and supply
chain industry—it “unpacks” the sources of potential supply chain
costs, and allow us to target them as areas that will yield immediate

improvement.

Here | would like to focus on practical issues and discuss briefly one
of the supply chain costs adversely affecting our regional and national
competitiveness: the lack of sufficient truck availability to either catch
cargo in direct discharge, or to catch cargo for movement to a
temporary storage facility within a port.





Thank you Commissioner Dye for the opportunity to address the FMC on
international supply chain efficiency, port congestion issues and industry
challenges that all stakeholders are wrestling with in today’s logistics supply
chain. | am Jim Michalski VP of Inland Operations at CMA CGM (America)
domiciled in Norfolk, Virginia.

My entire career has been within this industry and | have seen my fair share of
operational challenges. After spending nearly 25 years on the ocean carrier side
of the transportation industry, nothing has quite prepared me for the challenges
we are facing today. As everyone here knows, the smallest bit of congestion at
the port has a trickledown effect throughout the intermodal chain. Even brief
periods of congestion can lead to days or weeks of recovery. With the sustained
congestion we have seen this year, the supply chain is seriously at risk of grinding
to a halt which will impact our economy. | think all of the stakeholders here today
know that I’m not exaggerating or being melodramatic when | say that the
challenges we are discussing today have reached crisis level.

| have followed the previous port congestion forums with great interest, and |
appreciate Commissioner Dye and the other commissioners providing these
opportunities for public discussion. Unfortunately, it seems to me that at the
previous meetings many stakeholders have been too anxious about their own
point of view and not working collaboratively with other stakeholders. To quote
Pogo: “we have met the enemy and the enemy is us,” all of us. We need to stop
working against each other for our own interest and come together on solutions.
| recognize that each stakeholder here today has competing priorities; but at the
same time, | hope we can agree that we each need to make a profit in order to
build infrastructure and reinvest in our individual organizations for sustainability.

With that in mind, I’d like to highlight a few areas where | think investment is the
key to resolving the current crisis.

Port Authorities need to invest into capital infrastructure to ensure competitive
capabilities and to develop jobs in each of their states. The large capital
investments necessary to develop facilities have been slow to develop and are
currently behind the industry demands. We hear a lot from East Coast port


on safety. | support proposals to suspend the new HOS rules
and replace them with the rules which were previously in effect
until a rational review can be completed.

. When we pull containerized cargo, the driver does not have the
ability to inspect the cargo unless he/she breaks the door seal.
There are legal implications to breaking a seal. Shippers and
their domestic agents must be held to high standards when
packing cargo for import or export. The consequences of a load
shift can be devastating.

. Some jurisdictions allow drayage companies to pull heavy
containers (GVW>80,000 pounds). Others, such as mine, limit
weights to 80,000 pounds (84,000 pounds with permit and no
interstate travel). | see both sides of the argument. Where
heavy container debate does occur, please keep the following
in mind:

i. Proper number of chassis axles to accommodate weight
ii. Fairly priced permits to pay for wear and tear on the roads
iii. Driver training — hauling 100,000 pounds is much different
than hauling 80,000 pounds (brake time, etc.)

Heavy containers may have tremendous benefit by allowing
shippers to increase payloads. Theoretically, we can haul more
cargo with fewer drivers. That said, safety concerns must be
paramount in the decision making process.



Remarks of Richard Chriss, Executive Director of the American
Institute for International Steel

At the

Federal Maritime Commission Forum on International Supply Chain
Efficiency and Effectiveness: Challenges Facing Gulf Coast Ports

Port of New Orleans
November 3, 2014

| would like to thank the Federal Maritime Commission, and
particularly Commissioner Dye, for convening this important public

forum.

I very much appreciate the invitation to participate, and to engage in a
broad discussion of ideas.

With that, | would like to briefly introduce myself. | am currently
completing my first year as the head of the American Institute for
International Steel. Prior joining the AIlS, | served for six years as
Assistant General Counsel and Chief Agriculture Counsel with the
Office of the United States Trade Representative, where | had the
honor to represent the United States in various trade negotiations
around the world, at the World Trade Organization in Geneva, and
elsewhere. | also served as Senior Counsel to the Under Secretary
for International Trade at the U.S. Department of Commerce, and as
an International Trade Counsel for the U.S. Senate Committee on

Finance.


that equipment can be managed more efficiently by other stakeholders who are
in a better position to maximize efficiencies.

None of these issues are new to the industry, but they are exacerbated by the
volume growth in the industry. I do not pretend to think that these comments
are all inclusive for each of the stakeholders, but | do hope that | have identified
some of the competing challenges and areas where we can reach common
ground and stop working in different directions. Until we as an industry identify a
common path and accept that we all need to take responsibility for a financial
piece of the solution, this cyclical nature of congestion will persist and only get
worse. | recommend an industry wide CEO level task force encompassing all
stakeholders be formed to address the issues and work toward a common
industry solution. We all know the challenges and have the power to influence
the solution, but no one of us can solve it separately.

Thank you again for your time and opportunity to discuss solutions for change.



individual interests, over usage of rail cars by one company to protect its interest
against competitors has a negative effect on supply throughout the industry.

Chassis Management & Leasing Companies need to invest in an ageing fleet in
new equipment and the resources needed to timely repair equipment, as well as

to reposition equipment from surplus locations. Depots are holding chassis that
could be deployed to mitigate chassis shortages in other areas. Again, this simply
exacerbates to the problem.

USMX/ILA/PMA/ILWU - Cyclical availability in the workforce and stronger internal
leadership in each organization is required to meet the demands of the industry. |
applaud what has been done by USMX and ILA to increase the workforce in NYNJ,
including the ILA effort this year to limit vacations in the North East to meet the
demand of peak freight. Labor availability has notably improved over 2013, but
these initiatives need to be formalized in an agreement with PMA and USMX to
ensure the industry is provided with the consistent, skilled and efficient labor
force for the long term. Certainty of labor supply plays an important role in the
confidence of shippers and carriers alike.

Last, but not least,

Ocean Carriers need to invest in larger ships to take advantage of the economies
of scale needed to provide superior service at a competitive price. At the same
time, we need to exercise restraint in pricing to ensure that service levels are not
eroded by declining rates. Right now, carriers are barely afloat, losing money as
an industry year after year. To mitigate the bleeding, the carrier industry has
adopted a slow steaming policy. This mean when vessels are delayed due to port
congestion, it is cost prohibitive to spend the money to make up time.

Carriers also need to play our role in equipment investment by ensuring a strong
supply of containers, including specialized containers, and we need to invest our
time and efforts into finding a solution for container imbalances so that the
containers are not only available, but available where we need them. At the same
time, carriers must continue to push for a move out of the chassis business so



We look forward to addressing these and related concerns with the
Commission in the future, and to being part of the solution.

On behalf of the AIIS and our extraordinary member companies,
organizations, individuals, and partners, thank you again for the honor
to contribute to this public forum.



(measured from the time a driver arrives in line to the time
he/she exits), drayage drivers spend a lot of time in non-
compensable activities. As an industry, we must be sure our
drivers are compensated for all activities and that the
appropriate parties are charged.

. Hours — Often, local port drayage drivers have more legal
driving hours available than port and warehouses are open. In
Houston, working with our port, gate hours will be extended by
1 hour per weekday at two key container terminals, starting on
November 17, 2014. This seemingly simple change adds 10
hours per week of production opportunity. If this change is
successful, it paves the way for additional expansion of the
workday. Now, it is incumbent that chassis providers,
steamship lines and shipper/consignees extend their workdays
to leverage this change.

. Treatment — It upsets me when one of our drivers says “I’m just
a truck driver.” In reality, drivers are the backbone of our
economy. Without them, nothing moves. While our industry
bears primary responsibility for attracting qualified drivers, we
could use help. Everywhere we look drivers are hit with
difficult challenges — paperwork issues, new regulations,
roadside inspections, chassis problems. While some of this is
unavoidable, we as a country must show our appreciation for
and attract new drivers to this noble calling.

. Immediate new sources — | suggest looking at the areas that
could solve the driver shortage. First, identify and eliminate all
barriers to qualified military personnel from driving after

discharge. Second, it is time for a serious discussion and



based on six key dimensions to demonstrate comparative

performance in logistics.
The six criteria in the Logistics Performance Index are:

1) Efficiency of the clearance process (i.e., speed, simplicity and
predictability of formalities) by border control agencies, including
customs;

2) Quality of trade and transport related infrastructure (e.g., ports,
railroads, roads, and information technology);

3) Ease of arranging competitively priced shipments;

4) Competence and quality of logistics services (e.g., transport
operators, customs brokers);

5) Ability to track and trace consignments;

6) Timeliness of shipments in reaching destination within the
scheduled or expected delivery time.

Let’s take a look at how the United States fared in this analysis:

Overall, the United States ranked 14" in in logistics performance,
behind countries like Denmark, Belgium, the United Kingdom, Japan,
Germany, Canada, and Ireland.

In ease of Customs clearance, the United States ranked 19", in ease
of shipment, 20", in logistics services, we ranked 14", in timeliness of
shipments we ranked 18", and in domestic logistics costs, we ranked
a dismal 144" out of 150 countries.


could be described as one of the largest serving the Port of New Orleans. Being
in the business all of my life, | am probably biased but maybe, just maybe these
suggestions forthcoming can be viewed as coming from a “realist”.

Please accept these comments in the spirit intended; open, honest, and with
respect to other involved stakeholders who may receive negative attention.
While most examples used today will involve the Port of New Orleans, my home,
these examples are also true for the vast majority of Ports across America.
Chassis management and utilization, Port congestion, and infrastructure are the
topics I'll present today. Problems and solutions offered together.

First, chassis management and utilization is a topic weighing heavily across all
regions. The United States is trying to evolve from a steamship owned and
controlled system unique to only the U.S. to one preferred in the rest of the
World where motor carriers provide chassis. The problem is, the steamship
industry won’t “get out of the way”. As they are departing, or trying to, they are
also dictating the terms of the transition. In most circumstances, the ocean lines
are negotiating terms of chassis sales and future leasing arrangements. While in
principle this may seem appropriate, in reality the terms in my opinion are
criminal. Trucking companies are being forced to use chassis providers dictated
by the ocean line and overcharged while doing so. Concessions are given to the
ocean carrier that negotiated the deal in exchange for the lease revenue
generated. Open choice is not an option, free marketplace does not exist. Motor
carriers and the shipping public lose all control of an expense they incur.

The solution is simple, open choice for all chassis provisions. Motor carriers and
shippers should select and negotiate their terms between each other and
between chassis providers. In addition, | believe all chassis should have tubeless
radial tires, led lights, and updated brake systems. All chassis should be available
in roadworthy condition upon driver arrival not requiring them to position chassis
within a terminal to its mechanic area then wait on repairs. These two issues are



Another suggestion to improve Port congestion involves a very sensitive topic,
Labor. Ports across the nation are burdened with underproductive employees
carrying high payrolls. Truck drivers are often treated poorly, delayed intensively
by willful misconduct, and overall not being respected as a valuable asset in the
intermodal chain.

Lastly, infrastructure in the context of today’s discussion can be inside a terminal, |
within city limits, or on the nation’s most traveled highways. This issue is not |
cheap and answers are not glaringly obvious. Problems can be seen everywhere.
Most critics of the trucking industry are quick to say, “put it on a train or barge it”.
Being a realist today, that’s not going to happen! Trucks travel the first mile and
they travel the last mile in todays and tomorrow’s intermodal world. So let’s
acknowledge this problem and deal with it.

| will revert back to a previous statement made earlier to offer a partial solution,
“extended work hours”. The ability to use the same infrastructure over a longer
period of time daily/weekly will open capacity without incurring huge road and
facility infrastructure construction costs. Putting truck traffic on highways when 4
wheelers are less likely to be abundant makes our existing roads safer and more
productive. Congestion within our Ports will be eased allowing for a safer
workplace for dock workers and truck drivers alike.

Multiple truck routes to Ports, adequate lanes, turning radiuses, and signalization
are all issues that should be recognized, addressed, and resolved. Using New
Orleans as an example once more, it’s hard to believe in today’s economy the
Port of New Orleans only has one entrance to its container facility which forces All
of its truck traffic through the city’s downtown most congestive area in rush hour
morning/afternoon traffic. My entire career on behalf of the trucking community



Recent significant, comprehensive studies by the World Bank, the
World Economic Forum (WEF), the Organization for Economic
Cooperation and Development (OECD), and others, affirm the
tangible economic benefits of efforts to facilitate trade—to make trade
simpler, easier, faster, and less expensive. Improving the efficiency of
our global supply chains goes hand-in-hand with the global effort to
facilitate trade.

| believe that this session will help serve the essential goal of
broadening and deepening our understanding of what concerns our
efforts should address, and how these efforts should be organized,
both on a policy and a practical level.

There are meaningful policy and the practical dimensions of this
discussion. | would like to start with a quick look at a broad policy
framework, then focus on some practical issues that flow from this
broader context.

With regard to the policy framework, recent research has shown that
the central factor for the ability of a country to participate in supply
chains is the competence of local trade facilitation and logistics
services. In competitiveness terms, research shows that lack of
efficiency in local trade facilitation and logistics proficiency is
equivalent to an additional tax. For several years, the World Bank has
developed and published a Logistics Performance Index (LPI) of six
criteria for about 150 countries. These criteria serve as an
international “scorecard” to rank countries’ logistics performance


The AllS is a unique organization due to its diverse, comprehensive
character. Our 100 members comprise virtually every aspect of the
steel supply chain—shippers, traders, stevedores, importers,
exporters, major port authorities--including several of the great port
authorities represented here today, including the great Port of New
Orleans--producers, service centers, railroads, trucking companies,
customs experts, and others.

Every day of the year, the men and women who are part of the AIS
family load steel on and off ships, handle and store it on our docks,
transport it across oceans and waterways, in trucks and rail cars, and

much, much more.

The subject of today’s forum-- improving the efficiency and
effectiveness of our global supply chains--is an exceptionally
important and timely topic. In many ways, it is one of the most critical
and relevant trade-related issues of our time. The 160 member
nations of the World Trade Organization (WTO) recognized the
compelling linkages between competitiveness, trade facilitation, and
global supply chains when last December they took a consensus
decision to agree to a new multilateral Trade Facilitation Agreement,
the first successfully concluded agreement in the WTO’s 19-year
history. Most unfortunately, implementation of this historic agreement
is being held up by one country—India—over an unrelated matter
relating to food security, even though India favored the agreement in
the first instance.


Statement of

Randy Guillot

President
Triple G Express
&

Southeastern Motor Freight

Before the

Federal Maritime Commission

At the
International Supply Chain Efficiency: Challenges facing Gulf Coast Ports

Forum

New Orleans, LA

Nov 3, 2014



intertwined by the fact that a better spec’d chassis will not require the volume of
ongoing maintenance happening today. This policy will also help terminal
congestion by not having such a large inventory of unusable chassis taking up
space waiting on mechanics to repair. It also allows for the maintenance expense
of a chassis to follow through to the owner of the chassis. ALL maintenance and
repair should be built in a daily use price, similar to the “rental car” system widely
used around the country. Competition, choice, quality of product, safety oriented
chassis would be the standard not the exception as is today.

Port congestion is problematic across all regions, all Ports, and all facilities. Some
may define congestion by time, some by number of turns in a day; some may
even measure by revenue lost. By any description, it’s not good and it’s not
getting better. Here are a few “best practices” that should be employed
universally.

One multiuse chassis pool should be the standard even if multiple equipment
owners supply the pool. As example, New Orleans Port has one container facility.
Within the perimeter, two terminal operators are tenants. Each operator has its
own chassis pool which is operated by the same chassis management company
CCM. Trucks servicing both facilities in the same day have to exit and reenter the
same gate, drop and swap chassis, traverse a Port dedicated road, and
information entered by trucking companies in two separate systems. All of which
is counterproductive, costly, creates a safety exposure, and environmentally
irresponsible.

Extended work hours are a must. Many shippers and motor carriers work 24/7.
Most Port facilities are located in areas of urban congestion that are inherently
difficult to access during daytime hours. Whether terminal operators can adjust
existing staffing to extended hours for minimal additional expense or adding man
hours for longer and better performance, this “best practice” is a must. Ways to
finance cost can vary from shippers, Ports, steamship lines, truckers, or
governmental agencies.