legislation testimony

TAM Testimony – In support of Act Relative to Strengthening Massachusetts Economic Leadership

The following testimony was sent to the Joint Committee on Economic Development and Emerging Technologies. Our testimony supports House Bill 4459, an act to relative to strengthening Massachusetts economic leadership, which will support many industries throughout the Commonwealth.

The testimony supporting House Bill 4459, An Act Relative to Strengthening Massachusetts Economic Leadership, is also available as a PDF download.


Dear Chair Finegold, Chair Parisella and Members of the Committee:

On behalf of the over 250 member companies of the Transportation Association of Massachusetts (TAM), I am writing in strong support of House Bill 4459, An Act Relative to Strengthening Massachusetts Economic Leadership. The passage of this legislation – which will support so many industries throughout the Commonwealth – is essential. With that in mind, the trucking industry is also a vital link for supporting these same industries throughout the Commonwealth. To that end, I respectfully request that you include the rolling stock initiative, which will lead to additional tax revenue, greater public safety, a cleaner environment while creating numerous jobs with competitive salaries, to this legislation.

As you may know, TAM has been the voice of the trucking industry in Massachusetts since 1919. One of the oldest transportation associations in the United States, we represent a wide variety of companies ranging from small, family-owned trucking companies with a single truck to large national trucking companies with thousands of trucks. The trucking industry within the Commonwealth is responsible for transporting over 90% of all goods and products found in our homes and workplaces. In addition to being a key facilitator for the growth of other industries, the trucking industry is a significant creator of jobs within the Commonwealth. As a recent study by the Dukakis Center for Urban Research & Policy at Northeastern University stated, “[t]he overall trucking industry (including private and for-hire tucking) represent about one in 12 jobs or about 300,000 jobs in Massachusetts in 2017. And, trucking companies meet all Massachusetts freight movement needs.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.3 (May 2018)). In terms of employment demographics, the trucking industry is quickly diversifying as companies seek drivers to meet the growing need for trucking. (“Truck Driver Shortage Analysis 2019”, Costello & Karickhoff, American Trucking Associations, July 2019)(“ In 2018, 40.4% of [truck] drivers were minorities, which has jumped 13.8 percentage points from 26.6% in 2001.).

The rolling stock initiative, which has been passed by the Massachusetts House of Representatives as part of other economic development proposals in the past three sessions, is important to maintaining the trucking industry’s presence in the Commonwealth. Notwithstanding the significant impact of the COVID pandemic, rising fuel costs and a depleted workforce, the commercial trucking industry within the Commonwealth has been experiencing a decline as many trucking companies have moved to other states or simply closed down. Part of the reason that trucking companies have left the state is due to the Commonwealth’s tax policies. In particular, the Massachusetts Department of Revenue (DOR) collects sales and use tax for rolling stock purchased in other states which have an exemption in place for rolling stock. (i.e. tractors and trailers used in interstate commerce). As a result, any company with a nexus within the Commonwealth is being charged sales and use tax by the DOR even though the rolling stock was purchased in other states. Accordingly, various truck companies, who may be domiciled in Massachusetts or have repair facilities in Massachusetts, are now seeking to locate them outside of the state to reduce the nexus necessary to collect such tax.

Exempting the sale and use of rolling stock from taxation will bring Massachusetts in line with a majority of other states (37) within which an exemption from sales and use tax for rolling stock already exists. In fact, every surrounding New England state, except Vermont which applies a de minimus fee, has a rolling stock exemption in place. That said, amending Mass. Gen. Laws ch. 64H (i.e. sales tax) and Mass. Gen. Laws ch. 64I (i.e. use tax) to specifically exempt rolling stock from the sales and use tax brings much more than simple tax relief to the trucking industry. According to the aforementioned study conducted by the Dukakis Center for Urban Research & Policy, the elimination of the sales and use tax on rolling stock will, following national trends, create “2,768 more employees and 2,076 more power units … operating and generating an additional $15.9 million in tax revenue per year; while not estimable, … the impact on private fleets may be just as large.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.14 (May 2018)).

The need for eliminating the taxation of rolling stock cannot be overstated. First, this initiative will create a more attractive environment for trucking companies to remain in the Commonwealth. Trucking companies rely on constantly maintaining and upgrading their equipment. This means purchasing new rolling stock on a regular basis. If trucking companies know that their out-of-state purchases will incur an in-state tax, the companies will work to continue to reduce their nexus to the taxing state. As it stands, Massachusetts trucking companies are already at a competitive disadvantage when competing against carriers located in the neighboring states.

Second, but just as important, this initiative will have a significant positive impact on public safety and the environment. Exempting the sale and use of rolling stock from taxation will encourage the purchase of new equipment with the latest technology available as well incentivize companies to operate their newer trucks in the Commonwealth. This directly increases public safety and creates additional environmental benefits. In terms of public safety, new trucks include lane-departure, crash collision and speed regulator technology that significantly improve road safety. In terms of environmental benefits, newer trucks have more efficient engines and exhaust systems. This leads to greater fuel efficiency and reduces emissions of NOx and particulate matter to further support the Commonwealth’s fuel efficiency and clean air efforts. Given the Commonwealth’s recent interest in reducing emissions from the transportation sector, the rolling stock initiative makes even more sense.

Third, by keeping trucking companies in the Commonwealth, the good jobs and competitive salaries that these companies offer will remain within the state. According to the United States Bureau of Labor Statistics, Massachusetts is in the top ten for annual mean wage for heavy and tractor-trailer drivers within the country. (See http://www.bls.gov/oes/current/oes533032.htm). If more trucking companies find Massachusetts tax policy less favorable than neighboring states, it is likely the decrease in Massachusetts trucking companies will become even more significant.

Fourth, if the Commonwealth discourages trucking companies from domiciling in the state, transportation expenses will rise — further impacting the high cost of living already experienced in the Commonwealth. The costs associated with transporting goods are fairly straightforward. (See https://truckingresearch.org/2022/08/10/an-analysis-of-the-operational-costs-of-trucking-2022-update/) (“Total marginal cost of trucking grew by 12.7 percent in 2021 to $1.855 per mile, the highest on record. Leading contributors to this increase were fuel (35.4% higher than in 2020), repair and maintenance (18.2% higher than in 2020), and driver wages (10.8% higher than in 2020”). If the Commonwealth’s tax policies continue to cause trucking companies to domicile elsewhere, the additional fuel, tolls and vehicle maintenance, among other costs, will be borne by Massachusetts residents and businesses that already rely on the industry for over 90% of their goods. If the COVID-19 pandemic demonstrated one thing about the trucking industry, it is that it remains essential to residents and businesses alike.

This initiative is a matter of common sense. Given that neighboring states such as New York, Rhode Island, Connecticut, New Hampshire and Vermont (partial) exempt rolling stock from sales and use tax, Massachusetts’ current tax policy is causing higher costs for Massachusetts residents and businesses while driving economic opportunity to neighboring states. This initiative, which has been passed by the Massachusetts House of Representatives during the past three sessions, will not exclude trucking companies from the myriad of other taxes and fees the industry pays to the Commonwealth each year. This initiative simply tries to keep Massachusetts on par with the vast majority of states (37) with an exemption already in place.

On behalf of the thousands of men and women in Massachusetts who rely on the good jobs and competitive salaries these Massachusetts companies provide, I encourage you to quickly pass House Bill 4459. In doing so, I respectfully request that you include language to create an exemption from the Massachusetts sales and use tax as applied to rolling stock for trucks. This measure will produce additional tax revenue in the future while strengthening the trucking industry in Massachusetts in a manner that also improves the environment and public safety.

For your review, I have attached a variety of information about this initiative for your review. If you have any questions or concerns, please do not hesitate to let me know. I appreciate your consideration of this important matter.

Sincerely,

Kevin Weeks
Executive Director

legislation testimony

TAM Testimony – In support of An Act Relative to Carriers of Property by Motor Vehicle

The following testimony was sent to the State Senate Committee on Ways and Means. Our testimony supports Senate Bill 2209, which addresses a practical problem for larger motor carriers who may choose to ship alcohol within Massachusetts.

The testimony supporting Senate Bill 2209, An Act Relative to Carriers of Property by Motor Vehicle, is also available as a PDF download.


Dear Chair Rodrigues:

On behalf of the Trucking Association of Massachusetts (TAM), I am writing in strong support for Senate Bill 2209, An Act Relative to Carriers of Property by Motor Vehicle. This legislation, which addresses a practical problem for larger motor carriers who may choose to ship alcohol within the state, will ultimately reduce administrative costs for the Commonwealth.

As you may know, a variety of Massachusetts laws govern the shipment of alcohol from a manufacturer directly to the consumer. Under the licensing construct created under the applicable laws, each motor vehicle transporting an alcohol product must have a license from the Commonwealth. Under Senate Bill 2209, a motor carrier would be able to obtain a fleet permit to transport or deliver the products sold at retail by licensees under Mass. Gen. Laws ch. 138, §§19B, 19C, or 19F to the ultimate consumers of such products. In addition, any motor carrier so licensed would be required to ensure that parcels transported or delivered are clearly labeled with words that indicate that the package contains alcohol. The signature of a person, age 21 years or older, and proof of valid identification confirming the same will also be required for delivery. Finally, the motor carrier with a fleet license must have documentation reflecting all of these and other requirements are met.

With razor thin margins associated with the delivery of goods, trucking is at its core logistics. Unfortunately, for trucking companies with large fleets today, this means that each tractor and trailer must be able to be used for a wide variety of purposes. Whether transporting lumber, furniture, food or alcohol, a trucking company must be able to redirect its fleet to reflect market conditions and delivery needs at a moment’s notice. The Commonwealth’s licensure system – requiring each and every truck that might possibly haul alcohol be licensed – creates a disincentive for motor carriers to enter the Massachusetts market. As a result, Massachusetts consumers pay higher costs associated with a lack of competition.

Senate Bill 2209 will allow for the more practical issuance of a fleet license that covers a motor carrier’s entire fleet of vehicles. In doing so, Massachusetts will become a more attractive environment for trucking companies to transport alcohol. This legislation will not sacrifice public safety in any manner as all the same rules will still apply. All the safeguards that apply to ensuring that alcohol is only delivered to individuals 21 and older will remain in place. What this legislation will do is increase competition which will ultimately benefit consumers. As well, by issuing fleet licenses, the Commonwealth will be able to reduce licensing costs and associated resources, which may then be put towards enforcement efforts, thereby further safeguarding the general public.

I appreciate your consideration of this important matter and respectfully request that you release this legislation for its full consideration by the Senate. If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director

legislation testimony

TAM Testimony – Training tomorrow’s trucking workforce

The following testimony was sent to the Joint Committee on Transportation chairs. Our testimony supports House Bill 3371, directing the Massachusetts Board of Higher Education to create a grant program that would support training and education programs that address the workforce shortages in the commercial trucking industry.

The testimony in support of House Bill 3371, An Act Relative to Training Tomorrow’s Trucking Workforce, is also available as a PDF download.


Dear Chair Crighton, Chair Straus and Members of the Committee:

On behalf of the Trucking Association of Massachusetts (TAM), I am writing in strong support for House Bill 3371, An Act Relative to Training Tomorrow’s Trucking Workforce. With the trucking industry experiencing one of its greatest workforce challenges in recent years, it is essential that the Commonwealth strengthen its pipeline for developing a new workforce for this vital industry.

As drafted, House Bill 3371 seeks to bring a new generation of qualified workers into the trucking profession by directing the Massachusetts Board of Higher Education to create a grant program, subject to appropriation, that would support training and education programs that address the workforce shortages in the commercial trucking industry. The applicable areas of the trucking workforce targeted would include truck drivers, mechanics, technicians, and ancillary support personnel. The grant program would be used to train students, create new jobs, retrain and upgrade existing jobs, and retrain existing workers to implement new technologies and to help meet the workforce needs of the trucking industry within the Commonwealth.

House Bill 3371 is an important initiative for growing the trucking industry in Massachusetts. The creation of this program will allow for the training of students and transitioning career professionals — creating new jobs while improving the retainage and upgrading of existing jobs to help meet the growing workforce needs of the trucking industry. As reported by the American Trucking Associations (ATA), “there is no single cause of the driver shortage, but some of the primary factors include: high average age of current drivers, which leads to a high number of retirements; women making up only 7% of all drivers, well below their representation in the total workforce; the pandemic caused some drivers to leave the industry, [and] truck driver training schools trained far fewer drivers than normal in 2020. At current trends, the shortage could surpass 160,000 in 2030. This forecast is based on driver demographic trends, including gender and age, as well as expected freight growth. “Truck Driver Shortage Analysis Update 2021”, American Trucking Associations (October 2021).

Truck drivers play a crucial role in the current economy. 93% of all goods transported into and within the Commonwealth have been on a truck. Every item on the shelves of Massachusetts retailers are filled with products transported by the trucking industry. With interest in the profession dwindling, there is a clear need to encourage this career path. The revitalization of the profession is important for more than just the trucking companies, but the Commonwealth as a whole. This initiative will create a mechanism for a wide variety of organizations and employers to train and hire trucking professionals to fill the Commonwealth’s workforce shortage.

I appreciate your consideration of this important matter and respectfully request that you issue a favorable report to this legislation. If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director

legislation testimony

TAM Testimony – In support of Acts Relative to Rolling Stock

The following testimony – and detailed documentation on our position – was sent today to Massachusetts Joint Committee on Revenue members. Our testimony strongly supports House Bill 2841, Senate Bill 1178, and Senate Bill 1949, Acts Relative to Rolling Stock. The letter is available as a PDF to be printed.


Dear Chair Cusack, Chair Moran and Members of the Committee:

On behalf of the over 250 member companies of the Transportation Association of Massachusetts (TAM), I am writing in strong support of House Bill 2841 / Senate Bill 1178 / Senate Bill 1949, Acts Relative to Rolling Stock. This initiative, which will lead to greater public safety and a cleaner environment, will also lead to additional tax revenue while creating numerous jobs with competitive salaries. The legislation, which has been passed by the Massachusetts House of Representatives as part of other legislative vehicles in the past three sessions, received a favorable report from this Committee the past two sessions.

As you may know, TAM has been the voice of the trucking industry in Massachusetts since 1919. One of the oldest transportation associations in the United States, we represent a wide variety of companies ranging from small, family-owned trucking companies with a single truck to large national trucking companies with thousands of trucks.  The trucking industry within the Commonwealth is responsible for transporting over 90% of all goods and products found in our homes and workplaces. In addition to being a key facilitator for the growth of other industries, the trucking industry is a significant creator of jobs within the Commonwealth.  As a recent study by the Dukakis Center for Urban Research & Policy at Northeastern University stated “[t]he overall trucking industry (including private and for-hire tucking) represent about one in 12 jobs or about 300,000 jobs in Massachusetts in 2017. And, trucking companies meet all Massachusetts freight movement needs.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.3 (May 2018)). In terms of employment demographics, the trucking industry is quickly diversifying as companies seek drivers to meet the growing need for trucking.  (“Truck Driver Shortage Analysis 2019”, Costello & Karickhoff, American Trucking Associations, July 2019)(“ In 2018, 40.4% of [truck] drivers were minorities, which has jumped 13.8 percentage points from 26.6% in 2001.).

Notwithstanding the significant impact of the COVID pandemic, rising fuel costs and a depleted workforce, the commercial trucking industry within the Commonwealth has been experiencing a decline as many trucking companies have moved to other states or simply closed down.  Part of the reason that trucking companies have left the state is due to the Commonwealth’s tax policies. In particular, the Massachusetts Department of Revenue (DOR) collects sales and use tax for rolling stock purchased in other states which have an exemption in place for rolling stock. (i.e. tractors and trailers used in interstate commerce). As a result, any company with a nexus within the Commonwealth is being charged sales and use tax by the DOR even though the rolling stock was purchased in other states.  Accordingly, various truck companies, who may be domiciled in Massachusetts or have repair facilities in Massachusetts, are now seeking to locate them outside of the state to reduce the nexus necessary to collect such tax.

Exempting the sale and use of rolling stock from taxation will bring Massachusetts in line with a majority of other states (37) within which an exemption from sales and use tax for rolling stock already exists. In fact, every surrounding New England state, except Vermont which applies a de minimus fee, has a rolling stock exemption in place. That said, amending Mass. Gen. Laws ch. 64H (i.e. sales tax) and Mass. Gen. Laws ch. 64I (i.e. use tax) to specifically exempt rolling stock from the sales and use tax brings much more than simple tax relief to the trucking industry. According to the aforementioned study conducted by the Dukakis Center for Urban Research & Policy, the elimination of the sales and use tax on rolling stock will, following national trends, create “2,768 more employees and 2,076 more power units … operating and generating an additional $15.9 million in tax revenue per year; while not estimable, … the impact on private fleets may be just as large.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.14 (May 2018)).

The need for eliminating the taxation of rolling stock cannot be overstated.  First, this initiative will create a more attractive environment for trucking companies to remain in the Commonwealth. Trucking companies rely on constantly maintaining and upgrading their equipment. This means purchasing new rolling stock on a regular basis. If trucking companies know that their out-of-state purchases will incur an in-state tax, the companies will work to continue to reduce their nexus to the taxing state. As it stands, Massachusetts trucking companies are already at a competitive disadvantage when competing against carriers located in the neighboring states.

Second, but just as important, this initiative will have a significant positive impact on public safety and the environment. Exempting the sale and use of rolling stock from taxation will encourage the purchase of new equipment with the latest technology available as well incentivize companies to operate their newer trucks in the Commonwealth. This directly increases public safety and creates additional environmental benefits. In terms of public safety, new trucks include lane-departure, crash collision and speed regulator technology that significantly improve road safety. In terms of environmental benefits, newer trucks have more efficient engines and exhaust systems. This leads to greater fuel efficiency and reduces emissions of NOx and particulate matter to further support the Commonwealth’s fuel efficiency and clean air efforts. Given the Commonwealth’s recent interest in reducing emissions from the transportation sector, the rolling stock initiative makes even more sense.

Third, by keeping trucking companies in the Commonwealth, the good jobs and competitive salaries that these companies offer will remain within the state. According to the United States Bureau of Labor Statistics, Massachusetts is in the top ten for annual mean wage for heavy and tractor-trailer drivers within the country.  (See http://www.bls.gov/oes/current/oes533032.htm). If more trucking companies find Massachusetts tax policy less favorable than neighboring states, it is likely the decrease in Massachusetts trucking companies will become even more significant.

Fourth, if the Commonwealth discourages trucking companies from domiciling in the state, transportation expenses will rise — further impacting the high cost of living already experienced in the Commonwealth.  The costs associated with transporting goods are fairly straightforward. (See https://truckingresearch.org/2022/08/10/an-analysis-of-the-operational-costs-of-trucking-2022-update/) (“Total marginal cost of trucking grew by 12.7 percent in 2021 to $1.855 per mile, the highest on record. Leading contributors to this increase were fuel (35.4% higher than in 2020), repair and maintenance (18.2% higher than in 2020), and driver wages (10.8% higher than in 2020”). If the Commonwealth’s tax policies continue to cause trucking companies to domicile elsewhere, the additional fuel, tolls and vehicle maintenance, among other costs, will be borne by Massachusetts residents and businesses that already rely on the industry for over 90% of their goods. If the COVID-19 pandemic demonstrated one thing about the trucking industry, it is that it remains essential to residents and businesses alike.

This initiative is a matter of common sense. Given that neighboring states such as New York, Rhode Island, Connecticut, New Hampshire and Vermont (partial) exempt rolling stock from sales and use tax, Massachusetts’ current tax policy is causing higher costs for Massachusetts residents and businesses while driving economic opportunity to neighboring states. This initiative, which has been passed by the Massachusetts House of Representatives during the past three sessions, will not exclude trucking companies from the myriad of other taxes and fees the industry pays to the Commonwealth each year. This initiative simply tries to keep Massachusetts on par with the vast majority of states (37) with an exemption already in place.

On behalf of the thousands of men and women in Massachusetts who rely on the good jobs and competitive salaries these Massachusetts companies provide; I respectfully request that you issue a favorable report to this legislation. Again, including language to create an exemption from the Massachusetts sales and use tax as applied to rolling stock for trucks will produce additional tax revenue in the future while strengthening the trucking industry in Massachusetts in a manner that also improves the environment and public safety.

For your review, I have attached a variety of information about this initiative for your review.  If you have any questions or concerns, please do not hesitate to let me know. I appreciate your consideration of this important matter.

Sincerely,

Kevin Weeks
Executive Director

legislation testimony

TAM Testimony – Rolling stock tax relief initiative

The following testimony – and detailed documentation on our position – was sent today to Massachusetts Governor Maura Healy. Our testimony encourages the governor to include the rolling stock tax relief initiative into the administration’s tax reform proposal. The letter is available as a PDF to be printed.


Dear Governor Healey:

On behalf of the over 250 member companies of the Transportation Association of Massachusetts (TAM), I am writing relative to the rolling stock tax relief initiative. This initiative, which will lead to greater public safety and a cleaner environment, will also lead to additional tax revenue while creating numerous jobs with competitive salaries. Accordingly, I respectfully request that you include this initiative as part of any tax relief / tax reform proposal submitted to the Massachusetts legislature.

As you may know, TAM has been the voice of the trucking industry in Massachusetts since 1919. One of the oldest transportation associations in the United States, we represent a wide variety of companies ranging from small, family-owned trucking companies with a single truck to large national trucking companies with thousands of trucks. The trucking industry within the Commonwealth is responsible for transporting over 90% of all goods and products found in our homes and workplaces. In addition to being a key facilitator for the growth of other industries, the trucking industry is a significant creator of jobs within the Commonwealth. As a recent study by the Dukakis Center for Urban Research & Policy at Northeastern University stated “[t]he overall trucking industry (including private and for-hire tucking) represent about one in 12 jobs or about 300,000 jobs in Massachusetts in 2017. And, trucking companies meet all Massachusetts freight movement needs.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.3 (May 2018)). In terms of employment demographics, the trucking industry is quickly diversifying as companies seek drivers to meet the growing need for trucking. (“Truck Driver Shortage Analysis 2019”, Costello & Karickhoff, American Trucking Associations, July 2019)(“ In 2018, 40.4% of [truck] drivers were minorities, which has jumped 13.8 percentage points from 26.6% in 2001.).

Notwithstanding the significant impact of the COVID pandemic, rising fuel costs and a depleted workforce, the commercial trucking industry within the Commonwealth has been experiencing a decline as many trucking companies have moved to other states or simply closed down. Part of the reason that trucking companies have left the state is due to the Commonwealth’s tax policies. In particular, the Massachusetts Department of Revenue (DOR) collects sales and use tax for rolling stock purchased in other states which have an exemption in place for rolling stock. (i.e. tractors and trailers used in interstate commerce). As a result, any company with a substantial nexus within the Commonwealth is being charged sales and use tax by the DOR even though the rolling stock was purchased in other states. Accordingly, various truck companies, who may be domiciled in Massachusetts or have repair facilities in Massachusetts, are now seeking to locate them outside of the state to reduce the nexus necessary to collect such tax.

Exempting the sale and use of rolling stock from taxation will bring Massachusetts in line with a majority of other states (37) within which an exemption from sales and use tax for rolling stock already exists. In fact, every surrounding New England state, except Vermont which applies a de minimus fee, has a rolling stock exemption in place. That said, amending Mass. Gen. Laws ch. 64H (i.e. sales tax) and Mass. Gen. Laws ch. 64I (i.e. use tax) to specifically exempt rolling stock from the sales and use tax brings much more than simple tax relief to the trucking industry. According to the aforementioned study conducted by the Dukakis Center for Urban Research & Policy, the elimination of the sales and use tax on rolling stock will, following national trends, create “2,768 more employees and 2,076 more power units … operating and generating an additional $15.9 million in tax revenue per year; while not estimable, … the impact on private fleets may be just as large.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.14 (May 2018)).

The need for eliminating the taxation of rolling stock cannot be overstated. First, this initiative will create a more attractive environment for trucking companies to remain in the Commonwealth. Trucking companies rely on constantly maintaining and upgrading their equipment. This means purchasing new rolling stock on a regular basis. If trucking companies know that their out-of-state purchases will incur an in-state tax, the companies will work to continue to reduce their nexus to the taxing state. As it stands, Massachusetts trucking companies are already at a competitive disadvantage when competing against carriers located in the neighboring states.

Second, but just as important, this initiative will have a significant positive impact on public safety and the environment. Exempting the sale and use of rolling stock from taxation will encourage the purchase of new equipment with the latest technology available as well incentivize companies to operate their newer trucks in the Commonwealth. This directly increases public safety and creates additional environmental benefits. In terms of public safety, new trucks include lane-departure, crash collision and speed regulator technology that significantly improve road safety. In terms of environmental benefits, newer trucks have more efficient engines and exhaust systems. This leads to greater fuel efficiency and reduces emissions of NOx and particulate matter to further support the Commonwealth’s fuel efficiency and clean air efforts. Given the Commonwealth’s recent interest in reducing emissions from the transportation sector, the rolling stock initiative makes even more sense.

Third, by keeping trucking companies in the Commonwealth, the good jobs and competitive salaries that these companies offer will remain within the state. According to the United States Bureau of Labor Statistics, Massachusetts is in the top ten for annual mean wage for heavy and tractor-trailer drivers within the country. (See http://www.bls.gov/oes/current/oes533032.htm). If more trucking companies find Massachusetts tax policy less favorable than neighboring states, it is likely the decrease in Massachusetts trucking companies will become even more significant.

Fourth, if the Commonwealth discourages trucking companies from domiciling in the state, transportation expenses will rise — further impacting the high cost of living already experienced in the Commonwealth. The costs associated with transporting goods are fairly straightforward. (“Total marginal cost of trucking grew by 12.7 percent in 2021 to $1.855 per mile, the highest on record. Leading contributors to this increase were fuel (35.4% higher than in 2020), repair and maintenance (18.2% higher than in 2020), and driver wages (10.8% higher than in 2020”). If the Commonwealth’s tax policies continue to cause trucking companies to domicile elsewhere, the additional fuel, tolls and vehicle maintenance, among other costs, will be borne by Massachusetts residents and businesses that already rely on the industry for their goods. If the COVID-19 pandemic demonstrated one thing about the trucking industry, it is that it remains essential to residents and businesses alike.

This initiative is a matter of common sense. Given that neighboring states such as New York, Rhode Island, Connecticut, New Hampshire and Vermont (partial) exempt rolling stock from sales and use tax, Massachusetts’ current tax policy is causing higher costs for Massachusetts residents and businesses while driving economic opportunity to neighboring states. This initiative, which has been passed by the Massachusetts House of Representatives during the past three sessions, will not exclude trucking companies from the myriad of other taxes and fees the industry pays to the Commonwealth each year. This initiative simply tries to keep Massachusetts on par with the vast majority of states (37) with an exemption already in place.

On behalf of the thousands of men and women in Massachusetts who rely on the good jobs and competitive salaries these Massachusetts companies provide; I respectfully urge you to include relief for Massachusetts trucking companies and Massachusetts companies with truck fleets within any tax relief / tax reform proposal submitted to the Massachusetts legislature. Again, including language to create an exemption from the Massachusetts sales and use tax as applied to rolling stock for trucks will produce additional tax revenue in the future while strengthening the trucking industry in Massachusetts in a manner that also improves the environment and public safety.

For your review, I have attached a variety of information about this initiative for your review. If you have any questions or concerns, please do not hesitate to let me know. I appreciate your consideration of this important matter.

Sincerely,

Kevin Weeks
Executive Director

All attachments and the above letter are included in the downloadable PDF that can be printed. It includes the following:

  • SD1392, An Act Relative to the Taxation of Rolling Stock
  • Fact Sheet – Rolling Stock Initiative Overview
  • Fact Sheet – Environmental Benefits of the Rolling Stock Initiative
  • Fact Sheet – Public Safety Benefits of the Rolling Stock Initiative
legislation testimony

TAM Testimony – Large Entity Reporting Requirement

The following testimony was sent today to Ms. Ngoc Hoang, environmental analyst at the Massachusetts Department of Environmental Protection Bureau of Air and Waste. It concerns 310 CMR 7.41, Large Entity Reporting Requirement. The letter is available as a PDF to be printed.


Dear Ms. Hoang:

On behalf of the over 250 member companies of the Transportation Association of Massachusetts (TAM), I am writing to provide comments relative to the Massachusetts Department of Environmental Protection’s (DEP’s) proposed regulation 310 CMR 7.41, Large Entity Reporting Requirement.

As you may know, TAM has been the voice of the trucking industry in Massachusetts since 1919. One of the oldest transportation associations within the Commonwealth, we represent a wide variety of companies ranging from small, family-owned trucking companies with a single truck to large national trucking companies with thousands of trucks. The trucking industry within the Commonwealth is responsible for transporting over 90% of all goods and products found in our homes and workplaces. In addition to being a key facilitator for the growth of other industries, the trucking industry is a significant creator of jobs within the Commonwealth. As a recent study by the Dukakis Center for Urban Research & Policy at Northeastern University stated “[t]he overall trucking industry (including private and for-hire tucking) represent about one in 12 jobs or about 300,000 jobs in Massachusetts in 2017. And, trucking companies meet all Massachusetts freight movement needs.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.3 (May 2018)). In terms of employment demographics, the trucking industry is quickly diversifying as companies seek drivers to meet the growing need for trucking. (“Truck Driver Shortage Analysis 2019”, Costello & Karickhoff, American Trucking Associations, July 2019)(“ In 2018, 40.4% of [truck] drivers were minorities, which has jumped 13.8 percentage points from 26.6% in 2001.).

TAM and its members have been active participants in reducing the trucking industry’s carbon footprint throughout the Commonwealth already. TAM, which has supported tougher idling laws and their enforcement; increased auxiliary power unit weight exemptions; and the establishment of cogent transportation rules to reduce delays, recognizes that the future is “green”. The use of “clean” diesel fuels and advanced engine technology in today’s new trucks reduces emissions of particulate matter (PM) by 99% and nitrous oxide (NOX) by 98%. While the ultimate goal is to produce no engine emissions, it is important to note that newer heavy duty trucks are already minimizing emissions on many levels. The transition to zero emission heavy duty trucks cannot – nor will not – happen overnight. To the aforementioned point, mandates that simply push the burden of zero emissions compliance completely on the trucking industry – without providing the necessary infrastructure, financial support and technology – will ultimately harm the trucking industry and the residents and businesses in Massachusetts that rely on it.

With this in mind, TAM respectfully requests your consideration of the following points:

  1. Purpose of the Proposed Inventory Rule. The “Background Document” made available by the DEP states that the agency is promulgating this regulation “so it (DEP) can assess the ways to develop and locate charging infrastructure and programs on how to support and accelerate the MHD ZEV market in Massachusetts”. The document, which acknowledges a similar inventory regulation was promulgated by the California Air Resources Board (CARB), further comments on the DEP’s “adoption of CARB’s Advanced Clean Trucks (ACT), Phase 2 GHG, and Heavy-duty Omnibus regulations.” Although these latter regulations will increase the price of trucks in Massachusetts while the regulatory burden is placed on the manufacturers, no mention is made of CARB’s upcoming Advanced Clean Fleets (ACF) regulation, which will require fleets with 50 or more trucks to purchase zero emissions vehicles (ZEV) trucks. The original survey, which was part of CARB’s ACT regulation, was adopted with the intent to develop/justify the ACF regulation. Accordingly, is the proposed regulation merely a stepping-stone for the DEP following the CARB’s ACF regulation, which simply lays a de facto mandate on any companies that utilize trucks? Or, more appropriately, will this inventory be used in a cooperative manner that seeks the development of an incentive-based approach to replacing the trucking industry’s existing vehicles. Put simply, why bother with a “large entity (fleet) inventory” if DEP has already decided that it will follow the existing CARB regulations? The trucking industry in Massachusetts, which is already in a precarious position, will be adversely impacted if the DEP does not engage in a collaborative approach that provides the necessary infrastructure, financial support and availability of technology.
  2. Size of the Fleets to be Inventoried. TAM urges the DEP to reject any calls for reducing the number of trucks within a fleet for purposes of reporting and complying with the proposed regulation. The proposed regulatory reporting is already going to be onerous on the companies that have 40 or more trucks within their fleet. Reducing the reporting requirement to companies with five or more trucks in their fleet will significantly burden countless small companies while likely providing more data than the DEP will be able to effectively use. From direct experience with their fleets in California, certain TAM members have reported that CARB’s “reporting costs of $50 per hour and 25 hours per entity, or approximately $1,250 for each entity” are optimistic at best.¹
  3. Routing Information. TAM opposes any additional requirement to report on a truck’s specific route or, collectively, routes used by a trucking company as part of this proposed regulation. While appreciative of the concern for environmental justice (EJ) communities, mandating the release of a company’s operations information at that level of detail would open a pandora’s box of potential legal and practical issues. Notwithstanding the time, cost and effort of compiling that data, the information would also lead to concerns about anti-competitive actions by competitors or municipal routing actions in contravention to federal law and regulations governing the same.²

Alternative fuel heavy duty and medium duty trucks still remain much more expensive than traditional diesel-powered trucks of the same class and designation. The proposed large entity inventory regulation can be useful if the data is used to underpin arguments for increasing both incentives for the purchase of new, alternative fuel heavy and medium duty trucks and improving the infrastructure necessary to support the future use of such vehicles. Otherwise, Massachusetts’ current energy infrastructure for alternative fuel vehicles will be unable to support the entire trucking industry’s needs even if affordable alternative fueled vehicles existed.

I appreciate your consideration of these comments to the DEP’s proposed regulation, 310 CMR 7.41, Large Entity Reporting Requirement. TAM looks forward making sure that the eventual transition from diesel fueled engines remains practical and affordable for all. To that end, we implore the agency to include the trucking industry at the table before further regulations are promulgated.

If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director, Trucking Association of Massachusetts


¹ Again, TAM is unclear why the DEP did not also adopt the 50-truck limit that CARB used. If we purport to be following CARB’s lead – including their cost estimates for compliance, why not simply set the standard at trucking companies with 50 or more qualifying trucks? If this “large entity inventory” requirement is a merely a “check box” for eventually adopting the CARB regulations, why create this different reporting threshold?

² On a related, but slightly different note, TAM appreciates the specific reference to 310 CMR 3.00, governing the use and handling of confidential information by state agencies.

legislation testimony

In support of legislation to meet the workforce needs of the trucking industry

The following communication was sent today to the House Chair, Senate Vice Chair, and members of the Joint Committee on Transportation expressing TAMs strong support for for House Bill 3522, An Act Relative to the Training of Tomorrow’s Trucking Industry Workforce. The letter is also available as a PDF to be printed.


Dear Chair Straus, Vice Chair Keenan and Members of the Committee:

On behalf of the over 250 member companies of the Trucking Association of Massachusetts (TAM), I am writing to urge your strong support for House Bill 3522, An Act Relative to the Training of Tomorrow’s Trucking Industry Workforce. This legislation, which received a favorable report from a different committee last session, will encourage the training of students and transitioning of career professionals to meet the growing workforce needs of the trucking industry.

In Massachusetts, the trucking industry is a key driver of economic growth: it accounts for about 1 out every of 12 jobs in the Commonwealth, or approximately 300,000 jobs in total as of 2017. There are many lucrative career options within the trucking industry. For example, according to the United States Bureau of Labor and Statistics, heavy and tractor-trailer truck drivers make upwards of $60,000 per year. Many trucking industry jobs don’t require a college degree, unlike certain jobs in today’s market, making trucking an attractive profession for those looking to earn a steady income without first spending a lot of their own money and time to attend four or more years of school.

Despite the potential career options that the trucking industry offers, the industry is facing a workforce shortage. According to the American Trucking Association, the industry will need to hire almost 900,000 new drivers and other key positions nationally over the coming decade, with most of the demand resulting from retiring drivers and industry growth. At the same time, interest in the profession is waning, making it difficult for the industry to fill these vital positions. By 2026, the ATA forecasts that the industry could be facing a shortage of almost 175,000 drivers and additional trucking industry workforce. When you consider that 93% of all goods transported into and within the Commonwealth are carried on a truck, it becomes clear that this shortage is a problem not just for the trucking industry, but the Commonwealth as a whole. Indeed, the trucking industry workforce shortage could cost Massachusetts to miss out on significant tax revenues: a study by the Dukakis Center for Urban Research and Policy at Northeastern University recently estimated that each local trucking employee generates about $3,396 per year in state and local payroll, income and property taxes.

Accordingly, House Bill 3522 would create a mechanism for a wide variety of organizations and employers to train and hire individuals for positions within the trucking industry to address this workforce shortage. By establishing a Trucking Industry Workforce Training Fund, the bill would provide a source of funding by which employers and employer associations, local workforce investment boards, institutions of higher education, vocational schools, and other organizations could finance programs to support both the training of the next generation of the trucking workforce and the retention and upgrading of the existing trucking workforce.

In order to finance the Trucking Industry Workforce Training Fund, the bill would create a $5 surcharge on all applications for licensure or renewal of a commercial driver’s license. This mechanism ensures that no financial burden would fall on most residents of the Commonwealth. Organizations across the Commonwealth could then apply for grants, financed by the Trucking Industry Workforce Training Fund, to operate training programs, which will follow guidelines established by the Massachusetts Board of Higher Education. This funding will be crucial in addressing the trucking industry’s workforce shortage, and, ultimately, enable individuals to obtain good careers in a vibrant and growing industry.

I appreciate your consideration of House Bill 3522, An Act Relative to Training Tomorrow’s Trucking Industry Workforce, and respectfully request that the Committee release the bill with a favorable report. Please do not hesitate to contact me with any questions or concerns. I look forward to working with you on this important matter.

Sincerely,

Kevin R Weeks
Executive Director

legislation testimony

TAM Testimony – Related to legislation filed relative to autonomous vehicles

On Jan. 17, Kevin Weeks, the executive director of the Trucking Association of Massachusetts, submitted written testimony relative to House Bill 3013, Senate Bill 2115, House Bill 3143, and House Bill 3089 filed relative to autonomous vehicles. The testimony is provided below, and a PDF is available for download.

For additional information, contact the Trucking Association of Massachusetts.

Honorable William Straus, House Chair
Honorable Joseph Boncore, Senate Chair
Joint Committee on Transportation
State House, Room 134
Boston, Massachusetts 02133

Dear Chair Straus, Chair Boncore, and Members of the Committee:

On behalf of the over 250 member companies of the Trucking Association of Massachusetts (“TAM”) which employ thousands of individuals throughout the Commonwealth, I am writing in regard to House Bill 3013, Senate Bill 2115, House Bill 3143, and House Bill 3089 filed relative to autonomous vehicles. We ask that you consider the potential impact of regulating autonomous vehicles carrying passengers on the trucking industry as it begins to implement autonomous technology on its trucks.

The TAM recognizes the importance of considering regulations on passenger vehicles at this time, but autonomous technology as related to autonomous trucks is still developing and will have the ability to benefit all aspects of the industry. Regulations on passenger vehicles at this time may inadvertently limit the use of these autonomous trucks in the future. A fully autonomous truck will have the ability to identify, interact with and safely react to all aspects of the driving environment without a driver in control of the wheel. However, it may be decades before this vehicle could be commercially available. For your reference, we have again enclosed a report by the American Transportation Research Institute (ATRI) that outlines the future of AV technology in the trucking industry.

There are different levels of “autonomy” that come with different technologies, functionalities, and expectations. The National Highway Traffic Safety Administration (NHTSA) and the Society of Automotive Engineers (SAE) have developed automation scales ranging from Level 0 of no automation to Level 5 of full automation where no operator is present in the truck. Level 3 is conditional automation where an automated system can actually conduct some parts of the driving task, but there must be a driver present to take back control of when the automated system requests. The timeline of Level 3 and Level 5 trucks replacing the existing US trucks is dependent on the investment in research and development.

The progressive implementation of these levels of autonomous technology will benefit the industry as it will increase driver health and wellness and their productivity, address industry issues of driver shortage and retention, and decrease need for truck parking facilities. Road safety will also increase as urban congestion is mitigated with the widespread use of autonomous vehicles.

Drivers currently work and drive in 14-hour shifts driving up to 11 of those hours. Autonomous trucks would allow for drivers to take more rest breaks, simultaneously increasing road safety with driver awareness and increasing productivity. Due to these conditions, there is currently a shortage of 48,000 drivers that will increase to 175,000 drivers by 2024. To address this issue, the use of autonomous technology can make truck driving an attractive career as it decreases fatigue and stress, and allows drivers to get home earlier. The technology would also decrease the number of trucks needed, leading to a decreased driver shortage.

Please refer to the attached report by ATRI for further information of the impact of autonomous technology on the trucking industry when considering the legislation regarding autonomous vehicles before your committee. I appreciate your consideration of this important matter. If you have any questions please do not hesitate to contact me.consider the potential impact of regulating autonomous vehicles carrying passengers on the trucking industry as it begins to implement autonomous technology on its trucks.

Sincerely,

Kevin Weeks
Executive Director

legislation testimony

TAM Testimony – Concerning House Bill 3980, An Act to Promote Commercial Driving Safety

On Jan. 2, Kevin Weeks, the executive director of the Trucking Association of Massachusetts, submitted written testimony relative to House Bill 3980, An Act to Promote Commercial Driving Safety. The testimony is provided below, and a PDF is available for download.

For additional information, contact the Trucking Association of Massachusetts.

Honorable William Straus, House Chair
Honorable Joseph Boncore, Senate Chair
Joint Committee on Transportation
State House, Room 134
Boston, Massachusetts 02133

Dear Chair Boncore, Chair Straus and Members of the Committee:

On behalf of the Trucking Association of Massachusetts (TAM), I am writing relative to House Bill 3980, An Act to Promote Commercial Driving Safety. TAM, which has a proven history of supporting increased public safety measures, respectfully requests that this legislation be amended to reflect a variety of practical considerations that will not impact the public safety objectives of this legislation.

As you know, TAM has been the voice of the trucking industry in Massachusetts since 1919. One of the oldest transportation associations within the Commonwealth, our membership represents a wide variety of companies ranging from small, family owned trucking companies with a single truck to large national trucking companies with thousands of trucks. The trucking industry within the Commonwealth is responsible for transporting 87%-93% of all goods and products found in our homes and workplaces. In addition to being a key facilitator for the growth of other industries, the trucking industry is a significant creator of jobs within the Commonwealth. As a recent study by the Dukakis Center for Urban Research & Policy at Northeastern University stated “[t]he overall trucking industry (including private and for-hire tucking) represent about one in 12 jobs or about 300,000 jobs in Massachusetts in 2017. And, trucking companies meet all Massachusetts freight movement needs.” (“The Importance of the Trucking Industry to the Massachusetts Economy”, Pritchard, R. & Scott, A., p.3 (May 2018)).

Most importantly, TAM and its members work to ensure that the Commonwealth’s roadways are safe for the general public as well as commercial motor vehicles. Safety is the single most important consideration for trucking companies or companies with trucking fleets – whether hauling hazardous materials, household goods or food products. As a result, TAM and its members work closely with local, state and federal officials to ensure that drivers are appropriately trained and licensed; tractors and trailers are legally compliant and safe for operation, and best management practices for reducing risk are employed every day.

In reviewing, HB3980, TAM respectfully requests that the Committee consider the following four areas for potential amendment:

(1). Section 11: Three years clear driving history and the unintentional increase to the minimum age for a CDL. A plain reading of Section 11 of HB3980 would appear to push the Commonwealth’s minimum driving age for acquiring a CDL license to 19+. Specifically, the bill’s language states: “An applicant for a commercial driver’s license shall be a duly licensed motor vehicle operator for a period of 3 continuous years immediately prior to his or her application.”. In the Commonwealth, the earliest an individual can obtain a junior driver’s license is 16 ½ years old. A requirement for a three year period of clear driving would accordingly push the minimum age for acquiring a CDL to 19½ years of age. This will push the minimum age qualification for an intrastate CDL from the current standard of 18 years of age. Given that an 18 year old may currently hold a CDL for in-state operation of a commercial motor vehicle, HB3980 will harm employers who utilize 18 year old to 19½ year old intrastate operators.

(2). Section 11: Prohibition for obtaining a CDL and the types of infractions which cause a suspension. HB3980 would prohibit the issuance of a CDL due to a wide range of previously committed offenses resulting in a suspended license for the applicant. However, the list of offenses that could result in the suspension of the CDL applicant’s Class D driver’s license contains a number of offenses that have nothing to do with driving. For example, a license suspension resulting from Mass. Gen. Laws ch. 266, §126A ( “tagging”, aka grafitti) or Mass. Gen. Laws ch. 90, §22G (“littering”) would prevent an individual from ever being eligible for a CDL. While not condoning such action, it is still difficult to understand why offenses unrelated to driving or, even, not actual moving violations should prevent an applicant from applying for a CDL. (Note: if a standard needs to be restated, consider instead using the criteria established in Melanie’s law, Chapter 122 of the Acts of 2005, already used by trucking companies / truck driving schools.).

(3). Section 11: Grandfathering students currently in truck driving schools or training programs. Under Section 11’s prohibitions for acquiring a CDL, the enactment of HB3980 would potentially harm students, enrolled at that time, in truck driving schools or training programs, who would otherwise be disqualified from driving a truck. Under existing law, potential applicants for CDLs are not in jeopardy because of a previous license suspension due to littering, the failure to pay child support or a similar type of infraction. However, the enactment of HB3980, without some type of grandfathering clause, would cause financial and other harms to these individuals, who started a truck driving school or training program before they knew they would be prohibited from obtaining a CDL. Accordingly, TAM respectfully requests that a provision be included within the legislation to “grandfather” any students in a truck driving or training program at the time any potential law is made effective.

(4). Section 16: Definition of employers. This section requires employers to register for the Registry of Motor Vehicles’ (RMV’s) free driver verification service (DVS) service. The question from many of the companies within a number of industries is simple – how far does the definition of employer extend? For example, if a national company has many out of state CDL holders and a few CDL holders licensed in Massachusetts, must it sign up for the RMV’s DVS for every employee or independent contractor? Likewise, if an employer already uses a “pay” service that exceeds the requirements of the DVS, must an employer register for a second, redundant service? Again, TAM welcomes the opportunity to work with the Committee to clarify these questions in the proposed law so that the Commonwealth’s roadways are made safer without unnecessarily harming employers or their employees.

Trucking is a heavily regulated industry. The laws and regulations, whether federal or state, that oversee the industry ensure that both drivers and their equipment meet stringent safety standards and training. TAM appreciates the thought that has gone into HB3980; it is a piece of legislation that aims to close potential loopholes in the CDL law. The legislation’s provisions implementing a reasonable electronic device hands-free prohibition, penalties for inappropriate approaches to railroad crossings and empowering the RMV to suspend a CDL on notice from another government entity are laudable public safety measures. With that in mind, TAM, through the four aforementioned points listed above, seeks to make the legislation before the Committee one that protects the public, yet understands the practical considerations trucking companies must address in order to comply with the proposed law.

I appreciate your consideration of this important matter. If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director

legislation testimony

TAM Testimony – Opposition to House Bill 3129, and in support of Senate Bill 2141

On Jan. 2, Kevin Weeks, the executive director of the Trucking Association of Massachusetts, submitted written testimony in opposition to House Bill 3129, An Act relative to the use of liquid calcium chloride on state highways, and in support of Senate Bill 2141, An Act relative to commercial fees. The testimony is provided below, and a PDF is available for download.

For additional information, contact the Trucking Association of Massachusetts.

Honorable Joseph Boncore, Senate Chair
Honorable William Straus, House Chair
Joint Committee on Transportation
State House, Room 134
Boston, Massachusetts 02133

Dear Chair Straus, Chair Boncore and Members of the Committee:

On behalf of the over 250 trucking company members of the Trucking Association of Massachusetts (“TAM”), I am writing in opposition to House Bill 3129, An Act relative to the use of liquid calcium chloride on state highways, and in support of Senate Bill 2141, An Act relative to commercial fees.

House Bill 3129 seeks to prevent the use of liquid calcium chloride for the treatment, prevention or removal of snow or ice on roads or bridges within the Commonwealth, or for any other related purpose. As you may know, liquid calcium chloride is used to pre-wet salts as part of an anti-icing strategy. The liquid calcium chloride is applied to dry salts before or during salt application to the pavement. When the liquid is applied to the rock salt particle, it penetrates ice and snow pack better and decreases the loss of salt from traffic action by 30%. The use of liquid calcium chloride as part of anti-icing strategy is proactive in ice control as it prevents ice from bonding to the surface and leads to better pavement conditions, easier clean-up, and requires less chemicals, decreasing the environmental impact.

During winter storm conditions, trucking companies are specifically concerned about the accumulation of snow and ice on the Commonwealth’s roads and bridges. Accordingly, TAM supports strategies that address snow and ice control in as efficient and safe a manner as possible. Calcium chloride is the most widely used non-sodium chloride deicer and provides performance advantages over other deicers as only small quantities are necessary due to its ability to melt ice faster and at lower temperatures. These qualities decrease costs, increase safety, and minimize environmental impact. As a result, discontinuing the use of liquid calcium chloride will likely lead to a number of avoidable harms. Primarily, discontinuing the use of liquid calcium chloride will increase costs by increasing the quantity of salt that must be used on roads and bridges while increasing the likelihood excess rock salt will make its way into sensitive environmental areas adjacent to the Commonwealth’s roads and bridges. Given a National Highway Traffic Safety Administration’s report that Massachusetts has among the lowest road fatality rate in the nation for trucking, now is not the time change a successful process.

With respect to Senate Bill 2141, the legislation proposes to cap fees on any individual fee to no more than 2.5 per cent in a calendar year. As well, the legislation requires the Massachusetts Registry of Motor Vehicles (RMV) to offer a discount for any person registering 5 or more units in a calendar year, including but not limited to, semi-trailers (normal), semi-trailer (reserved), trailer (normal), trailer (reserved). The discount shall be in an amount of no less than 10 percent of each registration fee they would otherwise incur. Finally, the legislation requires the RMV to issue a report to the legislature within 90 days offering recommendations to reduce the cost of operating a commercial vehicle or unit in Massachusetts in order to promote competition with neighboring states.

Just as TAM has argued in favor of eliminating the state’s rolling stock tax, Massachusetts is a comparatively expensive jurisdiction to domicile or operate a trucking company within. Certain taxes and fees on essential aspects of operating a trucking company are simply higher than those in the other New England states. SB2141 would provide a small measure of relief by reducing the potential for large fee increases while also offering a key reduction in costs for fleet registration. To retain the trucking industry’s presence in the Commonwealth, which in turn reduces costs for consumers and creates jobs for residents, there needs to be a competitive environment to foster the growth of this important industry. SB2141 will provide a reasonable and measured strategy for creating a sustainable platform for the trucking industry in this state.

I appreciate your consideration of these two important matters. If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director