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ATRI releases the Top 10 Trucking Industry Issues for 2022

The trucking industry’s not-for-profit research organization, the American Transportation Research Institute (ATRI), released its 18th annual Top Industry Issues report.

Across all respondents, fuel prices were selected as the top industry concern in 2022. After spending five years as the number one concern, the driver shortage dropped one position in 2022 to rank second overall. The lack of available truck parking rose one spot this year to the third-ranked issue, followed by driver compensation. The state of the nation’s economy rounded out the top five concerns (Figure 1).

This year’s list had a new entry to the top ten concerns, speed limiters, ranking ninth overall. Earlier this year, the Federal Motor Carrier Safety Administration released a Speed Limiters Notice of Intent to commence in 2023.

For more information, visit the ATRI website.

Issue Priority Scores

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.


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.

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Massachusetts state police recognized by national trucking industry research organization for commercial vehicle enforcement effectiveness

Boston, MA – The American Transportation Research Institute (ATRI), the trucking industry’s not-for-profit research organization, has just released the update to its Crash Predictor Model, which statistically quantifies the likelihood of future crash involvement based on specific truck driving behaviors (e.g. prior crashes, violations and convictions).

ATRI’s research draws on data from over 580,000 U.S. truck drivers over a two-year time frame. The analysis identified more than 25 different violations and convictions that increased the likelihood of future crashes, five of which increased future crash likelihood by over 100 percent. Simply having a previous crash increased a truck driver’s probability of having a future crash by 113 percent, 28.4 percent higher than previous ATRI Crash Predictor reports.

Recognizing that traffic enforcement, particularly those activities that target the crash predictor behaviors, is an effective tool for mitigating crashes, ATRI’s research quantifies the “top tier” states which emphasizes those states that have proven track records of maximizing their enforcement resources while minimizing their share of the nation’s truck crashes. Massachusetts was ranked fifth overall in ATRI’s report.

John McKenna, Chairman of the Trucking Association of Massachusetts, said:

TAM applauds the Massachusetts State Police for their leadership, training, and enforcement. These actions are what put our state in the top 5, and make our roadways among the safest in the country. Kudos to recently retired Lieutenant Thomas Fitzgerald, his successor Lieutenant Vincent Noe, and the entire truck team for this achievement. We are also proud of our members and fellow truckers for their effort in keeping the roads safe.

Other key findings from ATRI’s Crash Predictor Model Update are:

  • The top three behaviors for predicting future crash involvement, with more than 100 percent increased likelihood of a future crash, are a Failure to Yield Right-of-Way violation, a Failure to Use / Improper Signal conviction and a Reckless Driving violation.
  • Several behaviors have maintained stable trends across all four ATRI Crash Predictor models (2005, 2011, 2018 and 2022) as statistically significant predictors of future crash involvement including violations for Failure to Yield Right-of-Way and Reckless Driving, along with convictions for Failure to Use / Improper Signal and an Improper / Erratic Lane Changes.
  • The 2022 Crash Predictor update includes several new analyses, including a safety comparison of 18-20 year old truck drivers and those older than 24 years. The report also revisits the safety of male versus female truck drivers, with female drivers continuing to be safer than their male counterparts.
  • The analysis also documents a surprising differential between the percentage of female truck drivers overall (6.7%) and their much smaller representation among truck driver inspections (2.7%). Several explanations are tested to understand the basis for the difference.

A copy of this report is available at the ATRI website.

The Trucking Association of Massachusetts (TAM) is the voice of the trucking industry in Massachusetts. As an independent, non-profit trade association representing trucking companies and industry vendors, TAM exists to encourage the healthy growth and betterment of the trucking industry statewide.

Orange Line and North Green Line shutdown

The Orange Line shutdown and the northern section of the Green Line being shut down for a month will cause residual impacts to the “roadway” transportation network in and around the metro-Boston area, especially the north side of Boston’s I-93 corridor.

MassDOT Highway is working to ensure they are prepared on the roadway network and to support the movement of passengers along the designated routes on the bus shuttles.

Changes have been implemented from Route 16/Revere Beach Parkway West to Wellington Circle and down the Fellsway/Route 28 Southbound, then what comes out of Sullivan Square, down Rutherford Avenue, and over the Gilmore Bridge to Charles River Dam Road (Rt 28).

The most significant impact is the Gilmore Bridge, which has only two lanes in each direction but will accommodate bus-only lanes and NO LEFT TURN restrictions at either end (the left to Charles River Dam Road / and the left to the Rutherford on-ramp at Bunker Hill Community College.

Please review the graphics to assist you in adjusting routes if it applies to you.

gilmore bridge traffic

MassDOT issues IRP Apportion Registration extension

The Massachusetts Registry of Motor Vehicles has issued an extension for IRP Apportion Registrations displaying a June 2022 expiration decal.

All submitted renewals have been processed; however, due to US Postal Service mailing timelines, some carriers may not have received their credentials (CAB Cards) with the new 2023 expiration decal.

MassDOT has requested law enforcement refrain from taking action on these vehicles until after July 16, 2022.

MassDOT has sent a letter to IRP jurisdictions requesting they honor this grace period by delaying enforcement of expired apportion plate decals on vehicles operating in their jurisdictions until July 16, 2022.


Repealing rolling stock tax

Bill aims to repeal rolling stock tax in Massachusetts

Rep. Bradley Jones Jr. (R) recently introduced H.B. 2959, An act relative to the taxation of rolling stock, in the Massachusetts House of Representatives. The issue has been a serious one for the trucking industry for about eight years.

“We’ve been fighting this for three or four sessions — almost eight years now — trying to make this occur. We’re hoping this will be the right time,” said Kevin Weeks, executive director of the Trucking Association of Massachusetts. “We have met with the governor a few times on this separately. He has assured us he would sign this if it makes it to his desk. We get support from everyone we’ve met with on the House and Senate side.”

The measure would provide an exemption from a “rolling stock” tax for trucks, tractors, and trailers owned by interstate trucking companies that are used to transport goods in interstate commerce.

“We are currently the only New England state, and one of just 13 nationwide, that provides no sales tax exemption for interstate for-hire trucking firms,” Jones told Transport Topics about the measure, officially House Bill 2959 in the Massachusetts Statehouse. “H.B. 2959 would codify in statute the commonwealth’s pre-1996 tax policies on rolling stock and would help make Massachusetts more competitive compared to our neighboring states.”

Read the full article on Transport Topics.


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MassDOT & ThinkArgus conducts trucker roadway experience survey

Are there specific things you would change to make your experience on the roadways better as a truck driver? A survey is being conducted by the MassDOT Highway Division for commercial truck drivers.

Your answers will help MassDOT gain a better understanding of your needs and lived experience on Massachusetts roads. It should only take about 10 minutes to complete. The MassDOT values your feedback.

This survey will be live for the next two weeks, so please complete at your earliest convenience.

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Entry-level driver training standards effective Feb. 7

truck driver smiling in cabThe new entry-level driver training (ELDT) standards (49 CFR Part 380) set a national baseline for entry-level driver training to improve the safety of our roads and highways across the Commonwealth and our nation.

These new standards become effective Monday, Feb. 7 and impacts drivers applying to:

  • Obtain a Class A or Class B commercial driver’s license (CDL) for the first time
  • Upgrade to a Class B CDL or to a Class A CDL
  • Obtain a school bus (S), passenger (P), or hazardous materials (H) endorsement for the first time

Beginning Feb. 7,  the Massachusetts Registry of Motor Vehicles (RMV) will verify completion of training for applicants that are subject to ELDT prior to scheduling a CDL skills test, or knowledge test for drivers applying for a hazmat endorsement for the first time.

Organizations planning to provide ELDT must be registered with the Federal Motor Carrier Safety Administration Training Provider Registry (TPR). Training providers can register for the TPR online.

By registering, training providers will have the ability to enter training information for driver’s that successfully complete ELDT.

The RMV has hosted multiple webinars on the subject. Below are links to a list of questions and answers from the Jan. 12 webinar, plus the webinar’s presentation material.

snowplow truck winter storm

Winter Storm: Tractor trailer ban set for Saturday

Effective at 6 a.m. on Saturday, Jan. 29 tractor trailers will be restricted from all state roads. The restriction is currently set to expire at 11:59 p.m. on Jan. 29.

This post will be updated as new information becomes available, but we do suggest you refer to the Alerts section on the 511 website or mobile app to receive immediate notifications.


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Governor declares emergency related to hours of service regulations

On Jan. 13, Gov. Charlie Baker signed a Declaration of Emergency Notice providing relief from regulations pertaining to hours of service of motor carriers and drivers of commercial motor vehicles. This exemption is exclusive to those commercial drivers transporting and delivering fuels necessary for the continued heating of homes, businesses and other structures.

The exemption remains in effect through Feb. 6, 2022 unless rescinded sooner by appropriate order. It applies only to 49 CFR Part 395 and no other sections of the FMCSRs.

The full text of the declaration is available online, and a PDF is available for download.

(Title 49 CFR Part 390.23)

Pursuant to 49 CFR Section 390.23, I, Governor Charles D, Baker, declare that an emergency exists pertaining to the delivery of essential supplies, more specifically propane and heating and fuel oil to customers in the Commonwealth of Massachusetts,

This emergency exemption is issued as a result of the confluence of below average cold temperatures that have caused on increased demand for fuel throughout the Commonwealth and workforce shortages, caused by the COVID-19 Omicron variant.

This emergency declaration provides regulatory relief for commercial motor vehicles operation while providing direct assistance supporting the delivery of propane and heating and fuel oil into the affected areas and to consumers during the emergency,

This emergency exemption is effective beginning 11:59 PM, EST, January 11, 2022 and will remain in effect until 11:59 P.M., EST, February 6, 2022 unless rescinded sooner by appropriate order.

The following ls ordered:

  1. An emergency exists that requires relief from regulations adopted in Massachusetts and Federal Statutes and Regulations pertaining to hours of service of motor carriers and drivers of commercial motor vehicles, while transporting and delivering fuels necessary for the continued heating of homes, businesses, and other structures,  (49 CFR Part 395).
  2. Nothing contained in this declaration shall be construed as an exemption from the Controlled Substances and Alcohol Use and Testing requirements (49 CFR Part 382), the Commercial Driver’s License requirements (49 CFR Part 383), the Financial Responsibility requirements (49 CFR Part 387), applicable Size and Weight requirements, or any other portion of the regulation not specifically authorized pursuant to Title 49 CFR Section 390.23.
  3. No motor carrier operating under the terms of this exemption shall require or allow a fatigued or ill driver to operate a motor vehicle.  A driver who informs a carrier that he or she needs immediate rest shall be given at least ten consecutive hams off-duty before the  driver is allowed to return to service.
  4. Motor carriers or drivers that have an Out of Service Order in effect may not take advantage of the relief from regulations that this declaration provides under Title 49 CFR 390.23.
  5. Drivers of motor carders that operate under this Declaration of Emergency Notice must have a copy of it in their possession.
  6. Consistent with Title 49 CFR Section 390.23, this emergency notice will remain in effect through 11:59 P.M., February 6,  EST or sooner if terminated by the Governor.

DATE:  January 13, 2022

Charles D. Baker

Last updated: Friday, January 14, 2022