that that lays out some specific guidelines as to how this program can work, and that a fine level that is not outrageous should be something that is reasonable and correspond right along with that. The CHAIR. Very well. Thank you very, very much.

Mr. Shuster, do you have any further statements or questions? Mr. SHUSTER. Just one question. Would you support the CVSA line schedule being adopted nationwide?

Mr. SPENCER. I worked on the particular committee that developed that fine schedule, and most truckers that I talk to believe even that fine schedule is too high, and that they generally believe the key area to spend money on is to repair the vehicle, to improve safety. And, you know, any revenues that are for another source, they don't see where it is especially productive in increasing safety. If the best we can do is the uniform sanction schedule for recommended maximums, our organization would and does support that. But the key being, from our perspective, take safety dollars and actually convert them into safety rather than penalties.

In too many areas in trucking we have big penalties that we presume will have a deterrent effect. But the problem is they never get to the parties that are responsible for creating the situation or resolving the situation. So we just have a penalty unfairly applied. Mr. SHUSTER. Thank you very much.

The CHAIR. Thank you very much, gentlemen.

There being no further business before the Subcommittee on Surface Transportation, the subcommittee will stand adjourned. Thank you very much.

[Whereupon, at 3:40 p.m., the subcommittee was adjourned.]

PFMI

INSTITUTE

Private Carrier

PREPARED STATEMENTS SUBMITTED BY WITNESSES

NPTC

NATIONAL PRIVATE TRUCK COUNCIL

66 Canal Center Plaza, Suite 600, Alexandria, VA 22314 Phone: 703-683-1300 Fax: 703-683-1217

INTRODUCTION

The National Private Truck Council (NPTC) is the national association of manufacturers, processors, distributors, retailers and service companies that operate truck fleets in support of their commercial activities. NPTC's membership comprises approximately 1200 national and regional corporations, and includes many of the Fortune 500 companies.

Collectively, private, or "corporate" truck fleets haul more than half of the nation's truck freight, and operate 80 percent of the nation's commercial vehicles.

NPTC believes, as a matter of philosophy, that government actions involving the safety of commercial motor vehicles should be based, wherever possible, on performance criteria, while allowing fleet operators maximum flexibility in meeting those criteria. We also believe, given limited resources for enforcement, that government actions should be geared toward "working smarter, not harder" by focusing enforcement attention on those fleets, as well as those elements of accident causation that "need it the most." Our comments

today will reflect these philosophies. We offer several examples of current or prospective government initiatives which we believe meet the test for appropriate government involvement and several which we believe do not.

ZERO-BASE REGULATORY REVIEW

An example of government regulation at its best is the Federal Highway Administration's

(FHWA) "zero-base review" of the Federal Motor Safety Carrier Regulations (FMSCRs). This initiative seeks to review the existing regulations to determine whether they are rational and justified, understandable, worthy of implementation, performance-based, enforceable and, most importantly, actually enhance safety and reduce accidents.

We wish to commend the Office of Motor Carriers and its new Director, George Reagle, for their continuing strong commitment to this effort. The zero-base review reflects both the desirability of performance-based criteria and the concept of working smarter, not harder. It is an excellent example of a meaningful effort to "reinvent government" in a way that provides the greatest safety benefits while minimizing regulatory burdens.

For example, as a part of the zero-base review, NPTC has asked FHWA to evaluate whether the existing FMCSRs should continue to be applied uniformly to all types and configurations of commercial vehicles. Commercial vehicles come in a variety of shapes and sizes, with varied operating characteristics and vocational uses. Currently, the regulations come in "one size fits all." It may not make sense to apply the same regulatory scheme to a 12,000 pound snack food delivery vehicle as is applied to an overthe-road vehicle with a gross vehicle weight of 80,000 pounds. We believe the regulatory outcome should be based on the safety performance experience of these different types of vehicles. The zero-base review provides a mechanism to address this issue.

We urge the members of this subcommittee to support the zero-base initiative.

INTELLIGENT VEHICLE HIGHWAY SYSTEMS

Better use of data to identify problem carriers and drivers and improve motor carrier safety, particularly through use of Intelligent Vehicle Highway Systems (IVHS) technology, is another means to achieve performance based safety management in a more cost

effective manner.

NPTC has been very much involved in bringing the benefits of IVHS to fruition. We are participating in ongoing demonstration and developmental projects relating to IVHS Commercial Vehicle Operations (IVHS/CVO).

From our standpoint, the greatest potential benefit to be derived from IVHS/CVO is implementation of a nationwide commercial vehicle network, where trucks can voluntarily travel the nation's highways just as cars do, without stopping at state borders and weigh stations. Vital safety and other regulatory checks can be made automatically and without delays. This promises the multiple benefits of lower cost safety enforcement while lowering transportation costs and improving productivity.

However, there are barriers to overcome in putting such a system in place. The most difficult of these is not the technology which in large part, already exists. The real