Truck Parking Study Stakeholder Interviews Final 2/16/2021

Maricopa Association of Governments Truck Parking Study Stakeholder Interviews Final 2/16/2021

Introduction

The Maricopa Association of Governments (MAG) has undertaken a study to evaluate truck parking supply and demand in the MAG region. In 2018, the U.S. Department of Transportation mandated the use of electronic logging devices (ELD) as part of the Driver Hours of Service (HOS) regulations. Since these regulations have been in effect, MAG has seen the demand for truck parking increase. The goal of the study is to provide recommendations that will address the truck parking needs including a detailed implementation plan that will serve as a roadmap for the follow-on activities. Industry participation in the study is important in order to include the needs identified by freight industry operators. Stakeholder outreach activities were conducted in order to learn about operating conditions and concerns around truck parking. These activities included a series of interviews which are documented below.

The first stakeholder interviews for MAG were conducted in March 2020. Eight in-person interviews and one telephone interview were completed early in the month, before the COVID- 19 lockdown. Ground observation was done in conjunction with the in-person visits in Phoenix. An additional nine telephone interviews were conducted between March and September. The following notes summarize the findings of those stakeholder interviews. Interview participants included operations personnel from supply chain service providers and interested parties in law enforcement and academia.  Full truckload common carrier - 4  Independent Owner Operator - 1  Private fleet -2  Rail intermodal drayage - 1  Less than truckload (LTL) - 1  Airport operations -1  Receiving Warehouse/Private Fleet - 1  Law enforcement and public safety -2  University supply chain faculty - 2

As noted, the early round of interviews conducted in Phoenix in March of 2020 coincided with the onset of COVID-19. The Coronavirus pandemic had – and continues to have - a serious impact in Arizona and throughout the supply chain network. Supply chain service providers have been stretched to their limits and have therefore been less readily available for interviews. It should be noted that this document focuses on participant responses from interviews. The team has conducted surveys and met with the Stakeholder Expert Team (SET) as separate forms of engagement. The SET, comprised of member agency staff and local industry professionals,

2 will meet three times during this study to provide feedback on technical findings, issues and solutions. The results of those activities have been summarized in other documents. Summary of Findings

Interviews and ground observations revealed that company owned facilities in the MAG region support each fleet’s operations and provide parking needed by their vehicles. The provision of parking at regional facilities serves company trucks operating in the region and those crossing Arizona, defined as “through” traffic. Some participants’ operations are more restricted, encompassing just Arizona and adjacent states such as New Mexico, California, and Nevada. Southern California has a concentrated volume of import goods coming through the ports of Los Angeles and Long Beach. The team’s industry experience and the interview responses indicate that much of the truck traffic originating or terminating within the region is inbound and the vast majority of it passes through a regional distribution center prior to final delivery. There is also a high volume of truck traffic passing through the region. These through trucks have overnight (10-hour break) parking needs. This demand adds to the overall need for parking beyond what is required for the inbound and outbound requirements for trucks making deliveries or pickups in the region. Rail intermodal services are provided at the BNSF Railway facility at Grand Avenue and to a lesser extent at the Union Pacific facility in Tucson. Intermodal operations handle international boxes (20- and 40-foot) and 53-foot domestic containers. Many of the carriers that participated in the interviews have a base of operations located in the Phoenix region. As a result, most participants reported their 10-hour break parking needs are accommodated on their respective business properties. The participants stated that one of the biggest challenges for fleet operations within the MAG region is completing the 30-minute break requirement. Since the time of these interviews the Federal Hours of Service (HOS) regulations have changed in a way that relieves the 30-minute break issue. The 30-minute break requirement can now be satisfied by an on-duty, not driving break (in addition to an off-duty break). The requirement for property-carrying drivers is applicable in situations where a driver has driven for a period of 8 hours without at least a 30- minute interruption. This allows drivers to fulfill the 30-minute break requirement while waiting at a customer location and other times when they are on duty but not driving.

Another highlighted parking concern was the need to stage trucks for on-time pickup and delivery assignments. This has been described in other documents as “logistical” parking.

Interview Discussions

Electronic Logging and Hours of Service Regulations

The interviews shed light on the impact that the electronic logging mandate has had on trucking operations. This requirement along with changes to the HOS regulations directly affects the need for truck parking in the Phoenix metropolitan region. For regionally based operations the 30-minute break requirement was cited by participants as the most challenging issue at the time of the initial interviews. In the months following the interviews, HOS changes were made that have relieved some of the concerns around the 30- minute requirement. On June 1, 2020, the Federal Motor Carrier Safety Administration (FMCSA) published changes to the HOS regulations that offer drivers greater flexibility in operations. These changes went into effect on September 29, 2020. 1 Interviewees noted that congestion has increased at facilities where trucks have traditionally been able to park. There is also increased congestion and competition for parking around warehouses and industrial zones. As congestion increases, accident frequency often goes up and consequently maintenance and repair costs increase. The interviewees indicated that congested parking and reduced flexibility in operations planning cause drivers to seek parking ahead of the required break time to secure a location before the clock runs out. Stopping short of the actual operating time creates a loss in utilization of both the equipment and the driver; this is further exacerbated by the time spent looking for the parking space. In the case of the 30-minute break, regional operators reported a range of times from 15 to 30 minutes, or occasionally more, spent securing parking. Security was reported as a primary concern when selecting parking locations for the 10-hour break requirement. Interviewees noted that the increase in the number of women truck drivers elevates the security concerns, because women tend to be more concerned about personal safety. The cost of the lost utilization to fleet operations was characterized in different ways. Participants noted that drivers were driving less than the hours allowed to accommodate break requirements. The high side was an estimated 30% loss in utilization. Multiple fleets reported the loss was in the double digits; one suggested they were losing one delivery opportunity per truck per day. Multiplied over a large fleet, these numbers are quite high. For an individual owner-operator the revenue impact is a major concern.

1 https://www.fmcsa.dot.gov/regulations/hours-of-service

Operating Concerns

While the 30-minute break issues have been alleviated, trucking operations are still significantly impacted by overnight parking and more particularly by the need to stage near facilities for on- time pickup and delivery of loads. Interviewees suggested that hours of access and shipping and receiving processes are set to optimize warehouse operations at the expense of transportation operations. Trucking has turned into a “commodity purchase” with the human aspects being ignored. Shippers look at purchasing trucking services as if they are a product they would buy, while not considering the needs of the drivers providing the service. Interview participants indicated that E-Commerce and home delivery causes larger trucks to go into neighborhoods not designed to accommodate them. Some of the problems noted with neighborhood access include one lane streets, traffic circles and other physical infrastructure that complicates truck operations. Homeowners associations (HOAs) restrict delivery times and require immediate departure after delivery. Team member’s industry experience indicates that it is often the more affluent neighborhoods with the most restrictions who also have higher demand for complicated home delivery for large items, such as furniture and appliances. Participants noted that retail and some customer/vendor locations allow parking as these facilities often have better lighting and some level of security that is attractive to drivers. Retailers are sensitive to the interaction between the trucks and their own customers but in general can provide some relief to the parking situation. However, their willingness to provide parking can be thwarted by jurisdictional regulations that create restrictions. Specific locations were identified by respondents as problematic for parking. These are shown in the Appendix section titled “How Concerns Vary Geographically”. An exception to the parking-for-staging concern was expressed by one carrier whose operations in the region were primarily drop-and-hook shuttles. In this situation, the driver goes to a location with a loaded trailer, leaves it on the yard to be emptied later and picks up an empty trailer to return to the main facility. The reverse is also true where the driver leaves a loaded trailer to be unloaded by the receiver and leaves with an empty. This activity can occur during off-peak hours. This carrier reports few, if any, problems related to parking. Carriers attempt to use off hours as much as possible to avoid congestion and travel more efficiently to optimize utilization. Shipping and receiving hours do not always allow this.

Zoning and Development

One of the primary concerns expressed in interviews was rapid commercial development, particularly for large warehouse complexes. This has created several problems for truckers. One specific issue that was noted multiple times was the desire to maximize the building footprint for tax purposes. In many cases, this has been accomplished by eliminating on-site truck parking and narrowing the streets that trucks must use to operate around facilities. The regulatory framework is controlled at a jurisdictional level and participants felt that greater cooperation across jurisdictions is needed to address these concerns. Residential and mixed-use activities have grown in areas that were previously designated as industrial. This has restricted the space available for trucking and truck stop facilities to expand around these locations. This was noted in multiple interviews.

Environmental Concerns

Participants discussed a number of environmental and community concerns that impact truck parking. Maricopa County has a 5-minute idle regulation in place for heavy duty trucks as a way to reduce emissions. Many of the larger fleets have trucks that are equipped with alternate power to provide air conditioning or heat in order to avoid engine idling. This is not true across the board. Some operators noted that the acquisition of this equipment is cost prohibitive and that trucks coming into the region may not be aware of the regulations. Some jurisdictions have noise ordinances that restrict truck operations or idling while parked during certain hours of the day. Air quality is affected by trucks searching for parking areas and waiting in lines to access shippers, receivers, and service areas.

Safety

Interviewees noted several safety concerns related to a lack of truck parking. Mixed-use traffic and trucks parked in questionable areas create road hazards for passenger vehicles and other trucks. Additionally, drivers have concerns for their personal safety and seek parking with lighting, amenities and security services provided. Truckers are also concerned about equipment damage when they deal with heavily congested parking in designated lots.

Technology

The feedback on technology applications for parking was mixed. The primary purpose for technology installation by trucking firms was for regulatory compliance and added safety

6 features. Fleet managements indicated that most drivers prefer to park where they fuel. For larger carriers, the fuel stops are contractually determined. There are multiple software systems that drivers can access from their private devices to get parking information, but for many the preference is to visually identify the location. Participants noted that parking technology applications are primarily designed to meet overnight parking needs, and less for staging for pickup and delivery.

Amenities

Fleet operations managers expressed that many drivers prefer to park overnight where they have access to a full complement of amenities such as showers, food and recreation. Safety is a concern, so lighting and security features are a consideration. Some truck parking areas attract illicit activities and most drivers prefer to avoid that. Female drivers are particularly mindful of security considerations. Parking areas have been provided in some areas of the country that do not have any restroom facilities or other amenities. Companies noted in the interviews that these sites have biohazards and safety concerns. An independent contractor described the type of tractor he used that allowed him to provide some of his own food preparation plus heat and air, giving him more flexibility in parking sites. He noted the expense of this capability was possible due to the pricing for the customer’s commodities.

Parking Strategies

Participants were asked to discuss strategies to address parking concerns and their responses are summarized below:  Truckers prefer not to pay for overnight parking but recognize the need sometimes exists. The costs can be justified to the extent that reserved and paid parking allows for optimal utilization of the vehicle and driver assets.  Parking for staging for pickup and delivery is best when located in proximity to the shipping and receiving facilities. The most desirable location is on-site or on the streets adjacent to the facility. Street parking is dependent on space and a friendly regulatory environment from the local jurisdictions. On-site parking is only available when firms are motivated – internally or externally – to provide these areas in their facility footprint.  The potential for public truck parking areas in proximity to the primary warehouse zones, particularly for staging, was suggested. Some private retail locations such as Walmart and Home Depot allow truck parking, however this can vary by individual store location and is sometimes restricted by jurisdictional concerns such as noise and idling

7 ordinances. Enforcement varies by jurisdiction and is often driven by public complaint. The interviews presented a consistent theme that businesses and municipalities whose revenue depends on trucking need to be more active in providing the parking space required for their operations.

Appendix A: Direct Interview Comments

The following sections contain comments that were expressed directly in the interviews as they were captured in the notes of the interviewers. This information is organized in the topical format of the interview guide that was developed for the discussions.

General Truck Parking Issues  The likelihood of being hit (collision) in a truck stop is pretty high.  There are too many variables for exactly on-time service. The issues are beyond the control of the driver.  Most of the time, they park behind the store.  No sleepers: the company pays for hotels as needed (will do runs to Vegas, Las Cruces).  Newer stores are harder to get into; more costly real estate plus limited space.  Trucks often park on dirt due to a lack of space in brand new developments.  The data for the last three calendar years (2017, 2018, 2019) shows only five (5) parking violations for Commercial Motor Vehicles (CMV) in Maricopa County (45 statewide) written by State Troopers over that period of time. In short, the data would not suggest any CMV parking issues on state highways and/ or freeways.  They stay at truck stops including the Flying J in Glendale.  Shuttered rest areas on highways force trucks into the metro area and compounds the problem.

How Parking Issues Impact Operations / Lost Utilization due to Parking  HOS rules and customer locations and hours of operation dictate where drivers stop. It was noted the recent HOS changes have not made any significant change in demand for parking. Weather events are another reason drivers stop in a given location.  Congestion has increased at facilities where trucks have traditionally been able to park. Increased congestion and competition for parking around warehouses and industrial zones. As the congestion increases, the accident frequency also goes up and maintenance and repair costs rise.  Drivers seek parking ahead of the required break time in order to secure a location before the clock runs out. This process of stopping short of the actual operating time creates a loss in utilization of both the equipment and the driver. This is further exacerbated by the time spent looking for an actual parking space.  Range of times from 15 to 30 minutes and occasionally more spent in the process of securing parking. The uncertainty around parking causes increased stress to drivers which results in fatigue and further diminution of the driver experience.

 The high side was an estimated 30% loss in utilization. Drivers were driving fewer than the allowed hours because of the need for parking to accommodate break requirements. One company interviewed suggested they were losing one delivery opportunity per truck per day.  One of the carrier’s operations in the region were primarily drop and hook situations where the driver goes to a location with a loaded trailer, leaves it on the yard to be emptied later and picks up an empty trailer to return to the main facility. A lot of this can occur during off-peak hours. This carrier reports few problems related to parking.  Absolutely do lose time with parking. The fleet (over 136 trucks) probably loses 100-120 hours/day on trucks looking for parking.  He thinks parking results in a 30% loss of time, but this is based on 8 hours out of 11 driving at best.  We’re losing 8 hrs/truck/day from the change. (ELD)

How Concerns Vary Geographically  There are industrial areas that are unfriendly to truck parking.  The old parts of town are better. Historically the area to the east grew, but it has now shifted to higher use. PHX has little OB (outbound) freight.  Beardsley/ 95th Avenue from East Chandler to Ocatiel (new store off Ironwood): 1 mile stretch of no trucks; they have to go all the way around to go from one store to another.  Tolleson has a lot of new Distribution Centers (DCs). They put in parking for common carriers, others do not (e.g. Fry’s next door did not). So they will park in city streets.  Noise ordinances and curfews: none in Phoenix. Scottsdale is very anti-truck.  West side between 75th and 99th is the worst due to all the DCs (and other activity) although some have room for trucks. The ELD effect meant they need more equipment to do the job because they can’t do a full turn like they did before. With counties spread out as far as they are out here (in the west, not Phoenix per se), turns (out and back loads) are harder to construct due to the lower density of the region.  There is no truck parking in a 5-8 mile stretch in Scottsdale. Scottsdale is designed for the rapid movement of freight. USPS (a customer) is very strict on idling.  Almost all their largest customers are west of I-17 and most new development is on Buckeye Corridor (he’s hearing that more industry is moving from CA to AZ)  Peoria put in no truck parking and are along Grand Avenue (the BNSF corridor)  Buckeye was a farming community. Now a master planned development with new community areas and the developers push out the parking.  One participant thinks the biggest overnight (parking) issue is on the west side.  Truckers expressed no concerns about the BNSF facility. They move you in and out well. BNSF has no parking or infringement issues; just go over and get in line. UP Tucson has lots of land (and UP in PHX is just an auto ramp).

 Thomas Road COSTCO location, 465: no ordinances, but try not to go in at night  There are 31 documented commercial vehicle parking violations within the City of Peoria, either warnings or citations. Numerous complaints are usually handled via verbal warning from patrol officers as they are not as versed in the CMV laws/city codes.  Phoenix: I have written I believe 5 parking citations in the last 2 months. They stem from community complaints of semi-trucks parked on arterial streets.  The Town of Queen Creek has the occasional call regarding a commercial vehicle, whether it be a full size semi-tractor trailer combination, straight trucks, or a landscaping truck/trailer set up parking in some area, usually a residential neighborhood, during a holiday.  There are parking issues in the East Valley.  The Travel Advisory (TA) stops around Phoenix do not experience high demand for parking. Their lots are not busy. The main parking competitor is the desert, where there is plenty of open space. Drivers are not afraid to use open space in the region for overnight parking.  Kingman, AZ is a much busier location as well as stops along the NM border. The PHX area stops are not heavily used by pass-through traffic. Most who park in Eloy are picking up or delivering in the PHX area.  Problem locations include: o Scottsdale o Mesa o 104th Avenue o South of Van Buren o Many industrial areas have no parking o States Warehouse Just past Gatorade o Anthem – “no truck attitude” o West side 95th-99th traffic, used to be a roundtrip, now not possible o Peoria-Union o Sun City o Beardsley o East Chandler

Reasons for Need for Parking (e.g. HOS long or short break, staging for pickup and delivery)  Staging westbound to CA: they invested in CARB compliant equipment, only to discover it wasn’t enforced.  Not much demand to stage westbound to CA.

 Staging for pickup or delivery requires the truck to get in line and stay in line. This creates sanitary concerns for drivers. Many facilities will not allow drivers on the loading docks.  To find a spot for 30 minutes, it can take 30 minutes. Truck stops are not designed for 30 minute stops.  AQ (air quality) attainment: limits idling to 5 minutes, but it “fine” to drive around looking for parking. Rarely finds a 30-minute spot right away. Walmarts (WMs) are good for 30-minute parking. Path of least resistance: go to a place you know (usually a customer vicinity).  Most big fleets (and all of ATA’s) should have terminals here - and 50 truck fleets may lease space to smaller guys.

Time of Day  Most of the time they stage at a truck stop until it is time for the load or unload. Many of their customers load or receive on a 24/7 schedule. If they do encounter a problem, it is mostly on weekends or late at night.  Drivers quit driving early to be sure they have a safe, secure parking site. Drivers and their employers are reluctant to pay for a reserved or guaranteed spot and are willing to gamble that a space is available when and where needed.

Arrangements with Shippers/Receivers/Carriers  Hours and processes are set to optimize warehouse operations at the expense of transportation operations. Trucking has turned into a “commodity purchase” with the human aspects being ignored. Shippers are not concerned about trucks; trucks have become a commodity.  It is particularly frustrating when the truck is very close to a pick-up or delivery location but can’t make it there because of the restrictive time requirements. Limited operating hours and tight appointment windows narrow the opportunities for on-time performance.  The root problem is the shippers don’t allow trucks on property or make them wait too long. They delay loading and unloading.  Walmart is friendly to trucks and in general allows them at their store locations. Some locations sell diesel and can function as a truck stop. Not sure if there are any of those in the Phoenix area or not.  Generally drivers can park overnight at Walmart stores unless there are local restrictions. This can vary by store and location.  Walmart does allow paid overnight parking for their private fleet drivers when necessary (this would be when away from Walmart properties).

 Historically, it was First-Come-First-Serve, or the shipper would let you on the property  A lot of facilities don’t allow drivers on dock. AZ ordinance limits idling to 5 minutes in day cabs (not sleepers).  Can’t sit on the street outside Walmart. It’s an issue especially in the morning due to overnight arrival.  They used to allow parking on their “runway” (the entrance) but then they stopped this due to volume - so truckers now use surface streets which allows up to 2 hours parking (this is on the property, past the gate, so no appointment).  They have relationships with others that allow their trucks to park. This includes the R&L (LTL) terminal and Marshalls.

Technology/Systems to Manage Parking  Drivers plan their own trip: they don’t use software (some have PeopleNet). They have info to show where can break. Almost all fuel purchase is in house.  Technology that they use is anything to make it safer for us and public: that’s where costs are o Lane keeping, driver monitoring, outward facing cameras o 360 degree (camera view): not ready for prime time  Industry is 3:1 trailer:tractor (ratio) o Regarding backup cameras: 2/3 of trailers are idle (at any given time, thus investment would be underutilized) o Cost to do it is thousands to have truly reliable system and hookup o When the price comes down and they know the efficiency level, they will do it o They are excited about the future  Drivers often park where they purchase fuel. Truckstop operators (TSO) have phone apps (like Trucksmart) that drivers can use to locate both fueling and parking. There are also third-party apps like Truckerpath and industry apps like National Association of Truckstop Operators (NATSO) Park My Truck app. That said, it seems most drivers do not use electronic/digital methods to locate parking. They prefer to visually locate parking at sites. This may be another reason drivers often won’t reserve parking in advance. TSOs are turning to loyalty programs where drivers can use (fuel) credits for parking.

Features and Amenities Sought for Parking  Have trucks stops available, but they are not appealing to drivers o Riffraff like hookers and panhandlers o If there was more enforcement, they would open up more o “No lot lizards” stickers

 Safety and security are also issues that TSOs must manage as parking density increases.  Security is a primary concern in selecting parking locations particularly for the 10-hour break time. The increase in the percentage of women drivers on the road elevates the security concerns.  Drivers also want (preferably free) amenities like showers, as well as safe and secure locations to rest. Features and amenities that attract drivers include clean showers and restrooms; ATMs; wi-fi connectivity; food service (sit-down service while not in great demand is still desired); loyalty programs; larger parking sites; and security and control of parking areas.  Has not seen a great demand for “shore power” – site-provided power and heating/cooling without idling tractors. Early attempts were unsuccessful, and there are no plans to offer it at the moment. When asked about preparing for a future with electric trucks, he said they are not too far along in their thinking about EV or autonomous truck impacts.  Sanitary facilities are needed.

Strategies to Alleviate Parking  Overlay on DC district zone, taxes used to fund staging lots with real time info – some with restrooms.  Need a market solution – means someone pays, as it concerns a public dis-benefit  30-minute breaks at the store or restaurant. Do not allow side of road: they should be able to plan their trip.  Some have agreements with hotels e.g. Red Roof who have parking for trucks and have enough locations so drivers can drop a trailer, then park elsewhere  In Maricopa County, if they have 50+ employees, they must have AQ plan (which is based on commuters) so they could try giving credit for truck parking  In Phoenix, some can get an overlay (e.g. truck parking in mixed use) which gets the developer out of existing standards – which is a negative act maybe turned to be positive; standards historically would likely not have truck parking.  Parking should be just a part of new development. Should have a logistics parking area.  When developing the freeway system, they should build in places for trucks to stop.  Road widening projects: “If they’re going to develop it, get it done” so it doesn’t impact commerce.  Traffic circles are a design feature in residential neighborhoods and town centers that are not “truck friendly”. Homeowners associations (HOA) restrict delivery times and require immediate departure after delivery. It is often the more affluent neighborhoods with the most restrictions who have higher demand for complicated home delivery for large items such as furniture and appliances.

 One company uses a strategy of prohibiting roadside parking for extended breaks. They operate without sleeper cabs and utilize contractual relationships with hotels that will allow truck parking with the driver’s overnight stay.  The city should provide an area like a marshalling yard, paid by taxes.  Parking clusters through county.  Improve turning lanes, curbs, eliminate traffic circles.  Require allocated space as part of development.  Why not utilize state owned land adjacent to the interstate?

Driver Response to Issues  We only hear a fraction of issues drivers confront because drivers are problem solvers.  Platooning: one company looked at it a lot and found it was not for them. o Need 3 identical trucks; that is very challenging. o You need the same stopping, gearing, and speed limiting to get the full benefit. o Driver who did this said “trucks with no control” are scarier than combat.  Less than truckload (LTL) carriers used to be able to pull double pup trailers out to a location where they could drop one trailer and complete pickup and delivery operations from the second trailer. The driver would then return to get the previously dropped trailer and repeat the process. (This is about doubles being limited to the interstates; parking one trailer while delivering the other lets one driver deliver both loads.) The ability to operate in this way has decreased by more than 50% due to a lack of locations suitable to allow this type of parking.  Sometimes drivers will drop their trailer and drive without the trailer (bobtail) to a location where they can secure parking for the shortened vehicle. Sometimes trailers are dropped at agreed locations. In the MAG region trailers are often seen dropped along the streets to “hold” the place in line for staging while the driver takes the tractor elsewhere for the break.

Other Problematic Regulations / Other Issues  Local enforcement varies. Some agencies target areas where trucks have no option but street parking. Other agencies are flexible until an individual citizen raises complaints. “DPS is not much of a problem”, local police (jurisdictional) are more stringent. There is more municipal enforcement than state. Some states and metro areas are better, but more by virtue of conditions rather than actions taken.  Development has pushed available parking further out. For example, Avondale used to have space for break parking but that is no longer available. There used to be parking available at customer locations but that is no longer true.

 Zoning is a major issue, mainly in newer construction. Narrow streets with no room for parking. They want to maximize use of rentable land.  The biggest complaint drivers will ever have is roundabouts.  Some of the driver shortage is due to the loss of blue-collar labor. And today it is harder to qualify to be a driver. Low unemployment in the industry.  For regional operations, the 30-minute break requirement is the most challenging.  Areas have narrow streets by design to maximize land use.  Buildings reach to lot edges, maximizing land use, eliminating onsite parking.  Standards exist but variances are given to override the standards.  Some businesses do design facilities to allow trucks onto the property for staging and short breaks. This space can be restricted to only contracted carriers, but others will sometimes try to use the space.  At some locations, any available parking is taken up by trailers being used as storage.  The concentrated location of the warehouses causes significant congestion when shifts change and employees are leaving and arriving.  Many freight companies are near each other which increases truck traffic. An example was given that it can take an hour to get out to the highway (4.5 miles from the facility).  One company only allows right hand turns in the areas along Buckeye Road.  There is a lot of growth in the spec-built warehousing that is partially empty. The developer will wait until a certain % of the space is filled then start on new construction. If the space is not filled it can be written off as a loss.

Appendix B: Interview List

The following firms or entities were included in the interviews. Some of these required more than one interview to reach the proper personnel or to cover the topic area. In addition to these interviews, many additional targets were identified and contact attempts were made. Some parties were unavailable while others declined to participate. The participants included employees and representatives from the following companies:  Schneider National Carriers  Swift Transportation  Knight Transportation  Walmart Private Fleet  Costco  J&L Transportation  Safeway  Arizona Trucking Association  PAM Transport  Staley Trucking  Arizona Department of Public Safety Special Enforcement  Sky Harbor Airport Planning and Operations  Arizona State University Faculty, Supply Chain and Urban Planning Departments  TravelCenters of America