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Truck Parking Study Stakeholder Interviews Final 2/16/2021

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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. 3 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 4 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.
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