June 1, 2015
The Honorable Anthony R. Foxx
Secretary of Transportation
Office of the Secretary
United States Department of Transportation
1200 New Jersey Avenue SE, 9th Floor
Washington, DC 20590-9898
Dear Secretary Foxx,
I write on behalf of the more than 55,000 members of the National Narcotic Officers’ Associations’ Coalition (NNOAC) to express support for increasing the capacity of twin trailers from 28 feet to 33 feet.
We believe that an objective review of the facts shows an increase in twin trailer length to 33 feet will not result in an adverse safety impact, and in fact will result in a net benefit to the safety
for the driving public and to law enforcement officers working on the road.
Many members of the NNOAC’s state associations are police officers, sheriffs’ deputies, and state troopers who work every day on our nation’s highways conducting investigations into narcotics trafficking activities and making intelligence-led traffic stops to interdict drugs, weapons, and illegal cash proceeds. Their safety along the roadside is a primary concern. They understand that their dangerous work takes place amid increasingly congested traffic conditions due to continued growth in auto traffic and freight shipments.
According to the Centers for Disease Control, more than 33,000 Americans die every year as a result of drug overdoses, making drug use one of the most dangerous threats to public health. Most deadly narcotics are not created or grown in users’ homes. They are trafficked by violent criminal organizations who prey on vulnerable addicted people and exploit America’s transportation system, including our highways, to efficiently move their products. That is why we are on the roads.
Significant support for the work of narcotic officers comes from the alert drivers and workers employed by our nation’s commercial trucking companies. Many NNOAC members appreciate the role that professional drivers and their employers play in serving as “eyes and ears” who routinely provide tips and reports of suspicious activity to law enforcement. They may notrealize it, but their actions often result in taking drugs off the streets, depriving criminal organizations of profits and preventing poison from reaching victims.
We have considered the facts regarding recommendations to change policy to accommodate longer trailer length for twin trailers. The length of those trailers is currently limited to 28 feet. By lengthening the trailers, carriers can increase the volume of freight they are able carry on a single trip. The biggest implication of this simple increase in volume per truck trip is that more freight can be carried by a given number of trucks. Looked at a different way, fewer trucks are needed to carry the same amount of freight.
From our perspective, the benefit of this change is clear: as roadway freight shipments increase over time, the number of trucks required to carry that freight would increase at a slower rate than under the current policy limits. Slowing the growth in the number of truck trips while allowing for growth in freight shipments helps law enforcement on the side of the road – including the narcotic officers we represent. By one estimate, the change could ultimately reduce the number of truck trips taken each year by more than 6 million and reduce truck miles driven by more than 1 billion per year. Fewer trips and fewer miles means less exposure to law enforcement and very likely means fewer accidents.
We understand that an increase in length of these trailers would not be accompanied by an authorization to increase the maximum weight permitted to be pulled by a truck. We also understand that the longer wheel base of the slightly longer trailers actually results in a slight increase in the stability of the twin trailers. That additional safety benefit is good for law enforcement and the driving public on the road.
Thank you for considering our views.
National Narcotic Officers’ Associations’ Coalition