10. POLICY OPTIONS TO REALIZE DEPLOYMENT
The previous sections of this synthesis document described the test technologies
in terms of performance in the field; how participating motor carriers and enforcement
agencies used them; their impressions of effectiveness in improving operations
and mitigate risk of terrorist activity, issues and concerns; and on return
on investment (ROI) to private and publics sectors. The concerns of the participants
are considered along with well-documented technology deployment issues of the
motor carrier industry. These issues present barriers to full deployment of
potentially beneficial technology systems. These issues are described in the
The predominant issue of the participating motor carriers and the enforcement
agencies is “How will the systems be paid for?” For the motor carriers,
the Wireless Communications with tracking capabilities was viewed as a positive
ROI-generating technology, while few others tested were. In fleets such as Bulk
Fuel and LTL-package delivery services that rely heavily on driver management
to increase revenues and lower costs, in-vehicle login features were considered
as an ROI-generating technology feature. Though not a revenue generator, the
low-cost additional feature, the Panic Button, was considered a valuable security
capability and one that would likely be readily adopted by fleets using the
core communications capabilities. Other technologies tested were considered
potentially useful and would be adopted if reliability of performance was high
and if the customers demanded their use and were willing to accept higher freight
rates to cover their expense. In other words, the carriers did not see salient
reasons to invest in them unilaterally.
10.1.2 Technical Performance
An important issue identified is the technical reliability of systems, especially
with respect to security. Overall, the commercially available technology systems
performed as designed. It was observed during the test that the emerging technologies
– E-seals, the Biometric identification systems, and the Psrc exhibited
in the field shortcomings that will need to be addressed before they would be
For the Biometric system, a Reader that is both accurate but forgiving in
regards to how a driver places his/her finger on the device and what condition
the drivers finger is in – greasy, wet, etc., is needed to prevent driver
frustration with the inability to log into a vehicle. This is especially germane
if future in-vehicle login systems are linked to the ability to start the vehicle.
For the E-seals, initially the system was slow in responding to arming and
disarming commands, thus delaying the driver in his/her duties. A later software
version improved the time lag, but still not to a convenient level for drivers.
More importantly, it was observed that the seal could not be read through a
“newer, heavy-duty" trailer, in which hundreds of thousands of units
are already in service and is rapidly becoming the industry standard in dry
van trailers. This is a technical issue that would need to be resolved or a
potentially large portion of the market may not be realized.
The Psrc-staged events demonstrated the capabilities of the system to employ
decision agents to screen and disseminate information across multiple distribution
modes to personnel in the field. A shortcoming of the technology system observed
in a staged test in California was its reliance on cellular communications for
distributing information. In areas where cellular coverage has a dead zone,
the system was unable to forward alerts to the enforcement personnel.
Many motor carriers may delay investment in emerging technology concepts until
systems are sufficiently field proven en mass.
10.1.3 Vendor/Product Stability
The purchase, installation, staff training, and system maintenance associated
with technology acquisition represent significant investments for motor carriers.
A valid business risk often described by Information Technology (IT) managers
in transportation companies is whether product offerings will become “orphaned”
(i.e., the vendor either exits the business line entirely and/or no longer provides
technical support for a product). Additionally, the state-of-the-art in technology
is changing at an increasing rate, potentially making systems functionally obsolete
prior to recouping of investment.
Vehicle disabling was also considered a strong security capability, but the
issue of potential safety consequences associated with disabling a vehicle in
a fast-moving, congested traffic area dampened enthusiasm for this technology.
The potential liability rests not only with all those who may initiate a vehicle
disablement (carriers and enforcement), but also for those who are responsible
for the vehicles.
On the opposite side of the issue is the potential liability if a truck is
equipped with vehicle disabling technology or other security technology, and
the technology is not activated in a timely enough manner to thwart an attack
in that case.
Another liability issue that could arise for late adopters of a security technology
is when a technology is so widely adopted that it becomes a defacto security
standard. Should a carrier choose not to employ the technology, the carrier
may be held liable if an event occurs that might have been stopped had the technology
been in place. The threat of potential litigation can dampen the deployment
of the technologies.
10.1.5 Data Privacy Issues
Given the extremely competitive nature of the motor carrier industry, operational
data is extremely well guarded to prevent competing entities from obtaining
a business advantage. Information regarding customers, routes, and cargo/quantities
hauled, operational costs, and revenues are key to managing a fleet and establishing
and maintaining a customer base founded on rates and service. However obtained,
this information could allow a competitor to undercut prices and steal business
from a carrier. On the security side, the less information that could be obtained
by a terrorist cell regarding carriers’ operations, the less likely a
successful attack could be planned and mounted.
From a potential litigation point of view, detailed operational data that the
test technologies are capable of collecting and archiving are at risk of disclosure
in legal actions following an incident, whether due to traffic collision or
terrorist activity. Providers of tracking and other telemetry collection and
transmission services have responded with contractual agreements with customers
regarding the length of time for archiving records and information accessibility.
This notwithstanding, archived motor carrier data may still be at risk.
With regard to the public sector, there has been a long-standing reluctance
to make proprietary data accessible. This reluctance is based in concerns about
limits of use within government and the potential access to data by other entities
under laws such as the “Freedom of Information Act”. Regarding use
of data within government, carrier concerns focus on information being used
to facilitate or enable additional tax structures, set policy and regulations,
or instigate enforcement actions against carriers. This can be particularly
germane to the Psrc concept in tracking vehicles or accessing archived manifest
data via ESCM.
10.2 POLICY OPTIONS FOR OVERCOMMING ISSUES AND REALIZING INDUSTRY DEPLOYMENT
There are several possible strategies that could be employed singularly or
in combination to stimulate industry deployment of technologies that show promise
for reducing vulnerabilities in truck-based HAZMAT shipping.
For nearly all motor carriers, return on investment is the lead factor in the
adoption of technology systems. As found in this FOT, many of the technologies
tested did not demonstrate a quantifiable improvement in motor carriers’
bottom line, but did show promise for reducing vulnerabilities in truck-based
HAZMAT shipping, and therefore, rendering potentially significant societal benefits.
In establishing policy, the government needs to weigh these potential societal
benefits against the possibility of negatively impacting the trucking industry’s
ability to move freight efficiently and profitably.
Therefore, combinations of strategies can be employed by the government to
encourage accelerated deployment of promising technologies. Several of these
(in no particular priority order) are described in the following subsections.
To address technology cost issues, the following policy options are proffered:
- Develop outreach to motor carriers describing potential efficiency and security
- Work with motor carriers and technology vendors to encourage cooperative
purchasing arrangements to take advantage of volume discounts.
- For public sector agencies, investigate the feasibility of using current
funding mechanisms such as the Motor Carrier Safety Assistance Program (MCSAP)
for deploying Psrc-enabling technologies.
10.2.2 Technical Performance
To address technology performance issues, the following policy options are
- Collect and promulgate long-term data to accurately quantify technical reliability
in many operational environments.
- Encourage vendors to include motor carriers in the process of new product
10.2.3 Vendor/Product Stability
The issue of vendor/product stability can be addressed through outreach by
encouraging motor carriers to be aware of the changing market place for ITS
products and services. The outreach could provide a directory of organizations
such as ITS America from which carriers can obtain information.
10.2.4 Potential Liability Issues
To address liability issues, the following policy options are proffered:
- Research potential legal issues associated with the purchase and use, or
lack thereof, of security-oriented technologies. This would establish a baseline
assessment of liability risk and its contributing factors.
- Define limits on acquisition of archived motor carrier data.
- Establish well-defined criteria for enforcement escalation and intervention
10.2.5 Data Privacy Issues
To address data privacy issues, the following policy options are proffered:
- Review policies and laws regarding public access to proprietary company
information to enable legislation, policies and procedures to appropriately
protect competitively sensitive information.
- Establish clearly defined limits on the use of motor carrier information
and sharing among government entities.
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