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 following subsections.

10.1 ISSUES

10.1.1 TechnologyCost

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 attractive commercially.

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.

10.1.4 LiabilityIssues

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.

10.2.1 TechnologyCost

To address technology cost issues, the following policy options are proffered:

1. Develop outreach to motor carriers describing potential efficiency and security benefits.
2. Work with motor carriers and technology vendors to encourage cooperative purchasing arrangements to take advantage of volume discounts.
3. 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 proffered:

1. Collect and promulgate long-term data to accurately quantify technical reliability in many operational environments.
2. Encourage vendors to include motor carriers in the process of new product design.

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:

1. 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.
2. Define limits on acquisition of archived motor carrier data.
3. Establish well-defined criteria for enforcement escalation and intervention procedures.

10.2.5 Data Privacy Issues

To address data privacy issues, the following policy options are proffered:

1. Review policies and laws regarding public access to proprietary company information to enable legislation, policies and procedures to appropriately protect competitively sensitive information.
2. Establish clearly defined limits on the use of motor carrier information and sharing among government entities.
   

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