Joe Lane [mailto:JLane@amtrol ] Sent: Wednesday .
![Joe Lane [mailto:JLane@amtrol ] Sent: Wednesday .](/img2/130/2011-3-s05-letter.webp)
From: Joe Lane [mailto:JLane@amtrol.com]Sent: Wednesday, September 07, 2011 10:59 AMTo: William MascaroSubject: RE: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5William, thank you for your response. I did not doubt the professionalism of CCSB but wanted anexplanation that you provided. Thank you for your time and effort to answer my question.Joseph LaneAmtrol ConsultantAmtrol Inc1400 Division Rd.West Warwick RI 02893T: 401. 884.6300M: 401.965.9922jlane@amtrol.comFrom: William Mascaro [mailto:William.Mascaro@nmfta.org]Sent: Tuesday, September 06, 2011 2:48 PMTo: Joe Lane; Joel Ringer; 'Yelnatsk@aol.com'Cc: blombari@flexconind.com; christopher.lange@pentair.com; Chris VanHaaren;neal.white@pentair.com; mgentry@hotwater.com; .org; Colleen Airgood; rstone@fele.com; emery@daviseng.com;sja@merrillmfg.com; bo@flomatic.com; gduggan@flexconind.com; richard@masterwater.com;jjtroccoli@hotwater.com; buzmills@2mco.com; chris.jamieson@itt.com; t: RE: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5Mr. Lane,While the proposed provisions would group expansion tanks with other types of tanks, it woulddistinguish between tanks tendered in boxes or crates and those tendered other than in boxes or crates,in recognition of their respective transportation characteristics. This distinction is reflected by the factthat the classes would be higher for tanks tendered other than in boxes or crates than for tankstendered in boxes or crates for a given density.As detailed in the proposal, the record is based on information developed from shippers and carriers, aswell as firsthand observations by CCSB members. As is the case with all proposals, the CCSB’s NationalMotor Freight Classification Procedures, which are available on our website, were followed. Individualdiscussions between carriers and their customers are not within the purview of the CCSB.Regards,William MascaroMemberCommodity Classification Standards Board1001 North Fairfax Street, Suite 600Alexandria, Virginia 22314703-838-1834
From: Joe Lane [mailto:JLane@amtrol.com]Sent: Friday, September 02, 2011 11:49 AMTo: William Mascaro; Joel Ringer; 'Yelnatsk@aol.com'Cc: blombari@flexconind.com; christopher.lange@pentair.com; Chris VanHaaren;neal.white@pentair.com; mgentry@hotwater.com; .org; Colleen Airgood; rstone@fele.com; emery@daviseng.com;sja@merrillmfg.com; bo@flomatic.com; gduggan@flexconind.com; richard@masterwater.com;jjtroccoli@hotwater.com; buzmills@2mco.com; chris.jamieson@itt.com; t: RE: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5Thank you and Mr. Ringer for spending the time to consider my question. Evidently I still do notunderstand. By combining all tanks into one category as proposed, the unpackaged tanks and packagingtanks are considered equal whereas having separate categories provided different classifications for thedensities. I assume that those who load and ship the tanks were solicited for their comments as to whatis the most important factors. In my dealings with our carriers, the fact that we can fill the cube of thetrailer is very important.Joseph LaneAmtrol ConsultantAmtrol Inc1400 Division Rd.West Warwick RI 02893T: 401. 884.6300M: 401.965.9922jlane@amtrol.com
From: William MascaroSent: Thursday, August 25, 2011 10:07 AMTo: 'Joe Lane'; Joel Ringer; 'Yelnatsk@aol.com'Cc: blombari@flexconind.com; christopher.lange@pentair.com; Chris VanHaaren;neal.white@pentair.com; mgentry@hotwater.com; .org; Colleen Airgood; rstone@fele.com; emery@daviseng.com;sja@merrillmfg.com; bo@flomatic.com; gduggan@flexconind.com; richard@masterwater.com;jjtroccoli@hotwater.com; buzmills@2mco.com; chris.jamieson@itt.com; t: RE: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5Mr. Lane,As the CCSB member responsible for Subject 5 of Docket 2011-3 involving tanks, Mr. Ringer has askedme to respond to your email.The primacy of density as a transportation characteristic has been well established through numerousdecisions of the former Interstate Commerce Commission and its successor agency, the SurfaceTransportation Board. These decisions have determined that unless there are overriding stowability,handling or liability issues, density is generally the controlling characteristic.My analysis of Subject 5 of Docket 2011-3 also provides an in-depth discussion of all four transportationcharacteristics and clearly shows that stowability, handling and liability factor significantly in the CCSB’sevaluation of the involved tanks. These differences are reflected in the fact that Subject 5 of Docket2011-3 addresses the handling, stowing and liability differences of tanks tendered in boxes or cratesfrom those tendered other than in boxes or crates by providing a one or two class increase for tankstendered other than in a box or crate from the class provided for a tank of a similar density whentendered in a box or crate.Regards,William MascaroMemberCommodity Classification Standards Board1001 North Fairfax Street, Suite 600Alexandria, Virginia 22314703-838-1834
From: Joe Lane [mailto:JLane@amtrol.com]Sent: Wednesday, August 24, 2011 5:38 PMTo: Joel Ringer; 'Yelnatsk@aol.com'Cc: blombari@flexconind.com; christopher.lange@pentair.com; Chris VanHaaren;neal.white@pentair.com; mgentry@hotwater.com; .org; Colleen Airgood; William Mascaro; rstone@fele.com;emery@daviseng.com; sja@merrillmfg.com; bo@flomatic.com; gduggan@flexconind.com;richard@masterwater.com; jjtroccoli@hotwater.com; buzmills@2mco.com; chris.jamieson@itt.com;jim.bradley@pentair.com; dstuart@grundfos.comSubject: RE: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5Mr. Ringer, it is interesting that you mention 4 factors but the only factor that appears to be consideredis density. CCSB has put low liability, excellent stowability and easy handling of the carton packagedexpansion tanks in with engineered products that are difficult to handle has poor stowability and liabilityclaims are high. Due to the engineered product designs the densities are high so they can receive alower freight rate. What am I missing?Joseph LaneAmtrol ConsultantAmtrol Inc1400 Division Rd.West Warwick RI 02893T: 401. 884.6300M: 401.965.9922jlane@amtrol.com
From: Joel RingerSent: Monday, August 22, 2011 11:54 AMTo: 'Yelnatsk@aol.com'Cc: blombari@flexconind.com; christopher.lange@pentair.com; cvanhaaren@amtrol.com;neal.white@pentair.com; mgentry@hotwater.com; .org; Colleen Airgood; William Mascaro; rstone@fele.com;emery@daviseng.com; sja@merrillmfg.com; bo@flomatic.com; gduggan@flexconind.com;jlane@amtrol.com; richard@masterwater.com; jjtroccoli@hotwater.com; buzmills@2mco.com;chris.jamieson@itt.com; jim.bradley@pentair.com; dstuart@grundfos.comSubject: RE: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5Dear Ms. Stanley,This will acknowledge receipt of, and thank you for, your letter dated August 21, 2011. The letter will beadded to our public docket file for Subject 5 of Docket 2011-3, which as you mention will be consideredby the Commodity Classification Standards Board (CCSB) at our public meeting on September 12, 2011.With respect to your comment that “Currently, most expansion and hydropneumatic tanks for the waterwell industry manufactured by WSC members use Class 85 under Item 181070 for shipping,” I wouldpoint out that, while expansion tanks are currently named in item 181070, hydropneumatic tanks arenow named in item 181700.Regarding your comments on shipping costs and the possible economic impact the proposal would haveon your members, I must tell you that the CCSB is prohibited from considering freight rates or economicfactors, such as trade conditions. The National Motor Freight Classification groups products according totheir relative “transportability,” as determined by an evaluation of the four transportationcharacteristics of density, stowability, handling and liability. The CCSB has the responsibility of ensuringthat products are properly classified on the basis of the four transportation characteristics, and only onthe basis of those characteristics. I assure you the CCSB will review and consider the information youhave furnished relating to the transportation characteristics of the involved tanks.Again, thank you for your letter, which we will include in the public docket file.Regards,Joel L. RingerChairmanCommodity Classification Standards Board703-838-1826ringer@nmfta.orgFrom: Yelnatsk@aol.com [mailto:Yelnatsk@aol.com]Sent: Monday, August 22, 2011 9:50 AMTo: Joel Ringer; Colleen Airgood; William Mascaro; rstone@fele.com; emery@daviseng.com;sja@merrillmfg.com; bo@flomatic.com; gduggan@flexconind.com; jlane@amtrol.com;richard@masterwater.com; jjtroccoli@hotwater.com; buzmills@2mco.com; chris.jamieson@itt.com;jim.bradley@pentair.com; dstuart@grundfos.comCc: blombari@flexconind.com; christopher.lange@pentair.com; cvanhaaren@amtrol.com;neal.white@pentair.com; mgentry@hotwater.com; .orgSubject: SUBMITTED FOR PUBLIC DOCKET FILE -- DOCKET 2011-3, Subject 5
Attached is WSC 's response to your July 28, 2011 letter re: Reclassification of Tanks, iron orsteel, including Expansion Tanks; Proposed Cancellation of NMFC Item 181070 and Amendmentof Item 181700-Docket 2011-3, Subject 5.A copy is also being mailed to CCSB. This response is for inclusion in the public docket for theSept. 12 meeting.Kathleen M. StanleyExecutive DirectorWater Systems Council1101 30th Street, NW, Suite 500Washington, DC 20007202/625-4387 voice202/625-4363 faxwell water . naturally better
Letter to CCSB – August 21, 20111 of 2August 21, 2011Joel RingerChairman, CCSB1001 North Fairfax Street, Suite 600Alexandria, VA 22314-1798Delivered via Electronic Mail to: ccsb@nmfta.orgElectronic Copy to: Colleen Airgood, Classification Assistant, airgood@nmfta.orgWilliam Mascaro, Member, CCSB, William.Mascaro@nmfta.orgWater Systems Council (WSC) submits the following comments for inclusion in the public docket file foryour meeting September 12, 2011 in Alexandria, VA regarding reclassification of tanks, iron or steel,including expansion tanks and the proposed cancellation of NMFC Item 18070 and amendment of Item181700 – Docket 2011-3, Subject 5.WSC represents all of the major tank manufacturers in North America. Currently, most expansion andhydropneumatic tanks for the water well industry manufactured by WSC members use Class 85 underItem 181070 for shipping. Data from these companies mirrors that submitted to CCSB by the “involvedshipper” referenced in CCSB Docket 2011-3, Subject 5, Transportation Characteristics, Density.The following chart provides shipment data from WSC manufacturers for 2005-2010. WSC membersestimate that 90% of these expansion tanks have an average density of 6.66 pcf. And, an estimated90% of all tanks shipped were fully enclosed within a box or crate and/or banded to pallets or skids.WSC TANKSHIPMENT 91,078,1371,164,7261,261,422thNational Programs Office 1101 30 Street, N.W. Suite 500 Washington, DC 20007Phone: 202-625-4387 Fax: 202-625-4363 www.watersystemscouncil.org
Letter to CCSB – August 21, 20112 of 2As you know, shipping costs are based on factors of multiplication that include classification, zip code anddensity. WSC manufacturers ship tanks in stackable cartons on pallets with a flat load bearing surfacearea. This makes these tanks easy to load and unload via a forklift truck. Shipping damages are negligible.Claims data to prove this are available from the WSC tank manufacturer companies.Canceling Item 181070 and reclassifying expansion tanks as Class 125 (instead of current Class 85) asproposed will result in estimated increased shipping charges of between 20% and 25%. In fact, one ofour tank manufacturers estimates that the changes in an LTL carrier's non-discounted tariff rate aremuch bigger. They estimate that changing the class from 85 to 125 raises the rate 41%. And, changing theclass from 85 to 200 (which is also in the CCSB proposal) raises the rate a whopping 128%.Given the current status of the economy, any increases in shipping costs must be carefully considered.Unnecessary increases create an economic hardship for the manufacturing sector. And, these increases inshipping costs will ultimately be passed onto consumers. This will cut down on consumer spending andultimately affect manufacturing levels. Reductions in manufacturing will result in lower shipping volumesand everyone will lose.WSC strongly recommends that CCSB make no changes at this time and continue expansion tanks(precharged and hydropneumatic) under classification 85 per Item 181070.Respectfully,Kathleen M. StanleyKathleen M. StanleyExecutive DirectorCopy to WSC Tank Manufacturers:JJ Troccoli, AO SmithJoe Lane, AmtrolChris VanHaaren, AmtrolBob Lombari, Flexcon IndustriesGerry Duggan, Flexcon IndustriesChris Lange, Pentair WaterJim Bradley, Pentair WaterNeal White, Pentair WaterCopy to WSC Board of DirectorsCopy to The Accord Group
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