We note your response to prior comment 5 stating that that indirect consequences of climate-related regulation or business trends have not been and are not expected to be material. Please describe the indirect consequences you considered in your analysis and tell us how you concluded that they were immaterial. Please ensure your response specifically addresses each item from our prior comment.

Decreased demand for goods and services that produce significant greenhouse gas emissions or are related to carbon-based energy sources

While we acknowledge some decrease in consumer demand for goods and services that produce significant greenhouse gas emissions, we do not believe this concern is currently materially driving our customers’ demand for our services.    Further, we believe that increased demand for alternative goods that address concerns about climate-change (i.e., goods that could be seen as replacements for goods that generate significant greenhouse gas emissions) could potentially offset such lower demand for goods we have historically shipped.  We believe demand for our services is generally tied to overall market activity and cannot at this time predict whether climate change will or could negatively impact the overall US economy.

Increased demand for services that result in lower emissions than competing products

As we have noted, intermodal transportation has significantly lower greenhouse gas emissions than truck-based transportation.  However, we do not believe emission concerns are currently a primary driver of our customers’ transportation procurement decisions or are materially affecting our business.  Our intermodal transportation service offering, while environmentally favorable compared to some alternatives, also generally offers a lower cost as compared to truck-based transportation, despite a longer transit time.  We have not found any clear indication that our customers are primarily basing their decision to use intermodal transportation on environmental considerations, as customers electing such mode of transportation are generally willing to accept longer delivery times in exchange for a lower transportation cost.

Increased competition to develop innovative new services that result in lower emissions

We continuously compete to provide more cost-effective services for our customers.  One element of our value proposition is to offer sophisticated load planning services that enable certain of our customers’ goods to be transported along with other customers’ shipped goods that are destined to the same or nearby destination, which facilitates lower overall transportation costs.  We invest heavily in information technology to remain competitive in this respect.  Aside from potential service offerings using electric tractors, which we are piloting and do not currently anticipate to be material to our business, our focus is on increased efficiency for our customers, which may result in lower transportation costs as well as lower emissions.   We believe we have addressed these risks in our Form 10-K in the risk factors titled “We operate in a highly competitive industry and our business may suffer if we are unable to adequately address potential downward pricing pressures and other competitive factors.” (noting “we compete with many other transportation and logistics service providers, some of which have … lower cost structures than us”) and “If we fail to maintain and enhance our information technology systems, or if we fail to successfully implement new technology or enhancements, we may be at a competitive disadvantage and lose customers.”

Increased demand for generation and transmission of energy from alternative energy sources

We have not experienced any meaningful customer demand for our use of alternative energy sources.  As noted in our response to Comment 4 of the Staff’s previous letter, the Company is exploring the use of electric tractors but does not expect its usage to materially impact the Company’s business, operations, capital expenditure needs, cash flow or profitability in the foreseeable future.  In the event alternative energy sources are specifically required by a customer, we would expect to reflect the increased cost of such requirement in the price we charge a given customer, such that the Company would not bear the incremental impact on profitability.

Any anticipated reputational risks resulting from operations and services that produce material greenhouse gas emissions.

The Company has not faced adverse reputational impact related to greenhouse gas emissions, but it will continue to monitor the potential for reputational risk as it recognizes its operations and services generate greenhouse gas emissions and that stakeholders’ views are evolving.

Please provide us with additional detail supporting your statement in response to our prior comment 6 that the physical effects of climate change have not and are not expected to materially affect your business. In that regard, we note your risk factors titled "Relatively small increases in our transportation and warehouse costs that we are unable to pass through to our customers are likely to have a significant adverse effect on our gross margin and operating income" and "Extreme or unusual weather conditions can disrupt our operations, impact freight volumes, and increase our costs, all of which could have a material adverse effect on our business results" on page 9. Please ensure you address each of the items specifically noted in our prior comment and provide quantitative information with your response.

severity of weather, such as floods, hurricanes, sea levels, extreme fires, and water availability and quality;

As noted above, in general, we do not believe that past severe weather events have materially impacted our business because our transportation equipment can be positioned away from such severe weather events.

quantification of material weather-related damages to your property or operations;

The Company has not suffered any incident involving weather-related property damage to its property exceeding $250,000 in at least the past ten years.  Due to the de minimis impact such weather-related damage to our property has had on our operations, we have not historically tracked such impact and are unable to quantify such impact, if any.

potential for indirect weather-related impacts that have affected or may affect your major customers or suppliers;

As noted above, while weather-related events, if severe enough, could broadly affect the U.S. economy and, by extension, our business, recent severe weather events have not indirectly and materially affected our business.  While such events could affect demand regionally on a temporary basis, we have found that there are offsetting demands requiring our transportation services.  We recognize our past experience is not an assurance of future outcomes, and that future weather events (individually or in combination) could affect our business and financial results.   We have included a risk factor to address this uncertainty, but do not currently see such risk as foreseeable or immediate enough to require additional disclosure in Management Discussion & Analysis section of our Securities Exchange Act of 1934 reports.

decreased agricultural production capacity of your customers located in areas affected by drought or other weather-related changes; and

Although the Company serves some customers in the broader food sector, our exposure to raw agricultural products is limited and we do not have visibility to the agricultural production capacity of our customers.

any weather-related impacts on the cost or availability of insurance.