also makes substantial use of motor common carriage, whose service it regards as an essential supplement to Cresco Lines' more specialized operations.

As for the quality of the for-hire motor carrier service it requires, Allied avers "it is absolutely essential that in addition to its contract carrier, Allied have reliable and dependable common carriers to provide flat-bed equipment on extremely short notice and make delivery when required." It points out that its plant is located 15 miles from Gary, Ind., the center of steel production in the Midwest. As a result, it points out:

Allied must compete for every available flat bed trailer going to the West Coast. Unfortunately, Allied does not swing the "big stick" some of the giant steel mills do, and, as a result, because of multiple-stop loads, hand unloading, guaranteed timed delivery, etc., Allied gets what equipment is left over. When the steel mills are busy, the available flat bed equipment is scarce, when the steel mills are not busy, carriers will call offering equipment for transportation.

It has used the services of several of the protestants in this proceeding, but contends that they do not consistently provide flat-bed equipment for loading when called on. TOFC service is not a feasible alternative to the kind of motor carrier service it needs. In the several months immediately prior to the hearing it had been using the services of applicant System Transport (apparently with an interchange with a separate connecting carrier at applicant's Green Bay plantsite origin point) at a rate of approximately eight truckload shipments per month. It found that service dependable, and it avers that it will continue to use applicant at least at the same frequency if this application is granted. Allied indicates that its marketing pattern involves a holding out to its customers of whatever delivery service they need: multiple-stop truckloads, small deliveries to construction sites, dams, power plants, et cetera. Allied states:

This particularized delivery pattern can only be accomplished by a highly specialized irregular route carrier, in single-line service since it is imperative that we have immediate contact and information as to the location of vehicles and the delivery times of vehicles transporting our products. It is mandatory that we be completely informed with the facilities of distribution since our advertising emphasizes delivery will be made when the product is required.

In general, its customers tend to require unloading from the side of the trailers at jobsites. Customers often will either unload by hand or arrange for temporary help or rent a forklift or crane to unload the pipe at the point of use. Because of this type of unloading, Allied imprints on each bill of lading "the driver must help unload." It also specifies that the carrier must call 24 hours before delivery. Allied guarantees to its customers that such notification will be given, and Allied will absorb any additional charges that might accrue as a result of the carrier's failure to so notify customers. Allied has relatively recently been warehousing plastic conduit pipe, built to its own specifications by another manufacturer, so that it would be able to comingle these products with its steel conduit as a convenience to its customers. It has not yet been holding out that type of mixed shipment service to its west coast customers but it does plan to do so. Its marketing staff anticipates that eventually about 50 percent of its shipments will contain some percentage of these plastic products.

Allied has used the services of protestant Sammons in the past, having been a supporting shipper in a prior proceeding in which Sammons was granted authority to provide this type of service out of the Chicago area. In 1971 Allied found the

Sammons' service satisfactory, since the carrier was able to provide the requested service on 93 percent of the occasions requested. But in 1972, Sammons could provide the services as requested on only 23 of 35 tendered shipments. In 1973 Allied offered Sammons only six loads, since it had not been happy with the Sammons service in 1972. Allied did not describe the relative quality of the 1973 Sammons service, except to note that Sammons did not call on Allied to find out why this substantial traffic source had dried up. In early 1974, Allied called on Sammons for service on two occasions, for two truckloads each time, February 21 to California destinations and April 4 to Salt Lake City, but Sammons was not able to furnish the equipment needed.

Except for sporadic LTL shipments, Allied has not used the services of RingsbyUnited to the proposed destination area. Ringsby-United has solicited Allied's truckload volume traffic to other areas, but not to the west coast.

Midwest Forging and Manufacturing Company produces various small forgings that are used in railroad and farm machinery and welded tubing, its principal product, at Chicago Heights. Its market area includes the west coast where it has distributors or representatives who handle the ultimate sales. The tubing ranges between one-half inch and 3 inches in diameter, with lengths between 10 and 30 feet. Normally, a piece of tubing will weigh between 20 and 80 pounds. The tubing is bundled and banded for shipment, in gross weights as low as 300 pounds or as high as 45,000 pounds in some exceptional cases.

Ordinarily its shipments are made to locations generally in the area between Los Angeles and San Francisco, and only rarely to Oregon or Washington. Rail service is used only occasionally. Annually this California tonnage totals between 400,000 and 500,000 pounds. For the past several years, this traffic has been transported through a shipper association which forwards the freight onward to California in a procedure not detailed on this record. Shipper's witness at the hearing did not recall using the services of the protestants on this California traffic. On one or more occasions "some years ago" it used trucking service which included applicant System Transport as an interlining carrier, and it found that service satisfactory. It avers that it would use System Transport's services if the application is granted, but it is vague and indefinite about how much traffic it would tender applicant. That decision would turn on such factors as rate levels and the quality of service ultimately provided.

Ringsby Truck Line, Inc., Ringsby Pacific Limited, United-Buckingham Freight Line, and Norwalk Truck Lines, Inc., collectively hold numerous certificates of public convenience and necessity authorizing operation as common carriers of general commodities, with the usual exceptions, over various regular and irregular routes extending, as pertinent here, between the Midwestern States here involved and the Western States. These protestants have been operated as a single system for several years under temporary authority issued by this Commission. In Ringsby Truck Lines-Control-United-Buckingham, 116 M.C.C. 588 (1974), the Commission has granted conditional approval of the purchase by Ringsby Truck Lines of the operating rights and property of United Buckingham as part of a complex series of related financial transactions. For all practical purposes in the present proceeding, therefore, these carriers are considered as providing service to the public as a single carrier system, Ringsby-United.

As pertinent here the Ringsby-United system is authorized to originate shipments of the considered traffic at numerous points along regular routes extending between Youngstown, Ohio, through northern Ohio, southern Michigan, northern Indiana, and the Chicago area and transport them over its network of regular routes to numerous

destination in California, Oregon, Washington, and Montana. It operates numerous terminals at points throughout the Ringsby-United service territory.

The major portion of the Ringsby-United operation is as a general freight service conducted between its terminals on fixed schedules. More pertinent here, it also operates a special commodities division to handle types of traffic that tend to need more specialized equipment or handling. Whereas the regular-route service is performed with teams of employee drivers working between scheduled relay points between its terminals, the over-the-road trucking in the special commodities division is performed by owner-operators driving straight through from origin to final destination. The equipment of the general-commodities division includes approximately 1,900 semitrailers of various types and sizes, including approximately 116 open-top flat beds. These units are available for service in the special commodities division, in Ringsby-United's holding out of service on iron and steel traffic. The equipment of the special commodities division itself consists primarily of refrigerator trailers, but also includes 12 open-top flat beds and 17 converta-vans, trailers with removable, self-storing sides that are used interchangeably as vans or flat beds. The special commodities division has terminals at Youngstown, Sandusky, and Cleveland, Ohio, Chicago, Ill., Omaha, Nebr., Sioux Falls, S. Dak., Vancouver, Wash., Sacramento and Los Angeles, Calif., and Denver, Colo. It has suitable empty equipment available for loading on a daily basis in the proposed origin area. It seeks to handle the type of traffic involved and is experienced in doing so. It has provided the kind of service involved in this proceeding for six of the supporting shippers from midwestern origins to the west coast including Ryerson, Van Huffel Tube Division, Youngstown Sheet and Tube, A. M. Castle, Midwest Forging, and Docummun Metals. It has periodically tri- leased other carriers' equipment on shipments of iron and steel articles from the Chicago area to west coast destinations, primarily due to certain labor relations difficulties with members of the steel haulers local from the Chicago area. Between March and September 1973, for example, Ringsby-United tripleased equipment from applicant System Transport on some 32 occasions on shipments of iron and steel products from the Chicago area, primarily to Washington destinations for Ryerson as the shipper.

Hilt Truck Lines, by tacking several separate operating authorities, is authorized to transport (a) pipe, conduit, and tubing from points within a 50-mile radius of Melrose Park, III., an area which includes Chicago, via a gateway point in Illinois about 90 miles southwest of Chicago to points in California, Idaho, and Montana; (b) iron and steel articles from that same origin area via Livingston County, Ill., which lies about 60 miles southwest of Chicago, to points in Oregon and Washington; and (c) iron and steel articles, from that same origin area, via a gateway point about 100 miles due west of Chicago and through another gateway in eastern central Nebraska to points in California. The Chicago origin area is served by Hilt under a temporary authority pending final decision of the Commission in an application wherein Hilt seeks to acquire that authority permanently. It also offers a through service on such traffic originating on the lines of general freight carriers in Ohio and Michigan, such as American Transit Lines, in which there is no need for transfer of lading at the point of interchange at Chicago. Its equipment includes 20 flat-bed trailers and, at the time of the hearing, was "taking delivery" on 35 additional flat-bed trailers. As pertinent here it has terminal facilities at Chicago and either terminals or agency arrangements at several locations in California from which it also conducts outbound operations. Sammons Trucking, as pertinent here, is authorized to transport building materials from Chicago to points in Montana and to transport iron and steel articles from

Chicago to points in Montana, Washington, and Oregon, and it conducts operations under that authority. It handles this type of westbound traffic from Chicago Heights on through rates through an interline arrangement with a local carrier. It also interlines this type of traffic at Chicago from Ohio and Michigan origins, traffic originating at the service points of a number of other carriers such as Hennis. In some instances its flat beds are used for the through movement, being trip leased by the origin carrier to the Chicago interline point, but in most instances, this connecting carrier service involves physical transfer of lading at a Sammons facility at Chicago. That facility is a 10,000-foot warehouse space, held on a long-term lease, serviced with its 50-ton overhead crane. Normally, the transfer of lading is made from inbound trailer to outbound trailer, but at times, for various reasons, the load is unloaded from the inbound trailer onto the ground or into the warehouse for a period of time before being loaded onto a trailer for movement to final destination. Sammons Trucking also operates as a carrier of lumber from Western States to the Midwest and does have equipment regularly becoming empty in this area. In addition to the Chicago facility, it has terminals at Missoula, Mont., Vancouver, Wash., and San Francisco, among other places. The number of deliveries it has been averaging in Ohio and Michigan, and thus the number of units available for reloadings, has ranged between 8 and 10 per week. To the Chicago area, northern Illinois and Indiana, the average has been around 60 loads per week. At the time of the hearing its relevant fleet of equipment included 192 tractor-flat-bed trailer units. The cabs are all three-axle sleepers and the trailers all are 40-foot flat beds, equipped for handling this type of traffic. It offers jobsite deliveries and multiple pickups and deliveries. Its drivers will help unload shipments and will give advance notice of deliveries, if so requested.

During March 1974 it handled 77 shipments of iron and steel from origins within the Chicago commercial zone to points in Idaho, Montana, Oregon, and Washington, and 32 shipments from origins in Michigan and Ohio, as a connecting carrier to that same destination area.

Sammons maintains that on the occasions it has been unable to furnish the flat-bed equipment when requested by these shippers, the shortages have been of very limited duration.

Hennis Freight Lines, Inc., of Winston-Salem, N.C., is a general-commodity motor common carrier operating over a network of regular routes, extending, as pertinent here, between numerous points in Ohio on the one hand and Chicago on the other. It is not a formal protestant in this proceeding, but evidence of its operations as a connecting carrier was presented. On a regular basis it originates shipments of iron and steel articles at Ohio mills and transports them to the Sammons facility at Chicago where they are transloaded onto Sammons vehicles for delivery to destinations in the Western States. Hennis has empty equipment available for loading in the Ohio area.

There are two basic justifications urged in support of applicant's request for the new operating authority sought in this proceeding, the particular needs of the supporting shippers for applicant's proposed service and the more generalized need of applicant for a backhaul to its principal base of authorized operations. However, the facts presented on this record do not justify issuance of the authority sought, whether those justifications of the applicant are considered singly or jointly.

Collectively, the protestants are authorized and equipped to provide the type of services requested by the supporting shippers. Although it is true that at times several of these supporting shippers have experienced difficulty in securing flat-bed trailers when they request them, the evidence shows that the supporting shippers have made

no adequate investigation or testing of the services of the existing common carriers. When viewed in the strongest light favorable to applicant, the essence of the supporting shippers' testimony is that they cannot always rely upon presently authorized common carriers to furnish flat-bed trailers when requested for transcontinental movements of iron and steel and related articles to the west coast. In general, however, the shippers present a confused picture of their actual present pattern of usage of available common carrier service for this traffic. And, while they do not seem able to count on existing carriers to furnish all of the equipment they request, these same shippers, in return for their support here, on the other hand seem not to have demanded much proof from the applicant of precisely what it would do to ameliorate that situation. These supporting shippers, for example, support applicant's proposal with ritual language: that they need the "specialized" and specially responsive service applicant offers; and that protestants are not sufficiently responsive since they do not furnish enough equipment when requested. But applicant System Transport does not really offer to add to the supply of available equipment in any significant measure, if at all. Its relevant operations are founded on a fleet of 34 owner-operator units, and it does not promise any new investment of its own in tractors or trailers. Apparently any increment to applicant's own fleet of owneroperators—who are independent contractors not employees-would have to come from some form of reallocation of owner-operators already performing in this or related transportation markets. Yet applicant does not show whether, how, or why such a reallocation would take place. Applicant engages in exempt transportation westbound from the Midwest, but the basic patterns of these operations-origins, destinations, commodities, seasonality, profitability—are not disclosed on this record. Presumably some of the equipment used in these operations would become available to iron and steel shippers in the Midwest, but one may only speculate how much, how often, how reliably, and under what conditions or assumptions. From the facts shown here it seems that authorizing the proposed service would give the supporting shippers little more than one additional telephone number to call to learn whether flat-bed equipment might be available from a given supply of owner-operators performing in this transportation market. Applicant does not show that it will provide any stronger incentives to attract independent owner-operators than other certificate holders already functioning in this market. The applicant does not show that it has any "better mousetrap" or any other procedures or devices to furnish equipment on the "extremely short notice" claimed to be needed by supporting shipper Allied, for example. As to applicant's past performances, Allied's recent satisfactory experience with applicant's service has been of short duration and it is not enough to outweigh the other factors in this complex equation of equipment supply and demand in this transportation market.

Existing common carrier services are not here shown inadequate in any way that applicant's proposal has reasonable potential for alleviating. In this situation the general rule against authorizing new common carrier services, unless existing common carrier services have been tested and found wanting, should apply, unless applicant can show some additional special factor. Here applicant asserts need for an authorized backhaul. Such an argument bears most careful consideration in a proceeding of this nature. As we recognize today more than ever before, national transportation policy requires elimination and avoidance of wasteful use of energy and economic resources. But here there has been no assuring demonstration by applicant that any real economic or energy savings would be achieved under its proposal. In fact, granting System Transport authority it seeks to operate into California from the Midwest would