January 4, 2022
VIA EDGAR TRANSMISSION
Office of Energy & Transportation
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | P.A.M. Transportation Services, Inc. | |
Form 10-K for the Fiscal Year Ended December 31, 2020 | ||
Filed March 5, 2021 | ||
File No. 000-15057 |
Ladies and Gentlemen:
The following is the response of P.A.M. Transportation Services, Inc. (“P.A.M.” or the “Company”) to the comment contained in the letter from the Office of Energy & Transportation (the “Staff”) to Mr. Allen W. West, dated December 20, 2021. For convenient reference, this response letter duplicates the text of the enumerated Staff comment, as well as the headings contained in the Staff’s letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Selected Financial Data, page 21
1. | We note your response to our prior comment indicates that you will provide clarifying disclosures regarding your metrics in future filings. Please provide us with your proposed revised disclosures based on the metrics provided in the Form 10-K for the fiscal year ended December 31, 2020. |
1 |
Response:
Below are the Company’s proposed revised disclosures based on the metrics provided in the Form 10-K for the fiscal year ended December 31, 2020, as specifically noted in the Staff’s initial comment dated November 30, 2021. Specifically, the Company proposes to supplement the Selected Financial Data table and footnotes in the Form 10-K to include the additional operating data and footnote disclosures marked as follows:
Year Ended December 31, | ||||||||||||||||||||
Operating Data: | 2020 | 2019 | 2018 | 2017 | 2016 | |||||||||||||||
Operating revenues, before fuel surcharge, for truckload services | 337,529 | 363,593 | 356,569 | 322,425 | 338,323 | |||||||||||||||
Operating revenues, before fuel surcharge, for brokerage and logistics services | 101,458 | 75,918 | 89,286 | 51,098 | 44,413 | |||||||||||||||
Operating ratio (1) | 92.3% | 97.1% | 90.7% | 96.6% | 94.8% | |||||||||||||||
Average number of truckloads per week | 6,859 | 8,405 | 8,420 | 7,134 | 6,827 | |||||||||||||||
Average miles per trip | 553 | 499 | 521 | 635 | 684 | |||||||||||||||
Total miles traveled (in thousands) | 193,481 | 213,048 | 222,738 | 229,392 | 237,266 | |||||||||||||||
Average trucks in fleet (2) | 2,003 | 2,075 | 1,901 | 1,835 | 1,891 | |||||||||||||||
Average miles per truck | 96,532 | 102,674 | 117,169 | 125,009 | 125,471 | |||||||||||||||
Average revenue, before fuel surcharge per truck per day (3) | $ | 863 | $ | 834 | $ | 923 | $ | 805 | $ | 797 | ||||||||||
Average revenue, before fuel surcharge per loaded mile (4) | $ | 1.91 | $ | 1.84 | $ | 1.71 | $ | 1.51 | $ | 1.53 | ||||||||||
Empty mile factor | 8.8% | 7.3% | 6.3% | 6.8% | 6.8% | |||||||||||||||
At end of period: | ||||||||||||||||||||
Total company-owned/leased trucks (5) | 2,013 | 2,130 | 2,031 | 1,721 | 1,855 | |||||||||||||||
Average age of company-owned trucks (in years) | 1.44 | 1.46 | 1.20 | 1.49 | 1.49 | |||||||||||||||
Total company-owned/leased trailers (6) | 7,220 | 7,081 | 6,397 | 5,795 | 5,699 | |||||||||||||||
Average age of company-owned trailers (in years) | 4.92 | 4.18 | 3.54 | 3.38 | 2.71 | |||||||||||||||
Number of employees and independent contract drivers | 2,996 | 3,242 | 3,345 | 2,969 | 3,216 |
____________
(1) | Total operating expenses, net of fuel surcharge as a percentage of operating revenues, before fuel surcharge. | |
(2) | Calculated as the average of the number of trucks in the fleet during each day within the period, including independent contractor trucks. | |
(3) | Consists of total operating revenues, before fuel surcharge, divided by average trucks in fleet, and further divided by 254 work days in each year, which excludes weekends, federal holidays and February 29 in leap years. | |
(4) | Consists of total operating revenues, before fuel surcharge, for truckload services, divided by total miles traveled, net of empty miles. | |
(5) | Includes the following numbers of independent contractor trucks: 355 in 2020, 553 in 2019, 597 in 2018, 560 in 2017, and 578 in 2016. | |
(6) | Includes the following numbers of leased trailers: 0 in 2020, 56 in 2019, 43 in 2018, zero in 2017, and 232 in 2016. |
If you have any questions or require further information, please do not hesitate to contact me at
(479) 361-5409.
Sincerely,
/s/ Allen W. West
Allen W. West
Chief Financial Officer
cc: | Via E-mail | |
Courtney C. Crouch, III, Esq. | ||
Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C. | ||
Jason M. Butler, Partner | ||
Grant Thornton |
2 |