[Swift Transportation Letterhead]
December 13, 2005
VIA EDGAR AND FEDERAL EXPRESS
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Mail Stop 3561
Michael Fay
U. S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: Swift Transportation Co., Inc.
Form 10-K: for the Fiscal Year ended December 31, 2004
File No. 000-18605
Dear Mr. Fay:
This letter responds to the Staff's comments to the above referenced filing
of Swift Transportation Co., Inc. (the "Company"), as set forth in the Staff's
letter dated November 18, 2005. For your convenience, the headings and
paragraph numbers in our letter correspond to the headings and paragraph numbers
in the Staff's letter.
Form 10K: for the Fiscal Year Ended December 31, 2004
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SFAS 131
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1. We supplementally advise the Staff as follows:
We operate a fleet of tractors to transport a variety of freight for
customers using various forms of trailers such as flatbeds,
refrigerated vans, double vans, specialized trailers, and vans ranging
in lengths of 48 feet to 57 feet. Approximately 90% of our trailer
fleet is made up of 48 to 57 foot vans. While we do track revenue by
tractor, we do not track revenues from external customers by the
various types of trailers utilized. We believe our business is
essentially the service of transporting freight for customers using
whatever trailer is appropriate, the vast majority of which is single
vans. Therefore, we do not believe the disclosures described in SFAS
131 paragraph 37 are applicable.
Michael Fay
U.S. Securities and Exchange Commission
December 13, 2005
Page 2
Capital Commitments and Expenditures, page 27
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2. We supplementally advise the Staff as follows:
Our 2004 capital expenditures are detailed below in millions:
Revenue equipment:
Tractors $326,351
Trailers 41,264
Facilities 50,444
Other 11,162
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Total $429,221
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We capitalize, at cost, non-revenue equipment expenditures which
increase the service potential of the asset. Additions that are in
substance repairs are charged to operations when incurred.
Expenditures exceeding thresholds from $2,500 to $5,000, depending
upon the nature of the item, are capitalized. For example, computer
equipment is capitalized if it exceeds $5,000.
We will expand our future filings to discuss in greater detail our
capital expenditures and the amount we anticipate spending over both
the short and long term.
3. We supplementally advise the Staff as follows:
We consider our evaluation of return on capital investments
proprietary and integral to our pricing process when competing for
freight services in the marketplace. As a result, we anticipate
disclosing, in general terms, the basic criteria we use to evaluate
capital investments and the reasons for such investments. However, we
believe disclosing our cost of capital would negatively affect our
ability to compete for freight services.
Closing
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If you have any additional questions or comments after reviewing
this response letter, we would appreciate an opportunity to discuss these
comments or questions with the Staff
Michael Fay
U.S. Securities and Exchange Commission
December 13, 2005
Page 3
prior to the distribution of another comment letter. Please contact me with any
questions concerning this letter at (623) 907-7451.
Very truly yours,
Swift Transportation Co., Inc.
By:/s/ Glynis Bryan
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Glynis Bryan
Executive Vice President
and Chief Financial Officer