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United States securities and exchange commission logo
August 8, 2022
James Todd
Chief Financial Officer
Landstar System, Inc.
13410 Sutton Park Drive South
Jacksonville, FL 32224
Re: Landstar System,
Inc.
Form 10-K for
Fiscal Year Ended December 25, 2021
Filed February 18,
2022
File No. 000-21238
Dear Mr. Todd:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 25, 2021
General
1. We note that you
provide more expansive disclosure in the section of your website
relating to
Environmental Stewardship than you provided in your SEC filings. Please
advise us what
consideration you gave to providing the same type of climate-related
disclosure in your SEC
filings as you provide on your website.
Risk Factors, page 12
2. Disclose the material
effects of transition risks related to climate change that may affect
your business,
financial condition, and results of operations, such as market trends that
may alter business
opportunities, credit risks, or technological changes.
3. Disclose any material
litigation risks related to climate change and explain the potential
impact to the company.
James Todd
FirstName LastNameJames Todd
Landstar System, Inc.
Comapany
August NameLandstar System, Inc.
8, 2022
August
Page 2 8, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
22
4. Your website reflects that you have adopted certain initiatives to
increase efficiencies and
reduce emissions such as equipping trailers with low rolling
resistance tires and
implementing the use of technology-based tools such as electronic
logging devices.
Revise your disclosure to identify all material past and/or future
capital expenditures for
climate-related projects. Please provide quantitative information for
each of the periods
for which financial statements are presented in your Form 10-K and for
any future periods
as part of your response.
5. To the extent material, discuss the indirect consequences of
climate-related regulation or
business trends, such as the following:
decreased demand for services that produce significant greenhouse
gas emissions or
are related to carbon-based energy sources;
increased demand for services that result in lower emissions than
competing
products;
increased competition to develop innovative new services that
result in lower
emissions;
increased demand for generation and transmission of energy from
alternative energy
sources; and
any anticipated reputational risks resulting from operations or
services that produce
material greenhouse gas emissions.
6. If material, discuss the physical effects of climate change on your
operations and results.
This disclosure may include the following:
severity of weather, such as floods, hurricanes, sea levels,
extreme fires, and water
availability and quality;
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have affected
or may affect your
major customers, suppliers, or third-party capacity providers;
decreased agricultural production capacity of your customers
located in areas affected
by drought or other weather-related changes; and
any weather-related impacts on the cost or availability of
insurance.
As applicable, your response should include quantitative information
for each of the
periods for which financial statements are presented in your Form 10-K
and explain
whether changes are expected in future periods.
7. We note the disclosure on page 18 of your Form 10-K regarding
regulations focused on
diesel emissions and matters related to climate change. Please tell us
about and quantify
compliance costs related to climate change for each of the periods
covered by your Form
10-K and whether increased amounts are expected to be incurred in
future periods.
8. If material, please discuss any purchase or sale of carbon credits or
offsets and the effects
on your business, financial condition, and results of operations. To
the extent applicable,
James Todd
Landstar System, Inc.
August 8, 2022
Page 3
ensure you provide quantitative information with your response for
each of the periods for
which financial statements are presented in your Form 10-K and for any
future periods.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Anuja Madmudar at (202) 551-3844 or Ethan Horowitz at
(202) 551-
3311 with any questions.
FirstName LastNameJames Todd Sincerely,
Comapany NameLandstar System, Inc.
Division of
Corporation Finance
August 8, 2022 Page 3 Office of Energy
& Transportation
FirstName LastName