Fire Truck Antitrust Litigation

Recent antitrust litigation against major fire truck manufacturers raises fundamental questions about market concentration, pricing behavior, supply constraints, and information-sharing among rivals. This article will provide an economic framework to evaluate whether observed marketplace outcomes including rising prices, long lead times, and information-sharing are consistent with coordinated anticompetitive conduct.

Key Takeaways

The fire truck manufacturing industry has become dominated by a small number of large players including REV Group, Oshkosh, and Rosenbauer who together control roughly 80% of the market. Decades of private equity-driven consolidation combined with high barriers to entry produces conditions that economic theory associates with an increased potential for coordinated behavior.
Despite increasing demand since 2020, industry shipments of fire apparatus declined between 2020 and 2022. Meanwhile, backlogs at major manufacturers grew by hundreds of percent. Standard competitive economic theory would predict output expansion in response to rising demand.
While input costs for aluminum, steel, and labor did rise meaningfully during the pandemic period, those costs have since moderated. Yet manufacturers recorded record profits, suggesting that cost increases alone do not fully account for observed price increases. Econometric modeling can help evaluate this.
Economists bring proven and structured methodologies including but-for pricing models, benchmarking, and capacity utilization analysis to assess whether observed market outcomes are consistent with coordinated anticompetitive conduct. These tools will be central to quantifying overcharges and evaluating harm to fire truck purchasers.

Background: Emerging Fire Truck Antitrust Litigation

Multiple antitrust class-action cases against fire truck manufacturers have been consolidated in the U.S. District Court for the Eastern District of Wisconsin. The case is named In Re: Fire Apparatus Antitrust Litigation. A “Fire Apparatus” is “[a] vehicle designed to be used under emergency conditions to transport personnel and equipment or to support the suppression of fires or mitigation of other hazardous situations.”[1] Fire trucks are one type of fire apparatus. For simplicity, this article uses “fire trucks” to refer to fire apparatus generally.

Fire truck manufacturers are alleged to have engaged in coordinated pricing and output restrictions, resulting in inflated pricing and persistent supply backlogs. Plaintiffs contend this behavior coincided with elevated revenues and profit margins for defendants REV Group, Oshkosh Corporation, and Rosenbauer America (“Defendants”).

Also named as a Defendant is the Fire Apparatus Manufacturers’ Association (“FAMA”). FAMA is a trade organization whose membership includes Defendant manufacturers. FAMA is alleged to have hosted regular meetings which Defendants attended, and facilitated their exchange of competitively sensitive, nonpublic information and economic data.

Plaintiffs further assert that Defendants’ conduct led to constrained supply and inflated prices, with the result being that fire truck purchasers, such as municipalities and fire departments, allegedly paid supracompetitive prices dating back to at least as early as 2016.

From an economic perspective, these allegations raise questions about whether observed market structure and outcomes (in particular, rising prices and extended lead times) are consistent with competitive conditions or are indicative of coordinated conduct within a highly concentrated industry. This article offers economic insights in each of these areas.

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Market Structure: Concentration and Barriers to Entry

When assessing market dynamics, economists typically begin by examining the structure of the market. Market concentration and barriers to entry are two foundational considerations, as they directly affect the ability and incentives of firms to exercise market power. Economic theory suggests that having a small number of firms makes coordinated behavior easier to accomplish and more likely to succeed, especially when firms can use information-sharing to monitor each other’s actions and respond accordingly.

Barriers to entry, which can include regulatory hurdles, high capital requirements, and technical expertise, can reinforce these market dynamics by limiting the ability for a new competitor to enter the market and discipline prices. In that regard, it is important to consider not only whether new competitors could enter the market at all, but also whether entrants’ success was stifled by the incumbent firms’ conduct.

While these factors alone do not necessarily imply anticompetitive conduct, they provide an important context for evaluating observed pricing and output patterns.

High Market Concentration

According to an April 15, 2025 United States Senate letter from Elizabeth Warren and Jim Banks to Edward Kelly (General President, International Association of Fire Fighters), “REV Group controls the largest share of the fire truck manufacturing market, at approximately 33 percent,” while “independent companies make up only 20 percent of the market” as of 2023.^[2] This indicates that leading firms including REV Group, Oshkosh Corporation, and Rosenbauer America have a combined market share of roughly 80 percent of the market.

From an economic perspective, high levels of concentration may create conditions in which firms face reduced competitive pressure (due to the limited number of credible competitors) and therefore are more sensitive to the behavior of rivals.

How to Count the Number of Firms and Measure Concentration

Cases involving alleged collusion also raise questions as to how to measure concentration and what counts as a “firm.” Consolidation (and thus increased concentration) can occur even without the elimination of existing brand names. From a superficial perspective, there may appear to be the same number of brands as before, even as industry ownership is “rolled up” under a small number of owners.

From an economics perspective, it is not just the number of brands or corporate entities that matters when evaluating the potential for anticompetitive conduct. Rather, what matters is control over those brands or entities. Multiple brands or subsidiaries, if they are controlled by the same entity, are properly treated as a single “firm” from an economics perspective.

Consolidation Trends

Over the past twenty years, there has been a reduction in the number of independent competitors, largely due to private equity acquisitions and roll-ups.[3] This has contributed to a consolidation of companies into a smaller number of larger, vertically integrated firms.

REV Group was acquired by private equity company American Industrial Partners (“AIP”) in 2006.[4] Since then, REV Group/AIP has acquired more fire apparatus companies, including E-ONE (2008)[5], KME (2016)[6], Ferrara (2017)[7], and Spartan (including Smeal, Ladder Tower, and UST) (2020).[8]

REV’s acquisition of Spartan is particularly noteworthy, as REV viewed it as an opportunity to “increase[] the Company’s market share in several key product categories” through vertical integration with an “upstream” producer of fire truck cabs and chassis.[9]

Oshkosh, which owns the Pierce brand, has also acquired numerous fire apparatus companies. In 2021, Pierce acquired Boise Mobile Equipment, a premier provider of wildland firefighting vehicles and products.[10] In 2022, Oshkosh acquired Maxi-Metal, Inc., a “leading innovator of mission-critical vehicles and essential equipment” that serves fire and emergency professionals.[11] Aside from these third-party manufacturers, Oshkosh (through subsidiaries and dealers) also acquired related brands such as Schuhmacher Fire Equipment (2018)[12], Superior Equipment (2019)[13], Minuteman Fire and Rescue (2019)[14], Emergency Vehicle Specialists (2023)[15], Churchville Fire Equipment (2023)[16], and Halt Fire Inc. (2025)[17].

Rosenbauer also acquired fire apparatus companies, including the remaining 25 percent of General Safety Equipment Corp in 2022, which provided Rosenbauer full control of the company.[18] In 2023, Rosenbauer announced a partnership with IKON Fire, LLC for fire apparatus sales and service in Colorado and Wyoming.[19]

The above transactions reflect a sustained pattern of consolidation among leading fire apparatus manufacturers and their affiliated subsidiaries and dealers. As a result, the industry has become increasingly concentrated with a small number of firms exerting ever-greater control over manufacturing, distribution, service, and sales.

Barriers to Entry

New firms attempting to manufacture fire trucks face significant challenges in entering and competing effectively. These barriers to entry include high upfront capital investment costs, economies of scale and scope, specialized manufacturing processes, long production cycles, regulatory compliance, and long-established relationships with municipal buyers.

As noted above, the presence or absence of barriers to entry matters because it determines whether incumbent firms will face meaningful competitive pressure from new entrants. If there are high barriers to entry, incumbent firms would likely face limited competitive pressure from new entrants.

Alleged Anticompetitive Conduct: Economic Theories of Harm

The anticompetitive conduct alleged in these cases can be described as (1) information exchange, such as the sharing of confidential and competitively sensitive information and economic data among supposed rivals; (2) coordinated suppression of supply; and (3) coordinated efforts to fix, raise, maintain, or stabilize prices at elevated levels.[20]

1. Information Exchange as a Coordination Mechanism

Exchanging competitively sensitive information and economic data through industry associations has become an increasingly hot topic in the world of antitrust and is currently alleged to have occurred across a range of industries including the one at issue here. While information sharing can serve procompetitive purposes, it may raise concerns when it involves confidential or competitively sensitive information and/or economic data. For example, exchanging pricing, cost, production, or other strategic information can facilitate coordination across competitors and reduce uncertainty in ways that make collusion easier.

REV Group (E-ONE, KME, Ferrara, and Spartan), Oshkosh (Pierce), and Rosenbauer are all members of FAMA. The cases allege that FAMA enabled manufacturers to share competitively sensitive information resulting in supply suppression and artificially inflated prices.[21] An important requirement for successful collusion is the ability of participants to monitor compliance with the collusive agreement. FAMA provided statistics and reports—containing very detailed information on trucks, parts, and more—that allegedly gave Defendants access to competitively sensitive information that enabled them to monitor compliance.[22]

2. Output Restriction and Supply Constraints

The cases allege an intentional scheme to increase the backlog of unfulfilled orders. This backlog is alleged to have stemmed from Defendants’ suppression of supply. Instead of expanding their output in response to increasing demand, Defendants are alleged to have prevented output expansion and thus diverted the excess demand into their backlog. The backlog at each of the major suppliers has grown substantially since 2020.

As shown in Figure 1 below, REV Group’s backlog increased from $708 million in 2018 to $3.7 billion in 2023, an increase of 409 percent.

As shown in Figure 2 below, Oshkosh saw similar increases in their backlog, which rose from $970 million in 2019 to $6.6 billion in 2025, a 580 percent increase.

Rosenbauer’s president Mark Fusco confirmed that Rosenbauer also experienced an increase in backlog in 2022, stating that the company had “the strongest order backlog in company history.”[23]

3. Coordinated Efforts to Fix, Raise, Maintain, or Stabilize Prices at Elevated Levels

These cases are still in their early stages, and presumably Defendants will be asked to produce data and documents which might help answer the question of whether there were coordinated efforts to fix, raise, maintain, or stabilize prices at elevated levels.

In addition to Defendants’ own documents and data relevant to the presence or absence of coordinated efforts, economists can turn to a combination of public data and economic theory. For example, standard economic theory suggests that the competitive response to this sustained increase in demand would be an increase in output and possibly entry by new competitors. However, this was not the case.

The industry has experienced record-high backlogs and orders since 2020. Yet industry shipments of fire apparatus decreased between 2020 and 2022, falling below the 2011-2019 average.[24] See Figure 3 below. Basic economic theory would suggest that an increase in demand combined with flat or reduced output would lead to higher equilibrium prices. The cases allege that this is exactly what has played out in the market, with prolonged delivery times triggering massive price increases.[25]

Source: FAMA Releases Fire Apparatus Industry Update, Fire Apparatus Manufacturers Association (June 17, 2025), https://www.fama.org/fama-releases-fire-apparatus-industry-update/.

Are Price Effects Justified by Normal Competitive Behavior?

Price increases are not necessarily anticompetitive, as they may reflect increases in cost or quality improvements. Thus, an important question to ask is whether the observed price increases are, in fact, warranted by natural competitive behavior.

However, this is not to say that a cost increase or product improvement will automatically invalidate claims of anticompetitive price inflation. In fact, cost increases have been used in the past as excuses for price increases that were determined to have been anticompetitive.[26]

Economic Indicators of Potential Collusion

Economists can help assess alleged collusion and other anticompetitive conduct by analyzing industry characteristics, pricing behavior, market shares, and concentration metrics. While none of these are dispositive by themselves, economists can opine on whether observed market outcomes are consistent with collusion.

Parallel Pricing Behavior

Parallel pricing refers to a pattern in which competing firms adjust their prices in similar ways over time. This can arise with firms independently responding to natural market conditions, but it also can indicate coordinated conduct. If the parallel pricing behavior cannot be explained by competitive dynamics (e.g., increases in cost) then this may suggest that the parallel pricing is due to coordinated conduct. To address this issue, economists will typically construct an econometric model that predicts but-for prices which can then be compared to the actual prices in the market.

Stable Market Shares

Market shares provide a measure of a firm’s relative size and competitive position within a market. Economists can use market shares to assess market concentration and competitive effects. If prices unexpectedly rise for some competitors but market shares remain relatively stable over time, it may suggest that there is limited competition among rivals.

Stable or Elevated Margins

Margins refer to the difference between a product’s price and cost and are usually a strong predictor of a firm’s overall profitability. In a competitive market, economists expect margins to fluctuate as firms respond to changes in cost, demand, and competitive pressures from rivals.[27] Margins that are persistently stable and/or elevated—especially in the face of changing market conditions—may suggest limited competition, which can be consistent with coordination among firms.

Persistent Supply Delays

Persistent supply delays refer to continuous or recurring disruptions in the production and delivery of goods that extend beyond what would be expected under normal market conditions. While, broadly speaking, supply delays are not necessarily uncommon, those that seemingly occur under stable market conditions and are persistent in nature may indicate reduced competitive pressure to meet market demand. In certain instances, this can suggest firms limiting output or failing to compete aggressively on output/delivery.

Distinguishing Coordination from Competitive Outcomes

Market outcomes must always be carefully evaluated to determine whether they are the result of competition or coordinated conduct. Parallel pricing, stable market shares, stable and elevated margins, and persistent supply delays can theoretically arise in competitive markets. Of course, coordinated anticompetitive conduct could also contribute to these patterns, particularly when they are persistent, closely aligned across firms, and unexplained by market fundamentals. Given this complexity, economists must assess the totality of the evidence—including firm behavior, market conditions, market outcomes, and timing—to distinguish between competitive dynamics and coordination.

Alternative Explanations of Market Outcomes

Historically, fire truck manufacturers could estimate labor and material costs with a reasonable degree of confidence. However, more recently there have been various factors impacting labor and material costs including inflation, the Pandemic, and tariffs.[28]

Rising Costs

1. Material Costs

One of the primary material costs for fire truck manufacturers is aluminum.[29] As shown in Figure 4 below, the price of U.S. Midwest Aluminum fluctuated between $0.75 and $1.28 per pound between January 2010 and December 2019. From 2020 to March 2022, the average price per pound rose significantly to a high of $2.00, but it has since fallen to an average of $1.27 in 2023 and 2024.

Steel is another prominent material input for fire truck manufacturers.[30] As shown in Figure 5 below, the adjusted closing price of U.S. Midwest Domestic Hot-Rolled Coil Steel fluctuated between $391 and $920 per ton between January 2010 and December 2019. From January 2020 to September 2021, the price shot up to a high of $1,900 per ton. Since then, the price has fallen to an average of $898 per ton from 2022 to 2024.

Looking at two input costs alone does not tell the whole story. However, both aluminum and steel prices did increase substantially in 2021 and 2022, partly due to the pandemic shock followed by a surge in economic activity.[31] Since that time, material costs affecting fire truck manufacturers have decreased and are exhibiting a consistent trend that is above the 2010-2020 average but well off the highs experienced in 2021 and 2022. Econometric analysis enables an economist to account for the expected effects of these cost fluctuations on Defendants’ prices absent coordination.

1. Labor Costs

Labor is another major cost affecting fire truck manufacturers.[32] This is because fire trucks are highly specialized vehicles, in some cases custom built, and their production is heavily reliant on skilled workers such as welders, electricians, and mechanics.[33] As shown in Figure 6 below, unit labor costs for the manufacturing sector as a whole have risen consistently in recent years. The increasing unit labor costs indicate that wages are rising faster than productivity.

Increasing Demand

According to FAMA, orders for new mainline fire trucks reached 5,946 per year from 2021 to 2023. This compares to average orders of 4,169 per year during the prior decade.[34]

Despite the increasing labor and materials costs discussed above, fire truck manufacturers have seen record profits,[35] suggesting that increases in cost do not fully explain the increase in prices. This raises economic questions about whether fire truck manufacturers are using their market power to increase prices to supracompetitive levels. Providing a complete answer to this question may require additional, detailed data from the fire truck manufacturers themselves.

Economic Tests and Frameworks

Economists have a unique set of tools to assess how markets function, how prices are determined, and how resources are allocated. These tools help simplify complex real-world situations into economic models that can be analyzed and understood. In practice, some common tests and analytical frameworks an economist can use include:

But-for analysis: Estimates what prices would have been in the absence of a specific event or course of conduct.
Benchmarking against comparable industries: Compares pricing behavior, margins, etc. across similar markets to identify unusual patterns.
Capacity utilization analysis: Examines the degree to which producers are using their production capabilities, to understand how supply constraints or excess capacity are influencing prices.
Event studies around pricing changes: Analyzes how prices respond to specific events over time to identify causal relationships and broader market reactions.

Methods such as these enable economists to analyze claims of alleged anticompetitive conduct, including in the Fire Apparatus Antitrust Litigation. This can involve testing hypotheses, evaluating market behavior, and drawing reliable conclusions about pricing behavior and market outcomes.

Damages and Impact on Municipal Buyers

Many of the claims against the fire truck manufacturers are brought by municipalities that purchase fire trucks from Defendants. These municipalities presumably expect competitive pricing to help manage limited public budgets and ensure efficient allocation of taxpayer resources. However, if prices were artificially inflated due to the alleged anticompetitive conduct, this would result in municipal buyers paying more than they should have, yielding harm to municipalities in the form of overcharges.

Overcharge Estimation

Overcharges refer to the amounts that purchasers paid in excess of the amounts that would normally correspond to existing supply and demand factors. In terms of fire trucks, the overcharge is what municipalities paid in excess of the prices that would have prevailed in a but-for world absent the alleged misconduct.

Estimating overcharges requires constructing a reliable benchmark to predict what the pricing would have been absent the challenged conduct. Economists have several approaches at their disposal, including creating a but-for pricing model, comparing the affected period to an unaffected “yardstick” period, or benchmarking against similar industries or products. Which approach is best suited for the allegations against the fire truck manufacturers depends on various factors that cannot be accurately assessed without access to the production of documents and data.

Budgetary and Public Safety Implications

Overcharges might not be the only economic harm at issue in cases against fire truck manufacturers. Aside from claims that buyers paid more than they should have, buyers were also forced to delay purchases and extend the life of aging equipment given the stark rise in backlogs. This could have led to a broader economic cost in the form of reduced service quality and increased risk exposure that ultimately should be considered.

Key Economic Questions Going Forward

With cases and allegations stacking up against fire truck manufacturers, there will be several key economic questions going forward such as:

Can observed pricing patterns be explained by cost and demand fundamentals alone?
What impact did information-sharing through FAMA statistics and reporting have?
What is the appropriate competitive benchmark?

Conclusion: Why Economic Analysis Will Be Central

Most cases involving complicated economic questions, vast amounts of data, and complex market dynamics benefit from involving an experienced economist early in the process. Economic analysis provides a structured and rigorous framework for gathering and evaluating evidence and quantifying overcharges.

In these cases against fire truck manufacturers, where pricing behavior, supply backlogs, and the sharing of competitively sensitive information are central allegations, economic analysis is particularly important. These factors require careful, data-driven analysis to distinguish between oligopolistic and coordinated anticompetitive conduct.

By relying on an experienced economist to apply established methodologies, legal teams can expect well-supported analyses demonstrating impact of the challenged conduct on purchasers and the extent of any overcharges, as well as clear and objective conclusions grounded in the facts and economic evidence.

Referencias

[1] National Fire Protection Association, 1900: Standard for Aircraft Rescue and Firefighting Vehicles, Automotive Fire Apparatus, Wildland Fire Apparatus, and Automotive Ambulances (2024), §3.2 NFPA Official Definitions.

^[2] Letter from Senator Elizabeth Warren and Jim Banks to Edward A. Kelly, General President, International Association of Fire Fighters (April 15, 2025),https://www.warren.senate.gov/imo/media/doc/_firefighters.pdf.

[3] Whitney Downard, Pa. Fire Companies Feel the Pinch as Private Equity Buys Up Truck Manufacturers, Pennsylvania Capital-Star (March 31, 2026), https://penncapital-star.com/transportation-infrastructure/pa-fire-companies-feel-the-pinch-as-private-equity-buys-up-truck-manufacturers/.

[4] REV, American Industrial Partners, https://americanindustrial.com/project/rev-2/.

[5] American Industrial Partners Announces Acquisition of E-ONE, Inc., a Subsidiary of Federal Signal Corporation, American Industrial Partners (August 5, 2008), https://americanindustrial.com/american-industrial-partners-announces-acquisition-of-e-one-inc-a-subsidiary-of-federal-signal-corporation/.

[6] REV Group Acquires Kovatch Mobile Equipment, REV Group (April 11, 2026), https://web.archive.org/web/20170914135509/https://investors.revgroup.com/investor-releases/2016/11-04-2016.

[7] REV Group Acquires Ferrara Fire Apparatus, Inc. American Industrial Partners (April 25, 2017, https://americanindustrial.com/rev-group-acquires-ferrara-fire-apparatus-inc/.

[8] https://www.rwbaird.com/transactions/investment-banking/dealcard/5503/; Chris Mc Loone, REV Group Invests in the Strength of Fire Apparatus Brands, Fire Apparatus & Emergency Equipment (July 1, 2020), https://www.fireapparatusmagazine.com/fire-apparatus/ladder-trucks/rev-group-invests-in-the-strength-of-fire-apparatus-brands/; Chris, REV Group, Inc. Completes Acquisition of Spartan Emergency Response, FireFighter Nation (February 3, 2020), https://www.firefighternation.com/firerescue/rev-group-inc-completes-acquisition-of-spartan-emergency-response/.

[9] REV Group, Inc., Form 10-K for the fiscal year ended October 31, 2021 at 96.

[10] Pierce Manufacturing Completes Ownership Interest in Boise Mobile Equipment, Pierce (September 16, 2021), https://www.piercemfg.com/pierce/press-release/pierce-manufacturing-completes-ownership-interest-in-boise-mobile-equipment.

[11] Oshkosh Corporation Acquires Maxi-Metal Inc., Oshkosh (June 13, 2022), https://www.oshkoshcorp.com/news/2022/6-13-22-maxi-metal.

[12] MacQueen Emergency Group territory Expanded to Include 109 Missouri Counties, Pierce (July 10, 2018), https://www.piercemfg.com/pierce/press-release/macqueen-emergency-group-territory-expanded-to-include-109-missouri-counties.

[13] Siddons-Martin Emergency Group Expands Territory with Acquisition of Superior Equipment, Pierce (July 21, 2020), https://www.piercemfg.com/pierce/press-release/siddons-martin-emergency-group-expands-territory-with-acquisition-of-superior-equipment.

[14] Minuteman Fire and Rescue Acquired by Allegiance Fire and Rescue, Pierce (November 18, 2019), https://www.piercemfg.com/pierce/press-release/minuteman-fire-and-rescue-acquired-by-allegiance-fire-and-rescue.

[15] Pierce Dealer, Siddons-Martin Emergency Group, Broadens Territory with Acquisition of Emergency Vehicle Specialists, Pierce (April 6, 2023), https://www.piercemfg.com/pierce/press-release/pierce-dealer-siddons-martin-emergency-group-broadens-territory-with-acquisition-of-emergency-vehicle-specialists.

[16] Pierce Dealer Firematic Supply Co. Grows Presence in Northeast with Acquisition of Churchville Fire Equipment, Pierce (September 1, 2023), https://www.piercemfg.com/pierce/press-release/pierce-dealer-firematic-supply-co.-grows-presence-in-northeast-with-acquisition-of-churchville-fire-equipment.

[17] Reliant Fire Apparatus Acquires Halt Fire, Inc. Expands Pierce Dealership Territory to Include the State of Michigan, Pierce (June 12, 2025), https://www.piercemfg.com/pierce/press-release/reliant-fire-apparatus-acquires-halt-fire-inc.-expands-pierce-dealership-territory-to-include-the-state-of-michigan.

[18] Rosenbauer International Fully Acquires Rosenbauer America, Rosenbauer (June 23, 2022), https://www.rosenbauer.com/en/company/investor-relations/financial-news/2022/06/rosenbauer-international-fully-acquires-rosenbauer-america.

[19] Iain Hoey, Rosenbauer America Announces Partnership with IKON Fire, International Fire & Safety Journal (March 28, 2023), https://internationalfireandsafetyjournal.com/rosenbauer-america-announces-partnership-with-ikon-fire/.

[20] See, e.g., City of Arcadia v. American Industrial Partners, LLC, et al., 25-cv-020025, E.D.Wisc., Class Action Complaint, December 22, 2025, ¶¶ 7 and 11.

[21] For example, indirect purchaser Class Action Complaint and Jury Demand ¶¶ 6-9 in The Durango Fire Protection District v. OshKosh Corporation, et al., D.Colo., 1:26-cv-01574, filed April 14, 2026.

[22] FAMA Statistics Website Instructions, Fire Apparatus Manufacturers Association (March 31, 2026), https://stats.fama.org/assets/files/FAMA_Statistics_-_Website_Instructions_-_updated_March_31_2026.pdf.

[23] Iain Hoey, Exclusive: Mark Fusco, President at Rosenbauer America, talks supporting the mission of saving lives and protecting property, International Fire & Safety Journal (October 10, 2022), https://internationalfireandsafetyjournal.com/exclusive-mark-fusco-president-at-rosenbauer-america-talks-supporting-the-mission-of-saving-lives-and-protecting-property/.

[24] FAMA Releases Fire Apparatus Industry Update, Fire Engineering (May 30, 2025), https://www.fireengineering.com/fire-apparatus/fama-releases-fire-apparatus-industry-update/.

[25] LA County Brings Antitrust Suit Against Fire Truck Companies to Recover Overcharges and Unwind Anticompetitive Mergers, Office of the County Counsel (February 12, 2026), https://counsel.lacounty.gov/la-county-brings-antitrust-suit-against-fire-truck-companies-to-recover-overcharges-and-unwind-anticompetitive-mergers/.

[26] For example, the International Air Cargo Fuel Surcharge conspiracy. 21 Airlines Fined For Fixing Passenger, Cargo Fees, CBS News (March 5, 2011), https://www.cbsnews.com/losangeles/news/21-airlines-fined-for-fixing-passenger-cargo-fees/.

[27] See e.g., Carlton, Dennis and Perloff, Jeffrey (2015) Modern Industrial Organization, 4e, at 270; Pindyck, Robert and Rubinfeld, Daniel (2013) Microeconomics, 8e, at Example 10.5.

[28] What’s Driving the Cost of Fire Apparatus, Fire Apparatus & Emergency Equipment (September 4, 2025), https://www.fireapparatusmagazine.com/fama/whats-driving-the-cost-of-fire-apparatus/.

[29] Ibid.

[30] Ibid.

[31] Joshua Grimes, The Impact of COVID on the Price of Steel in Three Phases, U.S. Bureau of Labor Statistics (May 2025), https://www.bls.gov/opub/btn/volume-14/the-impact-of-covid-on-the-price-of-steel-in-three-phases.htm;

[32] What’s Driving the Cost of Fire Apparatus, Fire Apparatus & Emergency Equipment (September 4, 2025), https://www.fireapparatusmagazine.com/fama/whats-driving-the-cost-of-fire-apparatus/.

[33] Navigating the Fire Apparatus Landscape in 2026: Insights from FAMA Leaders, Fire Apparatus & Emergency Equipment (March 23, 2026), https://www.fireapparatusmagazine.com/fama/navigating-the-fire-apparatus-landscape-in-2026-insights-from-fama-leaders/.

[34] What’s Driving the Cost of Fire Apparatus, Fire Apparatus & Emergency Equipment (September 4, 2025), https://www.fireapparatusmagazine.com/fama/whats-driving-the-cost-of-fire-apparatus/.

[35] Mike Baker, Maureen Farrell, and Serge F. Kovaleski, As Wall Street Chases Profits, Fire Departments Have Paid the Price New York Times (February 17, 2025), https://www.nytimes.com/2025/02/17/us/fire-engines-shortage-private-equity.html.

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