Comment submitted by Don Greenwaldt, Tidewater Transit

The present hours of service have been successful in reducing fatigue related truck accidents. Rather than changing hours of service, enforce the hours of service we presntly have. We have worked diligently to fit our runs into the 11 hour driving time. Changing to 10 hours would required a 10 hour break to complete these runs. This would severely impact our rate structure. Shippers do not wish to pay for the extra service created. It would also negatively impact the driver's compensation and the company's profit margin. A further challenge would be for shippers to load the product 10 hours earlier to allow for the 10 hour break before the driver could continue for the remaining one hour required to make his destination. If we must return to the 10 hour driving rule the hos should return to the split sleeprer allowing drivers to take two periods of rest of 5 hours rather then the reqired 8 hours in the sleeper. As a driver with over 30 years experience I found I functioned best with a 4 - 6 hour rest period. This also allowed me the opportunity to plan my trip to make on time deliveries with adequate rest.