Linda A. Fangmeier - Comments

Dear FMCSA, I had a chance to see your latest proposed rule. This rule will not work for several reasons. 1. A professional truck driver can only be responsible for various things while operating the commercial vehicle. a. staying sober which the D.O.T. already has regulations in place for this type of violation. b. Staying off drugs. Again the D.O.T. has rules and random testing of all professional driver in the United States and keeps more then 95% of drivers off of drugs because it effects their lively hood. c. Speeding is a problem of all vehicles on the road today be it professional or private vehicle. If you check the records state by state you will find that other then professional drivers to be a higher rate of traffic fines then professional drivers. Some of the causes for speeding are... time frames to deliver a load because of dispatching error, weather, flow of all traffic on a highway, slow speed states 60 and 55 mph (a top reason)this is due to the rpm on the gears that wear and tear on equipment when speed is slower then what the rpm operation of trucks is required to operate at,an example is a ten speed truck doing 55 mph has an rpm of 13 to 14 rpm when the normal truck operation is 15 rpm to 17 rpm. This causes the driver to use a lower gear which is not made to travel at 55 mph and causes the engine to wind higher rpm then normal , pay per mile (one of the biggest reasons) , to much construction in one area mainly number of miles under construction, accident retention delays, regulation of hours spent driving per shift, not enough rest areas that are truck only accessible. Also a large problem is the use of the Rand McNally home movers guide to pay drivers with. This system only pays from the edge of a city to the next edge of a city. Drivers do not get paid for driving through any city and there are some large one's out there example: Chicago, Pittsburg, Syracuse just to name a few. This pay method should be outlawed. The newest method is by computer computation and this is based also on the movers guide and should be outlawed. Additionally trucking firms traditionally cut the driver another 5 to 15% off of the Rand McNally miles for out of route driving which sometimes can't be helped and for going to a truck stop for fueling or legal rest breaks. This cuts the pay considerably and to make up the difference the driver has to deliver as many miles and loads as they can. 2. Another issue I would like to add is the slow speed states that allow other then commercial vehicles to travel 10 to 15 mph faster then commercial vehicles as this causes more problems for the professional driver. These non commercial vehicles do not submit to right of ways , yeild signs or specific traffic lanes that are for commercial vehicles only as these slower speed states teach non commercial vehicles they have the right of way in all instances and the truck should yeild and this is not always possible because of size and weight of the commercial truck. In conclusion if you want to pass a law focused on the commercial driver then please make it mandatory in all states that education during driver education training in the schools include learning to drive with the big trucks and commercial vehicles. Also pass a law that instead of revolking the professional drivers liscence that the carrier be responsible for a in house program to rehabilitate first option before liscence supension voluntarily and then if it's refused then yes revoke it. Another suggestion is to require all foreign drivers especially from Mexico to pass a US DOT exam before being allowed to enter the US as Mexicos and other foreign nations have different driving regulations then the US and are not as well trained as the drivers in the US. There are already rules in existance concerning repeat offenders for the agenda being proposed. If you really want to help the trucking industry then consider what I have written to you. No one likes to work for free and truckers and other professional drivers do it all the time because of the method of payment I listed above. It not only cheats the federal government of tax dollars it cheats the American economy of the trickle down dollars that these professional drivers earn and spend. Spend more of the dollars allocated to your department to build just simple black tops at more locations for truckers to park in and sleep. Old weigh stations are already in place with black tops and needs minimal maintence. A good example to follow is in Pennsylvania where they have 120 parking black tops just for trucks only. This is working well or weigh stations that allow the trucker to pull in and park with out fear of being rousted in the 8 hr break period. When the trucker starts seeing these things then they will know that the D.O.T. cares about them other then to see them penalized for being bad. This WILL change the attitudes of the drivers. I would like to state that on the whole the D.O.T. is doing their job fairly well at spotting bad equipment, drunk drivers etc. Professionally Yours Linda Fangmeier