Carleton Watkins - Comments

The change in this rule to replace USB type B connectors with USB type A connectors without changing the definition of implementation is confusing according to the USB 2.0 spec. Type A connectors, according to the USB 2.0 spec implement a host connection which normally interfaces to a Mass Storage class / device". A Host class or Type A connector is not itself a Mass Storage device, nor does it per USB spec emulate a Mass Storage class / device. If our device is to implement a Type A connector / USB Host, then the DOT official's device should be the USB Mass Storage class device, such as a USB thumbdrive, etc. Please let me know if I'm mistaken or if there is still going to be a change in the DOT Official's device so that it appears as a USB Mass Storage device. Also, will the DOT official have a thumbdrive or present a cable to the CMV driver? Your rule states (which is a contradiction to the USB spec): Appendix A to Part 395—Electronic On-Board Recorder Performance Specifications * * * * * 2.2 Wired. EOBRs must be capable of transferring RODS using the ‘‘Universal Serial Bus Specification (Revision 2.0)’’ (incorporated by reference, see § 395.18). Each EOBR device must implement a single USB compliant interface featuring a Type A connector. The USB interface must implement the Mass Storage class (08h) for driverless operation.