Scott Jensen - Comments

According to Part N, A portion of the PASA will be a review of compliance with Part 395 (Hours of Service Regulations). What criteria are going to be used to measure this with Mexican based, border carriers? Hopefully not their CSA Score in this BASIC, because a large majority of these carriers are not required to fill out a log book because they operate within the 100 mile radius of their home terminal. On DOT inspections in the border areas, they are getting a "pass" on HOS regulations. I downloaded the entire FMCSA / CSA database, cross sorted and found that 15% of all carriers with more than 500 inspections were in the 99th percentile (worst 1% in Driver Fitness, and in Maintenance). The unique thing I noticed about this group is they all had near perfect scores in the Fatigue BASIC. This group of carriers has one other thing in common, they are all border based Mexican Carriers. Many of which only have 5 to 20 drivers / power units. Yet in the CSA model they "appear" as a large carrier based upon the number of inspections they receive. Not only is there the issue of having Carriers attempting to operate with no idea of how to operate within Part 395. They have already completely skewed the "curve" which is the basis of the CSA model, for all large USA based carriers. Are we now going to allow them to run free getting violations until they get enough to place them at intervention level? How many people could potentially loose their lives, or loved ones before their score places them in the crosshairs. As for me...one would be too many.