Anonymous - Comments

#1 - the definition of Interstate commerce (as it relates to farming) was not being enforced prior to UCR - so is it about public safety or the URC fee? (I already know the answer) #2 - 395.1.k exempts the vast majority of farmers from RODS and supporting documents. DOT is now using Part 379 as justification to review the supporting documents. If I'm exempt from supporting documents per 395.1.k I should not be subject to Part 379. #3 - Implements of husbandry must be exempted as it is literally impossible for them to pass the 396.17 periodic inspection standards, yet the implement is vital to the farming operation. #4 – Accident risk (public safety) is 100% unchanged when based upon the ownership of the grain being hauled. This is to say that any accident will not be caused or prevented because part of the grain being hauled belongs to the landlord (crop share). I believe this regulatory problem can be corrected by changing the 390.5 definition of “Farm vehicle driver” to read the same as the definition of “farmer”. So, the farm vehicle driver definition could read “ controlled and operated by a farmer or under the direct control of the farmer who was directly engaged in the harvest operation”. #5 – If there is documented accident history related to the CDL exemption for farmers, the FMCSA should void this exemption. If not, the exemption should allow the farmer to transport the crop share grain. Please don’t fix the CDL exemption if it is not broken.