Dan Klimek - Comments

Having reviewed the proposal to change "interpretation" of the Oilfield Exemption for hours of service, I believe the FMCSA should rescind the proposed regulation since the time frame is inadequate for public comment and the publication of the changes has not been very public. Secondly, the hearings that should be scheduled should provide an open and honest rationale for the change and also consider the economic cost / benefit of this interpretation. This should also include the data that supports the reason for this change. Lastly, it appears that the issue of specialized equipment and specialized training is not clearly understood by the regulators, so formal hearings and following the format of usually followed when regulations are issued or changed should be followed. Respectfully submitted, Dan Klimek