Rodney L. Steely - Comments

Docket # FMCSA – 2012 – 0183 Certain parts of the proposed guidance are in conflict with the interpretation and understanding by the industry as well as the enforcement community in a number of the states where oil and gas development has occurred over the past 50 years, such as Texas, Oklahoma, Colorado and others. In those states vehicles associated with oilfield activities, including water and sand trucks, have been considered specialized equipment and were eligible for the 24 hours restart and the waiting time exception. Many of these carriers, including those transporting sand and water, have worked under these exceptions for many years without questions from FMCSA or the state. The proposed guidance does not consider nor even acknowledge the economic impact of what could possibly have on our industry. In my state of Colorado since I have been in the oilfield business, (1976) we have always been allowed to utilize the oilfield exception rule. Colorado has been willing to work with our industry due to the fact of our specialized equipment. I started out on the construction and building of well sites. But for the last 22 years have been in the Crude Oil transportation side of the industry. Our trucks are specialized with tanks and pumps, hoses, and other specialized equipment, specifically designed for Crude Oil transportation. We can’t haul any other product. We appreciate the value of the oil field exception rule, for it is vital in our everyday operations. To my knowledge, at this point and time, there is no real documentation that states or confirms that the oil field exception has truly been a problem in our industry or an unsafe practice when used appropriately. If the wheel is not broke what are you trying to fix? Interpretation can be modified to satisfy all concerned. Thank you for your time. Rodney L. Steely, President Colorado Crude Carriers, Inc.