Diamond Pump & Transport - Comments

See attached file Comment on Regulatory Guidance for 49 CFR 395.1(d) docket # FMCSA-2012-0183. It is our belief that this new guidance will unjustifiably, unnecessarily, and arbitrarily cause undue burden on the oil and gas industry as a whole, and will have a very negative effect on our business and all of our employees. As we read your own published reasoning for making these changes, it appears that one of your biggest concerns is the increase in CMV traffic since the 1962 revision. We believe that this change will actually result in an increase of the said traffic by at least 30%. This will happen because of logistical requirement of changing out equipment and drivers, who otherwise would have been able to stay on location until needed. This will put an additional burden on an already ageing and substandard transportation infrastructure. This timed need cannot be predicted. This would also create a huge additional expense not only to the oil field servicing company (us), but also the drilling/fracturing contractors and the lease operator as well. All of which will be passed along to end users. Both the 24 hour reset and the onsite wait time provisions that are revised by this guidance are critical to the continued operation of all oilfield service providers. Another unplanned consequence of the new guidelines will be an additional tax on the already depleted qualified driver pool. This will undoubtedly result in more inexperienced CMV drivers sharing the roads with smaller motor vehicles. The vehicles that are used for the transportation of water to drilling and fracturing sites are indeed specially designed with pumps installed on these trucks for use at the well site. For the most part these apparatus’ have no other use in commerce. These trucks are multi-functional on location and once again these drivers/operators are indeed extensively trained at considerable expense in both funds and time. It takes years to develop the level of expertise required to safe