We are opposed to the rule making for Speed Limiters.
When considering the new CSA rules and regulations to improve safety and reduce fatal accidents, there should be given a time frame to determine if these new regulations have proven to be successful. By implementing speed limiters,it suggests that the element of CSA which encourages and measures Drivers in the Basic area of Driver Safety, is not sufficient or adequate. Are drivers not responsible enough to follow the new laws and regulations? Are we not professionals?
Does that mean that CSA is already being projected as unsuccessful in its original goals to create safer drivers, companies, and highways?
*Possibility that fatal truck accidents can actually be caused by the use of speed limiters. FMCSA studies should be conducted showing the comparison of high speed fatal truck accidents (without speed limiters) vs. fatal truck accidents involving the use of speed limiters.
*Better company CDL training programs mandated and enforced to ensure new drivers are safe and responsible. Trainers should remain in passenger seat at all times observing trainee behavior ( not sleeping in bunk)
*The ATA has stated repeatedly, especially during their arguments involving the new hours of service proposal, that fatal truck crashes have been reduced significantly in the last few years.
*If speed limits are no longer considered safe, then perhaps it is the speed limits themselves that need to be re-evaluated rather than placing speed limiters on certain commercial vehicles. This would also address the need to reduce fuel consumption and fuel emissions for ALL vehicles, not just heavy trucks. It would also prevent a speed differential between trucks and cars, which JB HUNT said, “This speed differential may cause a safety hazard…”
*CSA, better driver training, and the new PSP driver profiles for hiring purposes, and the final outcome should result in the best, safest, and most responsible professional quality drivers.
Aibrey A. Smith - Comment
This is comment on Rule
Federal Motor Vehicle Safety Standards: Engine Control Module Speed Limiter Device
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