American Moving & Storage Association (AMSA)

1611 DUKE STREET ALEXANDRIA, VA 22314-3482 Telephone (703) 683-7418 FAX (703) 683-8208 March 31, 2009 Docket # FMCSA-2007-27659 Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, S.E. Room W12-140 Washington, DC 20590-0001 Dear Sir/Madam: On behalf of its membership, the American Moving and Storage Association (AMSA) supports the National Highway Traffic Safety Administration’s (NHTSA) March 3, 2009, proposed rule on Federal Motor Vehicle Safety Standard for Air Brake Systems. The rule would extend to March 1st, 2011, the sunset period for the current requirement, which mandates trailers with antilock brake systems be equipped with an external antilock malfunction indicator lamp. The proposed rule also considers the possibility of making the requirement permanent. The extension of the current requirements on the ABS brake indicators is a practical plan. We are currently operating under the rule that requires ABS indicators for tractors/trucks manufactured after March 1, 1997 and trailers manufactured after March 1, 2001. If these requirements expired and were then brought back at a later date, it would cause much confusion among drivers, inspectors and carriers. Carriers are maintaining these ABS indicators as required and we should continue the current course, rather than allowing the rule to sunset and then possibly brought back months later. It would be extremely disruptive for carriers to cease current maintenance of ABS indicators, and then be required to resume current practices at a later date. AMSA recommends the extension of the sunset period pending a ruling to make this requirement permanent. The American Moving and Storage Association is the only national trade association representing the professional moving and storage industry. Our members provide household goods moving services, specialized transportation for sensitive freight such as computers and trade show exhibits, and warehouse storage services. The association has 3,200 members, including more than 300 international members, and offers programs and activities that promote consumer protection, professional development, safety, and operational efficiency. Respectfully Submitted, Linda Bauer Darr President and CEO