Iowa Division of Criminal Investigation - Comment

I have a comment of the length in which the IIDs must be "serviced". The 30 + 7 seems to be a step backwards for me, especially since throughout this document, NHTSA has commented several times about the increased performance of IIDs, but yet in this section, NHTSA is requiring more frequent calibration checks. With improvements in IID technology like better fuel cell technology, cameras and near real-time communication and the main fact that the vast majority of persons on IIDs blow 0.000 on a regular basis, requiring the 30 day service puts additional strain on the consumer to have their IID serviced more often. In States, like Iowa, many consumers have to drive 50-100 miles roundtrip to get to a service center, and to force them to do it more frequently will cause additional strain on them. Testing of IIDs have shown they are very capable of maintaining extended calibrations. In Iowa, we have tested units at a concentraion of 0.100 - three times a day for 210 days and these devices have held their calibrations within 10% the entire test period. When these devices are used in combination of other types of personal monitoring such as bluetooth data downloads which moniter uses and attempted bypasses, the requirement of 30 + 7 days for service is really unnecessary. The 37 day lockout is more to monitor the end user, than to monitor the device itself. More and more safeguards are being used to monitor the person and I think NHTSA should consider the capabilitites of the device, and not the person. Therefore, I would recommend for consideration, that the 30+7 day service requirement have some flexibility to it for devices that can be shown to hold their calibrations well beyond the 30+7 days be allowed to have longer "service intevals" at the descretion of the governing body within the State that they are used.