What’s going on here? Comments on FMCSA’s  EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) proposal have raised a lot of questions that need answers from equipment manufacturers, installers, and others who know about the technology and actual implementation of EOBRs.  These “tech-xperts” have been invited to discuss those questions here. To see a list of the companies/organizations we’ve invited to contribute experts to the discussion click here.

This discussion will be open until FRIDAY, MAY 20.   Then the Regulation Room team will  prepare the Expert Discussion for submission to FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) as a public comment no later than May 23 (when the official comment period ends).

To tech-xperts: Each section deals with a different set of concerns.  To help keep the discussion focused and manageable, please make your comments in the “right” section.  (Just click on the section you want to comment on and leave your comment in the box that appears to the right.)  You can propose new topics in the last section.  If you know someone who should participate in this discussion but was not invited, contact us.

To everyone else:   ONLY tech-xperts can make comments on this post (although everyone can read everything that’s being said.)  If you think you should be participating as a tech-xpert, contact us.

Possible Devices. FMCSA used the Qualcomm MCP-100 as the principal the amount that is borrowed, not counting the cost of interest or fees basis for its cost and compliance estimates.  (See its reasons here and here.)  It doesn’t know of any “stand alone” EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) that would comply with current specifications but are not part of a fleet-management system.  Are there more options for complying devices than FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) currently recognizes?

Things you might want to discuss in this section:

• Range of EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) currently available that comply with FMCSA performance specs
• Feasibility of adapting other devices (e.g., cell phones, GPS Global positioning system (A space-based global navigation satellite system that provides location and time information anywhere on Earth) units)
• Feasibility of developing new compliant devices within the near future
• Whether current FMCSA performance specs limit range of usable devices — and if so, how the specs could/should be modified?

Market Capacity/3-year implementation. FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) uses the MCP-100 because it believes Qualcomm is the only manufacturer likely to be able to supply enough compliant devices within the proposed 3-year implementation period.  (See FMCSA’s reasons here and here.)  Are market conditions different than FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) realizes?  Is a 3-yr implementation practically feasible?

Things you might want to discuss in this section:

• Size and range of device market now, and in near future
• Feasibility of enough compliant devices in 3-year compliance window
• Other issues with 3-year compliance window (e.g., availability of trained installers)

Costs. Based on the Qualcomm MCP-100, FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) estimates per power-unit costs of $1675 for initial purchase; $100 for installation; negligible costs for driver training; and a $40/month communication fee.  It also assumes installation is possible on all currently operating CMVs Commercial Motor Vehicles (vehicles owned or used by a business) (electronic and mechanical engines), and that devices have at least a 10-year operating life.  (See its estimates here and here).  Are any of these estimates significantly too high or too low?  Anything missing?

Things you might want to talk about in this section:

• Device costs
• Installation  & Training costs
• Device useful life — does this vary if vehicle is used in off-road or other rough conditions?
• Are mechanical engines a problem?  are there other vehicle factors that will influence compliance costs?

Benefits/Actual Experience. FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) calculates substantial benefits to CMV Commercial Motor Vechicles owners from reduced paperwork costs, increased efficiency, etc. (See its estimates here and here).  Small companies especially seem skeptical.  What can you say about anticipated savings or other benefits based on experience with EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) so far?

Things you might want to talk about in this section:

• Current EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) and AOBRD usage
• Impact of type of operation (e.g., short haul) on predictable benefits

Privacy. Some drivers are really concerned about privacy:  who can get what information from from the device and when, and how the information will be transmitted.  What can technology do to resolve those concerns?

Things you might want to talk about in this section:

• security of wireless transmittal
• issues with equipment and/or software differences across range of local, state and federal enforcement officials
• additional safeguards (technical, training, etc.) against officials improperly downloading or maintaining data

International Issues/Experience. The NPRM Notice of Proposed Rulemaking: the official document announcing and explaining the proposed rule doesn’t talk much about experience with EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) in other countries. Are there data or other information from EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) experience in the EU and other countries that FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) should know about?

Other Topics? You’re the tech-xperts.  If there’s another topic you think people should be discussing, let us know by adding a comment here — and we’ll open another section on it.  Thanks!