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It’s not bold text; it’s underlined.
The first and the third pictures make much more sense than the one currently used. It looks like either a mushroom cloud or a cowboy hat. The second and fourth pictures are okay, but not as good as the first and third.
I agree with BarbaraB about websites only being useful for some customers. Sure, if you realize you need new tires, you can do research online before going and getting them. But if you get a flat tire, put on the spare, and drive right to the tire store for a replacement, you’re not going to swing by home to check out the NHTSA’s website first. Or if you go to get your oil changed or your car inspected and the mechanic points out you need new tires, you’re not going to be able to access the site at that point, unless you have an iPhone or Blackberry. I know retailers will have posters up, so those should contain all the relevant information, rather than expecting people to go check the internet first.
Thanks for this insightful suggestion! I’m wondering if anyone else on here can think of any problems this approach might raise.
Thanks for your comment. How well do you think this rule addresses the dangers you identify with texting while driving?
On page 14 of the VTTI study, the researchers explain how they came up with this data: they outfitted heavy trucks with both video cameras and a Data Analysis Reduction Tool that tracked driving behavior. Using these instruments, they were able to track “near misses.” I hope that answers your question.
Thanks for your comment. Do you think the airline should have a different policy for those for whom the trip will no longer be worthwhile now that their first flight has been canceled?
Thanks for your comment! Do you think there should be some overall weight formula for passengers and baggage fees? Or simply that passengers under a certain weight should be allowed to check a bag for free (or at least less)?
Thank you for your comment. Where do you think the line should be drawn with disclosure requirements? Should the rule be that if a fee is automatic, it should not be listed separately? Or do you propose something else?
Thanks for your comment. The rights debate is a great perspective. Do you think it has any bearing on other issues in the proposed rule?
Billup, it looks like your comment worked. I’m looking forward to hearing what you have to say on this rule.
Does anybody else have thoughts on how this could be done, or whether it should be done at all?
Thank you for your comment. Do you have links to any of the studies you cite?
Thank you for your comment, cmvs33. Aside from banning airlines from serving peanuts on flights, what other steps do you think the DOT could take to make flying safe for people with peanut & tree nut allergies?
Thanks for your comment. Does the rule address any other problems you have had as a frequent traveler?
Thank you for your comment and your perspective. Do you know if this is a rule for all airlines? Do you happen to have a link to any data to back it up?
Computer_Forensics_Expert and Immunoglobulin, thank you for your comments. You both seem to have good perspectives, based on personal experiences. Do you have personal experiences with other topics discussed in this rule? The DOT really wants to hear comments from a variety of people on issues such as baggage fees, tarmac delays, and bumping compensation. Use the rule dashboard at the left to navigate to this different areas to have your voice heard there as well!
Thank you for your comment. You have a great perspective as the parent of a child who has had an allergic reaction on a plane. It sounds like you have some interesting travel experiences. The DOT would love to hear what you have to say about topics such as tarmac delays, baggage fees, and bumping compensation. Use the Rule Dashboard on the left to navigate to these other issues in the rule.
Thank you for your comment. What do you think about the other regulations the DOT is proposing in this rule? Do you have similar objections to any of them? Use the Rule Dashboard on the left to see what other issues you might have something to say about.
Does anyone have the type of data lutefisk941 is looking for? This data would also be very useful for DOT to know as it makes its decision.
Thank you for your comment. What do you think of DOT’s proposal that airlines be required to promptly notify passengers of delays of 30 minutes or more? Do you think it would be effective?
Do you see a more effective way of getting this information to passengers? Or do you think that it is not really information that passengers need in the first place?
Thanks for your comment. Do you have any data about how many other people who have had similar experiences to your family?
Also, it sounds like you’ve done some traveling. The DOT would love to hear what you have to say about other issues in the rule! Use the Rule Dashboard on the left to navigate to other topics.
Does anyone see a way that DOT could address the peanut issue without running afoul of the problem kas and KingSlav see?
Thank you for your comment. You seem interested in striking a balance between competing interests and concerns. Do you think the proposed rule does a good job of this in other areas as well?
Thank you for your comment. Do you have experiences with other areas addressed the rule as well, where perhaps the supportiveness of airline staff and fellow travelers has differed?
Thanks for your comment and your suggestion. Does anyone know the details about how the large carriers collect this information?
Thanks for your comment, gwiener. Do you think any other areas of the rule implicate the rights issues you are concerned about?
Thanks for your comment! What do you think the solution should be if the plane has left the gate and is sitting somewhere out on the tarmac? Should passengers be allowed to de-plane?
Thank you for your comment. What do others think of the proposition that strong penalties will be more effective than contingency plans?
Thanks for your input! You bring up an interesting point, that passengers are the airline’s customers and should be treated accordingly. Do you think the DOT could do something to allow customers to make informed choices about which airline to fly, based on data about tarmac delays?
Thanks for your comment! Do others think the $15-$35 range is reasonable? Should the DOT get involved in regulating this fee?
Thanks for your comment! It looks like your previous submission has reappeared. I’ll let our site programmer know there might have been a problem.
Given that most airline tickets today are not reimbursable, do you think the practice of bumping should be effectively eliminated? And how much time do you think the passenger should be given to decide whether or not to cancel?
Thanks for your comment. How frequently do you think updates should be given?
Thanks for your comment. What tasks do you think could be performed elsewhere (such as from your home computer) to reduce the severity of this problem?
Thanks for your comment! Would you favor a flight sticking to an announced delay schedule, even if subsequently became possible for the flight to take off earlier than the announced time?
Thank you for your comment. What sort of flight status update requirements would you favor? Is 30 minutes soon enough? How often do you think airlines should be required to give new updates?
Thanks for your comment. This is an interesting idea. What do others think of this proposal? Do you think DOT should impose it, or should the airlines just be encouraged to adopt it themselves?
Thanks for reviewing the summary, chase. This is not the place to reargue your position. Now the goal is to ensure that the summary captures all the points that people made during the discussion. If you think something is unclear or wrong, please leave a comment on the section that you think needs work.
Thank you for your very helpful suggestions, buzzard. We will take everything you said into careful consideration when we are putting the final summary together. A few quick thoughts on your points:
1. We will definitely double-check our numbers, but we can only count what people actually say in their comments.
2. Our number estimates are based on commenters, not comments. So if one person said the same thing three times, it was only counted once.
3. On your last point, you’ll be glad to know that we have invited the authors of many of the scientific studies cited to come discuss the scientific evidence on our Experts’ Discussion Board.
Thank you so much for your helpful input. We will note it for inclusion in the final summary that is submitted to the agency.
Thank you for your suggestion. We will note it for inclusion when we create the final summary.
For the costs and benefits, the DOT is looking for your reactions to the estimated costs and benefits, as well as your reactions to their methodology. Do you think they did a good job in their calculations? Do you think the balance of costs & benefits justifies each of the proposed regulations?
Do you think there are any reasons foreign air carriers should not be held to the same rules as domestic air carriers? Are there any added benefits to travelers that you do not see mentioned here? Do you agree with the cutoff of 30 seats for these rules to apply to foreign air carriers?
Thank you very much for the clarification. We will be sure to modify the language in the final summary that we send to DOT.
Thanks for taking the time to review the draft summary, Howie. To answer your question about experts, we contacted all the authors (whom we could locate) of all the studies brought to our attention by commenters or people who responded to our request for other experts. You can see the complete list of studies here.
We will be appending this list of studies and the questions posed to experts to the final summary that we submit to DOT.
This is not the place to reargue your position. Now the goal is to ensure that the summary captures all the points that people made during the discussion.
Thank you for noting things you think we missed. We will note them for inclusion in the final summary.
Thank you for reviewing the summary. This is not the time to propose new arguments or re-argue existing positions. Now the goal is to ensure that the summary captures all the points that people made during the discussion. If you think something is unclear or wrong, please leave a comment on the section that you think needs work.
Thank you for reading the summary, kdiego. This is not the place to argue your position. Now the goal is to ensure that the summary captures all the points that people made during the discussion. If you think something is unclear or wrong, please leave a comment on the section that you think needs work.
Thank you for reading the summary. However, this is not the time to re-argue positions. Right now, the goal is to ensure that the summary adequately covers everything that was raised during the discussion. If you feel the summary misses something that was already discussed, click on the paragraph you think needs work to comment.
Thank you for reading the summary and letting us know what you think we missed, jmor123! We will note this for inclusion in the final summary.
Thank you for reading the summary. However, this is not the time to argue your position. At this point in the process, the goal is to get our commenters to ensure that the summaries fully capture the comments in the discussion, so that the summary we submit to the DOT is complete. If you think we missed something from the discussion, click on the paragraph you think needs work and leave a comment.
Thanks for reading the summary and adding your critique. We will note this for inclusion in the final summary.
schachgeek, you will be glad to know that we invited experts in peanut allergies, whom we identified from a list of studies commenters cited (see that list here). You can see what, if anything, the experts are saying here. We will send this list of studies to the DOT along with the final summary of discussion on the rule.
Thank you for reading the summary, yampalin. This is not the place to argue your position. Now the goal is to ensure that the summary captures all the points that people made during the discussion. If you think something is unclear or wrong, please leave a comment on the section that you think needs work.
Thanks for reading the summary and commenting on what you think we missed. We will note your comment for inclusion in the final summary that we send to the agency.
Right now the goal is to make sure we didn’t miss any information that was brought up in the discussion on the issue posts when we wrote the summary. It is not the time to argue your position. If you think we missed something, let us know.
Thank you for reading the summary. Right now, our goal is to write the best possible summary of the discussion. If you think the summary is missing anything, please click on the paragraph you think needs work and suggest specific language to be added or changed.
Thanks for pointing out that we missed that. We will note it for inclusion in the final summary.
What do you think about thewanderer’s experience that having EOBRs has made work easier for drivers? If EOBRs are required, what can FMCSA do to make sure all drivers see the benefits thewanderer talks about?
You bring up a good point about Mexican trucks and U.S. safety rules. FMCSA wants to use electronic recording devices to make sure Mexican drivers are following U.S. laws. (You can read more about it here.) How do other users think the proposed EOBR rule will affect American drivers’ ability to compete with Mexican drivers?
Under this proposed rule, FMCSA says that their investigators will only be able to use the electronic data to make sure drivers are following the hours of service rules. Does this reassure you and other drivers that the investigators won’t actually get a lot more information? Why or why not?
Mikeakakrazy, I appreciate your concern about this proposed rule, but this is not the appropriate forum for rallying protests. In fact, Regulation Room gives you the opportunity to make sure that FMCSA is addressing your concerns before they enact the rule. For more information, see How Does Rulemaking Work?.
According to grldbarnes, a driver who says he uses an EOBR for work, says that his EOBR “is set so once you start your day any time you shut off the truck you go on duty, and once the truck starts moving again you go back to driving. You do have to manuelly change to off duty but that is no big deal.” You can read his full comment here.
What do you think about his take on how EOBRs work?
The current regulations require that a driver reconstruct RODS for the past 7 days in the event of an EOBR failure and then keep a handwritten RODS until the EOBR is fixed. (You can read more here, here, here, and here.) However, it doesn’t seem that there’s a specific monthly back up requirement. Do you know more about this? For the current proposed rule, do you think there should be a monthly back up requirement?
Since you seem to think EOBRs are a good idea, do you think it makes sense to require them for for both long haul and short haul trips? Or at least for all trips that involve carrying passengers or hazardous materials?
It also sounds like you might be interested in looking at the Privacy post and the Cost post and responding to DOT’s questions and concerns of other commenters.
Jmorris is another commenter on this post who worries about exempting short haul drivers at all. He feels that exempting these drivers would give current long hail carriers a loophole for avoiding the requirement. You can read his full comment here here. Do you think this could be a real concern? Is there a way to avoid having a rule that isn’t just one size fits all, but also doesn’t create a loophole like this?
Your comment about FMCSA’s safety estimates is very important. What would you estimate the actual compliance rate to be? It’d be really helpful if you have a source for your information, like a news article or a report. FMCSA is specifically looking for this type of information, so anything you have would be very useful.
idrive, you can let FMCSA know that your employer is making it hard for you to comply with the HOS rules either online at this website or by calling them at 1-888-DOT-SAFT (1-888-368-7238).
Could you share more details about how big truck companies can affect prices and how this will impact small businesses?
Curious, thank you for returning and continuing to participate in this discussion. We don’t have a position pro or con EOBRs. (Regulation Room is not run by DOT.) The main goal of the Regulation Room is to provide useful and effective comments to DOT. Our job is to help every person air his or her views in the most effective way – whatever those views are. We certainly hope truck drivers will air their opinions to give us that important “on the ground” perspective. However, opinions alone, without providing more explanation or reasoning, are not useful to DOT because they do not help the agency figure out what is wrong with the proposed rule and what needs to be changed. What makes a comment persuasive in a rulemaking? Check out our Effective Commenting page.
This discussion is about more than Pro/Con EOBRs. The rulemaking process isn’t like voting. The decision to have some kind of regulation has already been made, and this is an opportunity for those who will be impacted by that regulation to shape it. We ask that all stay away from ridicule, sarcasm, and personalized attack.
We started the expert post because there was a clear need for answers from equipment manufacturers, installers, and others who know about the technology and actual implementation of EOBRs to speak to other possible devices, market capacity, implementation schedule, costs, etc. We avoided inviting advocate groups because we didn’t want to mirror the discussion already occurring on other topics. If you believe OOIDA has technology experts who can speak to these… more »
The Regulation Room team summarizes the discussion that has taken place here on the site and submits it to FMCSA as a formal comment. We write detailed summaries, and the agency does address them in the final rule. (To see an example, you can look at the recently completed airline passenger rights rule here.) We’ll be posting draft summaries of the EOBR discussion this week so that users can review them and suggest improvements. Then we’ll make changes to the summaries, based on users’ comments, and submit the final summary to DOT on the last day of the comment period.
So you definitely don’t have to post your comments to http://regulations.gov… more »
Thanks for your input to help make the final summary better. You left your comment about lowering HOS safestate scores on the Cost post, so you can see that comment reflected in the Cost post summary, available here.
At this point in the process, the focus is on making sure the summary includes everything that was raised in the comments on the different posts. This is not the time to raise new points or re-hash old arguments. If you think we missed something that you or someone else mentioned in the comments before, let us know!
I don’t know. This is just something that seems unfair to lots of passengers, and that probably won’t get changed without regulation. At the very least, DOT should make clear to airlines that they *can* discriminate on the basis of weight without fearing regulatory action.
Since weight seems to be the issue with charging extra fees for checked luggage, the 98 lb person should pay less for a ticket than the 250 pounder. I have thought that from the very beginning when the airlines introduced this new fee.
I think that the fees for optional services should be clearly disclosed at the time of ticket purchace and also be clearly printed in bold, 12 point font on the ticket and ticket confirmation itself. You should be able to purchace a “ticket” for these optional services at the time of ticket purchace. If you know you will be checking in one bag, and having a meal, you should be able to easily purchace a “checked bag ticket” and a “Meal ticket” along with the flight ticket. These optional tickets would be required to be honored by all airlines under all circumstances.
Yes, most airlines pay flight crew members scheduled flight time or actual time away from the gate whichever is more. Eg. if a flight is scheduled for 2 hours “block to block” (from/to the gate) but it takes 3 to fly it, the crew gets 3. If the flight leaves that gate and returns 2.5 hours later, most airlines only pay that crew either the 2.0 scheduled (if it cancels) or much less. For most crewmembers, the notion that 1 hour at the gate, 2.5 hours of sitting on that taxiway and only get paid for 2 is not very palatable. Whereas sitting for 2.5 hours then fly 2 totals 4.5. It is mostly the pay structure of pilots/flight attendants that poorly designed. Most people would balk at the notion of working 4.5 hours and getting paid for 2.
The ground delay limitation, has, well, it’s limitations. If we were in pre-regulation days where an airline was making money with only 60% of the seats filled, flights canceling due to the 3 hour limit would not be much of a problem. What is a problem is flights that are now being canceled because of the new rule and virtually no seats available on subsequent flights to accommodate those passengers. If the ground delays are due to ATC, weather, VIP movement (president in the area) then passengers will not be, as a rule, given cancellation perks since they are beyond the control of the company. If the air conditioning, and restrooms are functioning properly and there are plenty of beverages and snacks on board then that maximum number of hours should be flexible. I would be curious… more »
My child is 2 years old and he is severely allergic to peanuts, tree nuts, egg and milk. My son has reacted to airborne particles from someone opening a bag of nuts near him. My husband and I used to be world traveler’s and dreamed of traveling with our son. It is heart-breaking to think that our child will not get to experience the world, or if he does it may cost him his life. What about when he gets older and his job requires him to fly across the country in a weekend? Should he have to risk his life so he can work in his possible future dream job? This is a disability, no question about it. We are talking about being in the air with peanut particles being circulated through the cabin and possible no place to land for hours. An Epi-Pen only last 15 minutes. Peanut allergy is unpredictable.… more »
I disagree. The “rights” debate is not a good perspective in this context. As used by opponents of accommodations, it is an inflammatory bandwagon fallacy that simply appeals to an ideologically-motivated distrust of government and regulation in any case whatsoever. Even if “rights” was a good perspective, still, there are always competing rights to resolve. In this case, the equal right to travel safely trumps the right to eat a bag of peanuts.
The simple reality is that peanuts have become – for reasons not thoroughly understood – a potentially fatal allergen for a growing number of Americans. There problem will get worse before it gets better, as studies indicate that prevalence has tripled among children in recent years. Unless accommodations are made, this will represent… more »
There does not need to be a death record to make this decision. What sort of standard is that? Put the onus on the peanut industry to finalize the non-allergenic peanut, not on those suffering life-threatening peanut allergies to ante up a few more deaths.
This executive/administrative decision is so simple, it’s absurd. Discontinue service of peanuts on airlines.
I would love the links to those studies also. I unfortunately have seen my daughter have an allergic reaction to inhalation of peanut dust twice-once on an airplane and once in a restaurant we entered before we were aware of the peanut shells all over the floor. Her face swelled and her eyes completely swelled shut-something I would label as a serious reaction. She was too young for it to be from stress. I don’t have any studies to back it up – just what I witnessed. I don’t think the DOT should monitor what each person brings onto the flight – there is a big difference if 150 people open up peanut packs verses 5-10 people bringing on their own snacks. If you have the allergy you do need to be prepared with medications and clean your area with wipes or cover your seat.
We boarded a plane toward the end of the boarding call because our plane from Florida that connected was late. We were running & planning to use the bathroom on the plane cause we didn’t have time to stop. We were not told that the 1 bathroom on the plane was not working. I had to sit on that plane from AZ to CA and almost wet the seat. A plane should be required to have working facilities or ground it. I also think it is just as bad to be stuck on tarmac in small plane as large. There is no air & I have anxiety & start feeling really hot if there is no air conditioning & have to wait with all the people breathing in there it gets worse & worse. 2 hours maximum on the tarmac is enough. Deboard plane & let people get off. We are not cattle or sheep to be herded up in a pen (plane). It is inhuman.
I have a similar problem with errors on your website with MacOS Safari before it is published. Would you ask IT to test your site against modern browsers? Thx.
Once the plane has left the gate as long as it’s officially waiting for take-off, then it appears to me passengers should not be allowed to leave the gate. However, I remember times while traveling thru Denver, United would leave the gate, then taxi to the “penalty box” waiting for clearances and take off instructions. Airlines should not be allowed to leave the gate unless there is a expected takeoff time issued by FAA ATC Clearance Delivery and Ground Control. If the expected departure time issued by FAA ATC is over 3 hours then the aircraft should not be allowed to leave the gate. However, if an airline has left the gate, and the departure time is extended while waiting for take-off, where the total time is greater than three hours on the ground then the airport and airline… more »
As you can see there are mitigating circumstances affecting the airline and aircraft and there are a few organizations involved in the situation.. these organizations include the airport authority, the FAA ATC ground control and clearance delivery control, and airline pilots.
Stronger penalties and contingency plans are separate issues. Contingency plans are just that, they cover a broader array of situations that are likely to occur. Stronger penalties don’t appear to address all the issues. Contingency plans for a broader set of situations. Perhaps the corner cases might not be included but I think there are more situations that need to be worked through. Then again, maybe a blanket rule of three hours would be better since there could be no confusion… three hours is three hours regardless of the situation.
Moderator: So, the EOBR does work automatic, it still does not change my view about the whole EOBR deal. Besides, I did not see anything in the comment about how it has made his driving any safer.
My primary concern is FMCSA falsifying its own information to make it seem that new regulations and such are needed. Plus, adding yet another COST to the trucking company or owner operator – without a positive reasoning.
FMCSA has said that only 1.4% of the trucking accidents were fatigue related in 2009.
So why are EOBRs needed? Seems like a complete waste of time and money, at a time that money is tight for everyone. And with the announcement of another Cross-border trucking program, money will be even tighter.
By the way – FMCSA announced they where going to pay (Actually tax payers… more »
There is no definitive method of determining who is a long haul or short haul carrier. Any method used will cause carriers to get on the non EOBR required side. Some might consider this a loophole but it is not. If a carrier does what meets the definition of a short haul carrier than they are a short haul carrier. If the EOBR rule is then moved over to short haul carriers the cost of compliance figures are greatly under estimated. Instead of 2 million power units required to use EOBR over 10 million units will be required. At FMCSA’s estimated cost of $785 per unit a year that is almost $8 billion a year. The majorities of these short haul units are used very few miles a year and are not at risk of HOS violations. It is clear that this rule is made to enrich an industry that is lobbying… more »
Ok so a manufacture is an expert on how well an EBOR works, I will give you that. On the other hand any pit falls that they have with them they are not going to sit and air it out for all to see. Remember they are private companies out to make a profit, so they will always say they are a good thing. And as far as the trucking companies you have brought forward, and did the self imposed EOBR in their own truck. Why some ask? That is an easy one to answer, those companies chose to hire none experienced drivers and found that the EBOR was the easiest way in order to track their rookie drivers and make sure they were doing what the company wanted, an electronic babysitter. So now you say how those trucking companies are experts on the EBOR, maybe but like I said about the manufactures, I will also… more »