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1675 retail cost x 7= $11,725
100 installation x 7= $700
$480 yearly x 7 = $3360
$15,785 total first year cost for a small fleet of 7. (We’re assuming no repairs or anything else going wrong here)
$2255 total first year cost for 1.
My first question is “Who do you think is going to pay for this?” I’m assuming you guys sitting behind desks over there will say “You.” My second question is “Why?”
Why do you think we should have to pay for this? You present this as if this is some kind of miniscule cost for a small carrier. Maybe these big guys you’ve quoted can afford these things and they obviously can considering they’ve installed it on their entire fleet. Have you considered that maybe they’ve done this to simplify some of their bloated systems and utilize the government—by… more »
You mentioned that the government could subsidize production of new trucks so that they come pre-fitted with EOBRs. Could you share more details about how you see this working? Would truck owners receive subsidies to equip old trucks as well?
I see this working as a cooperation with manufacturers of the vehicles on any new vehicles that enter the market. A standard EOBR system would need to be introduced to cut costs and keep it consistent across the board. This would cut production costs as well as training costs in relation to safety officers inspecting the EOBRs and what to expect. If the EOBRs are always the same they know exactly what they’re doing when they inspect one—and so will the drivers and everyone else in the industry.
The trucks that are already on the road would pose the… more »
Is the 3-year proposal too long? Too short? Why?
3 years seems like adequate time for many companies to comply. However, just because one agrees with the timeframe doesn’t mean that it still allows for the industry to be competitive –as I’ve stated before about smaller companies and individuals being able to afford these items without assistance—or that one even agrees with the practice.
Should all carriers be required to comply by the same time, or should larger carriers be required to install EOBRs sooner than smaller ones? Why? The compliance date should be the same for either group. If anything a smaller fleet would have less trucks to worry about whereas a larger fleet would have a larger undertaking. As long as enough time is allowed for the smaller fleets to get the subsidies or anything else they could get to help pay for the equipment, install it and train their drivers in its use, then it shouldn’t make much of a difference here. I’d certainly be interested to hear any arguments as to why this would matter if they are allowed a several year deadline.
How many power units/vehicles should be considered “large” for this purpose?
This one would be hard to set a number on. I’m sure they already have classifications based on groupings they have developed using the new CSA 2010 standard where the groups are compared to their peers. Might as well stick to this standard.
Should EOBRs be phased in over a period of time, depending on the number of power units in the carrier’s fleet? Perhaps, but this would probably create another auditing point. Having a deadline for all trucks to have EOBRs sounds more feasible because you can just fine the offenders. Phasing it in and requiring that a certain amount of a fleet is required to have an EOBR by certain dates would require more auditing and resources.
What would be the break points for each phase? No comment.
Are there other factors FMCSA should consider in setting compliance dates?
Consideration for the carriers should always be a factor. Carriers should be able to ask for extensions due to relative hardships. Information (locations to have it done or how to do it, etc) and subsidizing the costs should be available to the smaller fleets certainly.
“I am all for being able to track our drivers”
I don’t want to word it this way. I’m not about tracking people. However, I think what’s being said here is “I want to track my equipment and my liabilities. I want to know what’s being done with it and how my resources are being spent.” We know that drivers can be a liability for smaller fleets because some of them think that after they get done with their assignments the truck is just their personal vehicle. I’d also love to know what route they are taking at all times and be able to easily divert my drivers with available information or even advise them where to get fuel without having to call them.
“include cell phone tracking/management systems.”
Sounds very interesting. Cell phones are also integrating GPS technologies all the time and things could be done just like I noted above. Our system already allows for load data to be sent to drivers with smart phones. These are certainly viable options and alternatives to EOBRs. In fact, I believe EOBRs are probably not where we should be heading. We should definitely be going paperless, but there are much better alternatives than what is already out there and understood and I know someone could innovate.
“HOS in the proper format on his cell phone or GPS PDA and the company has access to the same information at the Home Terminal”
This would be excellent for safety officers and operations. This would help dispatchers with a clear picture of things if they could view a driver’s logs in real time. A safety officer could also stop drivers before they go into violation with alert systems. The responsibility should still fall on a driver to properly maintain and adhere, but these would be excellent ways to ensure compliance.
“having all of the upfront cost on buying another accessory to add to our trucks that may “break” down and we have to send that unit off to get it repaired…does that truck just have to be put “out of service” until the unit comes back in?”
My first comment covers much of Jeff’s comment here. I agree completely that these will just be another item that needs to be repaired and contingency plans made that will get the item working again as soon as possible and still remain in compliance through the use of paper logs.
“there needs to be a standard for all CMV Companies”
Absolutely. That’s my comment.
“Why do you not include companies like Telenav Track or Xora or another similar company into the EOBR guidelines that all they need to do is “make [an] app for that”? The apps can be very detailed and the driver will have to enter some information but they will have to do that anyway we look at it.”
I’m still not sure about the whole cell phone thing. I think a separate system that could be hardwired into (but not necessarily installed into the truck) the vehicle that could serve as a multi-purpose unit would be a better choice. Cell phones are certainly growing into huge personal devices, but they can also be very unreliable as cell phone manufacturers make them cheaper and cheaper and the margins get ever tighter. Also, I imagine the data input into a cell phone would just be too difficult to manage. I’m sure there are methods that could be developed, but this seems like it would be a very tedious task. However, I would keep an open mind until I tried one. It’s just what I’m imagining. I’m certain many types of smartphones could do this very seamlessly. Such as a touchscreen device that would allow you to just drag a bar across the times you were on duty driving and then going up to do sleeper berth. Allow it to zoom in and do it in blocks.
I’m certainly open to this sort of thing, but I would see a device almost like an iPad or a 5 inch GPS unit that is mounted on the dash and hardwired (the power source at least) into the truck. The unit could be removed and used for communication through wireless networks/satellite back with the carrier, etc.
In other words, I wouldn’t want to see it just used for recording logs. It should benefit the industry. I think drivers everywhere could benefit from a GPS. Even if they don’t need it for directions, who could deny the benefits of seeing what roads you’re approaching, seeing the speed limits for the areas you’re driving through, etc… They even find locations to eat, banks in the area (has helped me once when doing IFTA for my company and they sent me with the wrong paperwork), etc.
“If these EOBRs had a broader range of features that drivers and companies could use for different purposes, do you think the companies would be more willing to foot the bill for purchasing, installing, and maintaining them? What other features do you think would make the cost worthwhile, especially for small companies?”
A GPS device is more than just a location tool or tracker. It can also save people from making wrong turns—and it can also encourage some others to make wrong turns. However, it is likely to cut down on the amount of fuel spent simply by encouraging better routes.
Take the time and do the math on one truck saving 20 miles a load. Now multiply that times a fleet. Or multiply that by the entire country. Think about how much less fuel we would need as a country.… more »
Thank you for your great comment aaron and welcome to Regulation Room! You raise a lot of good, practical points likely to get FMCSA’s attention.
You mentioned that the government could subsidize production of new trucks so that they come pre-fitted with EOBRs. Could you share more details about how you see this working? Would truck owners receive subsidies to equip old trucks as well? What do other commenters think about this proposal?
What do think of the ideas jeff raises below?
Also, aaron, maybe you have ideas about what whether FMCSA should phase in compliance by carrier size. You can read and discuss the current proposal here.
If these EOBRs had a broader range of features that drivers and companies could use for different purposes, do you think the companies would be more willing to foot the bill for purchasing, installing, and maintaining them? What other features do you think would make the cost worthwhile, especially for small companies?
You may also want to add your voice to the “What about Privacy concerns” section based on your comment that EOBRs are for tracking equipment and liabilities, not for tracking drivers. You can access it by clicking here.
Does anybody else know any reasons why small and large carriers should have different deadlines to comply with the rule?
Do other commenters agree that EOBRs should be made with additional features, like GPS technology? Do you think this could save money for drivers and owners? Is it possible to include more features without causing the price to rise?
Aaron, your comments on privacy concerns are helpful and will be incorporated into our summary to DOT, but would you be willing to re-post them in the privacy section? Commenters interested in that part of the proposed rule will have an easier time finding your thoughts and responding to them.
Would these equipment cost estimates be accurate once implementation of the rule creates a large increase in demand?