Profile: aaron
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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.
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 »
To be completely honest I don’t see why a system with an innate GPS isn’t just installed in everything. The GPS technologies are getting cheaper and I could see them being used to identify when the truck is in motion—as opposed to using an EOBR that tracks when the vehicle is in motion with motor use. They can certainly tell you how fast you’re going. I’m sure something could be setup that would not only track their on duty driving time (by automatically changing duty status when the vehicle is in motion), track the drivers and also serve as a location tool for trucks. It could even be used as a communication tool from the carrier. Some may think that they could just fool it by placing it in an area where it wouldn’t find satellites but as soon as it comes back on and finds a new location miles away from the original it would be easy to program to show an HOS violation. (Please note this idea here for when I claim some kind of use of my idea later in court hahaha).
These systems could also be integrated with current software to show more accurate arrival/departure times from shippers and possibly integrate enough into the software to automatically notify customers of these events and any delays in shipments. I’ve seen systems where the software can be checked online by customers before with GPS tracking that just gives a tracking position. I’m sure Google could jump into the trucking industry and before you know it we’d have locations of trucks on a map that you could just highlight and see the driver, contact information, route, hours available, etc. (Do you hear me Google?)
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.
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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?
“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 »
If the government could also communicate with the fleets through these units the savings could be astronomical. If they have a dedicated traffic department concerned with congestion and weather they could notify trucks in certain regions to avoid certain roads or even routes. No longer will you have hundreds of trucks backed up in a traffic jam burning fuel and going nowhere. You might have a few still that might slip through due to late notification or bad reception in some areas—one cannot foresee all the issues. However, providing them with advance notice allows them to make changes to their routes.
This could certainly generate more profit on the transportation side simply by making everything more efficient. The government certainly has enough opinions about making trucks and cars more efficient—I know the GSA has converted their entire fleet to hybrids. Let’s make the routes more efficient as well through technology. The capabilities are there. We know that devices can send and receive information almost everywhere over networks.
Allow me to address your “tracking equipment and liabilities, not for tracking drivers” concern here if you don’t mind. I really should get back to other things soon.
The GPS, like the EOBRs, can only track the equipment. Sure, cameras and things could be installed, but so long as it’s not on a cell phone constantly carried by a driver you cannot track the person. The GPS can determine when the vehicle is in motion. It can’t determine when the driver is in motion. It can’t determine when the driver is asleep. Sure, you might be able to install some weight sensors or something like that in a sleeper berth to determine when a driver is in the berth and have it integrated into the GPS unit somehow, but that would be extremely invasive.
The only point I would like to drive home by recommending alternatives to the “EOBR” standalone unit is that we have a chance to be innovative. Why spend 1500 dollars on a unit that could be emulated onto a much cheaper device with other capabilities?
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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?
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 »
Let me throw some random numbers at you, too. How does $2255 for the first year seem like a small cost to a guy or gal that is operating on thin margins most of the year, factoring and constantly worrying about maintenance fees and random fees that might be incurred? What about the fact that the fuel costs change faster than the freight pays sometimes? They already pay thousands in multiple forms of taxes.
“Simpler to operate than many mobile phones” is a subjective statement. Many drivers violate their logs, but many of the drivers violate their logs because they can’t count or pass basic math classes either, but apparently the simplicity will make this all better.
As per the “cost savings” it is very badly estimated. $27 and $29 an hour savings is not a very realistic figure and you’ve already mentioned that some drivers are not compensated by the hour or compensated to complete their logs. That’s definitely true in my fleet. $27/29 is probably overestimated by as much as 17-19 dollars an hour in some places. You’re much closer on the RODS forms estimate. Additionally you’re assuming that some of these smaller companies even have a staff that large and are compensated for this type of work.
“This means that more than 3.3 million CMVs Commercial Motor Vehicles (vehicles owned or used by a business) lack the devices.” So, were you planning on investing in Qualcomm stock anytime soon?
These smaller carriers aren’t accountants and many times they are not the best organized people in the world either. They’re living from day to day and paycheck to paycheck. I’m not even talking about our operation; I’m simply speaking for the trucking industry in general.
Do I think EOBRs are a good idea? Sure. Many of the things you report are pretty accurate in my opinion.
Do I think smaller companies should bear the burden of purchasing all of this equipment? No, I don’t. I think the government should assist and create a standard to be reviewed every 5-10 years with changes to equipment as they suggest that it should last about ten years.
This type of thing will be considered an additional start up cost as well, so you probably won’t see as many new people entering the industry or able to enter the industry. Many try to enter through the bigger players in the market like Schneider and pan out and do their own thing, but additional costs like this keep the small guy out of the playing field. I can think of several trucking companies that went out of business imply because they couldn’t afford to renew their tags, but their expected add another expensive item to their trucks.
The Feds could always coordinate and subsidize all new trucks produced in the factories to come installed with EOBRs as well. You just need an industry standard device when it comes to using EOBRs so that there is a consistent standard and training is available across the board. I’m sure Qualcomm will get the contract, so everyone should purchase a lot of Qualcomm stock as soon as it drops a little bit.
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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 »
To be completely honest I don’t see why a system with an innate GPS isn’t just installed in everything. The GPS technologies are getting cheaper and I could see them being used to identify when the truck is in motion—as opposed to using an EOBR that tracks when the vehicle is in motion with motor use. They can certainly tell you how fast you’re going. I’m sure something could be setup that would not only track their on duty driving time (by automatically changing duty status when the vehicle is in motion), track the drivers and also serve as a location tool for trucks. It could even be used as a communication tool from the carrier. Some may think that they could just fool it by placing it in an area where it wouldn’t find satellites but as soon as it comes back on and finds a new location miles away from the original it would be easy to program to show an HOS violation. (Please note this idea here for when I claim some kind of use of my idea later in court hahaha).
These systems could also be integrated with current software to show more accurate arrival/departure times from shippers and possibly integrate enough into the software to automatically notify customers of these events and any delays in shipments. I’ve seen systems where the software can be checked online by customers before with GPS tracking that just gives a tracking position. I’m sure Google could jump into the trucking industry and before you know it we’d have locations of trucks on a map that you could just highlight and see the driver, contact information, route, hours available, etc. (Do you hear me Google?)
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.
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“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 »
If the government could also communicate with the fleets through these units the savings could be astronomical. If they have a dedicated traffic department concerned with congestion and weather they could notify trucks in certain regions to avoid certain roads or even routes. No longer will you have hundreds of trucks backed up in a traffic jam burning fuel and going nowhere. You might have a few still that might slip through due to late notification or bad reception in some areas—one cannot foresee all the issues. However, providing them with advance notice allows them to make changes to their routes.
This could certainly generate more profit on the transportation side simply by making everything more efficient. The government certainly has enough opinions about making trucks and cars more efficient—I know the GSA has converted their entire fleet to hybrids. Let’s make the routes more efficient as well through technology. The capabilities are there. We know that devices can send and receive information almost everywhere over networks.
Allow me to address your “tracking equipment and liabilities, not for tracking drivers” concern here if you don’t mind. I really should get back to other things soon.
The GPS, like the EOBRs, can only track the equipment. Sure, cameras and things could be installed, but so long as it’s not on a cell phone constantly carried by a driver you cannot track the person. The GPS can determine when the vehicle is in motion. It can’t determine when the driver is in motion. It can’t determine when the driver is asleep. Sure, you might be able to install some weight sensors or something like that in a sleeper berth to determine when a driver is in the berth and have it integrated into the GPS unit somehow, but that would be extremely invasive.
The only point I would like to drive home by recommending alternatives to the “EOBR” standalone unit is that we have a chance to be innovative. Why spend 1500 dollars on a unit that could be emulated onto a much cheaper device with other capabilities?
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