Profile: jbh249
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Moderator: The PikePass-similar device is not actually anything that I know of to be in production, but rather a suggestion which would work as well as any EOBR without invasion of privacy concerns, potential abuse by law enforcement, and a wide variety of other effects.
The PikePass works simply by being scanned when a vehicle travels through a toll, where it simply attaches a log file to the account holder, charges or deducts the toll amount automatically, and allows the driver to remain traveling at the speed limit without the necessity to stop and wait in line to pay physical cash to a toll-booth operator.
If the same technology were implemented and adapted to include other information, such as the speed limit at time of “capture” of the device’s data, etc., then it… more »
Of course, this isn’t something that I have studied in great detail, but rather it’s one of the first things that comes to mind in regard to eliminating further discussion in favor of EOBRs.
From what I’ve gathered, requiring these devices is not favored by anyone in the vast majority of the industry, and at last check the industry was composed of somewhere near 80% owner-operators compared to a smaller group of mega-carriers, which happened to be in favor of the EOBR.
It would seem more rational to go with the majority than with the minority, for favoring the minority side’s decisions would imply an inherit amount of bias, and political/business cooperation, which is never a good thing.
Needless to say, I hear a screaming voice from the majority in opposition of the EOBRs and only a few in favor. I would be scared to go against that majority for fear of losing business, and implementing a “big brother” type of control over human beings in the name of what we are being told is safety.
One more thing, concerning the safety issue: I haven’t yet found any compelling evidence that the EOBRs have anything to do with safety. They seem more likely to be used as a time-saving tool for certain things like inspections but as they are not being properly marketed as such, one can only assume other things, hence the uproar and resentment, due in part to the foreknowledge by most that these devices will aide in the reduction of wages and in turn the decrease in the level of financial stability of the lives of the people directly effected.
As for Privacy issues, the only logical conclusion that can I can reach is that these devices invade privacy, whether it can be deemed legal or not. If someone does not want one of these devices capturing certain data then it would seem that doing it anyway is, in fact, an invasion of privacy, or at the very least, knowingly denying a citizen’s request for peace or “non-intrusion”, if you’ll pardon the vernacular.
Thank you. « less
So now all of a sudden the government is now telling a company that their cost of a unit is to much money, and you have your so called experts that are going to sit there and point their fingers at each other and saying how the other guy is charging to much and trying to take advantage of drivers. So maybe the FMCSA might want to step in and say how much the can charge drivers. Any way you look at it the government is totaly over stepping their power, and they have become a government run by the government for the better of the government and you need a special little room to see this. I do not know if I am the only one that see’s it this way or not but it’s a shame that the FMCSA is going to be the undoing of a lot of little companies and their is no defending that I don’t… more »
http://www-nrd.nhtsa.dot.gov/Pubs/811363.pdf
MR. moderator you were asking where somebody else came up with fatality stats that you asked where he found is stats. I do not know where he found them at, but these come right off there on web site.
In 2009 there were 3,3380 deaths in large truck related accidents and that was down 865 from 2008, in which was a 20% drop.
So the numbers have bee on a steady drop since about 1997. So tell me that there is not more to the big push for EOBRS and the push for a change of HOS. Those numbers do not take into consideration the percentage of those accidents that were caused by the other vehicle in which is figured to be at 75%. Now you… more »
Thank you for the link to the fatality statistics, trucking. Hard data and sources are invaluable to the Agency during this process. Do other commenters agree that FMCSA has not fully taken these statistics into account for the EOBR proposal? Do commenters have any more data on this topic?
Most of our drivers accepted the change as no different than paper logs, understanding that this is the nature of the industry. We have drivers that have been with us from anywhere between 1 to 30+ years. A few at first refered to it as the ‘egg timer on the dash board’ – but after using it for a few months and learning the software I haven’t had a single complaint. In fact, when there are computer problems or a driver needs to go to temporary rental unit they complain that they have to keep paper logs again! Our fleet is actually 100% EOBR and have been for almost a year.
We gradually introduced them to our team and we work with our entire fleet so that they are fully capable of using them with confidence. There has been no issue in terms of safety either. We also… more »
Perhaps the difference is that we are deeply committed to our team and that’s why we have had success with EOBRs? I would like to think so. « less
The fact that some drivers have grown to appreciate some of the benefits EOBRs have to offer has nothing to do with whether or not they should be mandated in every truck.
Every driver in the country could absolutely love them, and that still would not be reason enough to require them to be installed in every truck.
Personally, I am opposed to any mandate, but can see the benefits for requiring the carriers with a long history of HOS violations to use EOBRs. Outside of that, the choice of whether or not to equip a truck with an EOBR should belong to the carrier or truck owner.
Again, I have no personal experience using an EOBR since I am not a truck driver. Anecdotally, I can say that the majority of HOS violations are not due to driving more than ten or eleven hours per day. Rather, the… more »
Another bigh cause of logbook falsification is to allow a driver a break that would not be doable under the regulations while still allowing the driver to meet any deadlines.
EOBRs would be effective against this type of falsification. However, I’m pretty sure I would rather they weren’t. If a driver is feeling ill, wants to avoid the stress of rush-hour traffic, or simply has an off day and needs a rest break, the EOBR will be there telling them that they’d better keep moving if they want to meet their appointment time.
I’ll take the driver who chooses to take the break and fudge the book anyday over a driver with the same deadline pushing through while remaining perfectly compliant.
Again, I cannot stress enough that the FMCSA cannot have it both ways. The reasoning behind revisiting the HOS yet again is that they cannot be conclusively proven to increase highway safety. Therefore, increasing compliance with those HOS CANNOT be for the purpose of improving safety.
Even if they could conclusively prove a correlation, fatigue-related truck accidents make up only a small percentage of truck-involved accidents. Nothing about a sweeping mandate of EOBR technology makes any sense. « less
I don’t think making airlines responsible is the only way. It shouldn’t be. I think DOT should regulate the way in which air travel is sold whether it is by the carrier or not. It already does apparently with fare advertisements on sites like Orbitz, so why wouldn’t it with regard to website accessibility requirements?
Passengers with disabilities are often already able to use the priority/elite/premium class lines today (though this is probably on more of an ad hoc, charity basis and not as a matter of right). When 100% accessibility is achieved, it is indeed my hope that passengers with disabilities would be able to use every line–and the line most appropriate to their travel just as their non-disabled fellow customers.
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Thanks for expressing your concerns, Trucking. From your comments and others, it’s clear many truckers feel strongly that no kind of EOBR rule makes sense. But FMCSA might not agree, and then it will be important to know whether there are cheaper, better alternatives than what FMCSA’s been talking about so far. Our goal is to have users like you provide any information that may not be included in FMCSA’s proposed rule (you can learn more about Regulation Room’s goals and purposes here). FMCSA is not interested in what we can provide. They need hard data and sources from you, the public. If you feel that there is information on other websites or elsewhere that FMCSA should know about, please provide links to those websites or that information. FMCSA needs as much data as it can get.
Do you think that requiring EOBRs automate some of the tasks truck drivers have to do is enough remove some of these distractions and increase safety? If not, then how could FMCSA improve the proposed requirement for EOBRs so that drivers are less distracted and more compliant, but also aren’t overly burdened by more regulation?
Barney, FMCSA wants to get as much information as possible from people like you with experience in the trucking industry before it makes its final decision. Do you think that shippers and receivers would appreciate road conditions and other delays more if the EOBRs were required to record this information and then display it to the shippers and receivers when you arrive?
If so, could EOBRs help truckers with shipper and receiver problems?
Jeffs, you have provided a lot of useful information about FMCSA’s cost estimates and what the proposed rule may cost your company. You mention that your company will save little if anything from the paperwork reductions. Do you have any rough figures for how much your company may save (or lose) overall?
Your concerns will have the most impact if you can provide FMCSA with hard data and figures.
Dinsmoretransportation, could you provide some more information on the PikePass device, such as links to product websites or technical data? FMCSA is looking for as much hard information as possible and anything more you could provide would be very helpful.
Also, you raise some important concerns about privacy. Do you think that the information in the Privacy post addresses your concerns?
Some other commenters have mentioned that there might be less expensive and less intrusive EOBRs than the Qualcomm device (You can read their comments here and here). How would a mandate for a less expensive and intrusive device impact your decision about continuing to drive a truck?
What do other commenters think of thudder1j’s statement that an EOBR mandate would not be a problem if FMCSA paid to install the devices?
You have raised some important criticisms of the new expert post. Regulation Room is a neutral site and is run by Cornell University, not FMCSA, but we present proposed regulations based solely on what the Agency has released to the public. Some commenters raised issues concerning the Qualcomm device FMCSA bases some of its cost estimates on. We felt that it would be useful to provide a space for commenters with knowledge about other devices to discuss issues not explicitly mentioned in the rule. If you feel that there are entities or individuals with expert knowledge about these devices and should also be included on the discussion list, please contact us.
FMCSA is actually in the process of making changes to the HOS rules in another proposed rule. Information about that rule can be found here. Unfortunately, that rule closed for commenting in February, but you can still read the proposal at regulations.gov. Additionally, your comments about HOS on this site will be made part of the summary of this conversation on EOBRs that Regulation Room submits to FMCSA.
Thank you for the link to the fatality statistics, trucking. Hard data and sources are invaluable to the Agency during this process. Do other commenters agree that FMCSA has not fully taken these statistics into account for the EOBR proposal? Do commenters have any more data on this topic?
Thank you for your input, gorskibulk. Many commenters who identify themselves as experienced drivers say that EOBRs feel like a punishment and that the devices do not improve safety. Do you have any experienced drivers at your company who switched to EOBRs, and if so, could you describe their view before and after making the change?
Vganster, another commenter whose company uses EOBRs says that drivers had some issues with them at first, but after using them for a while grew to like them (you can read the comment here). Do you have experience with EOBRs that leads you to a different conclusion? If so, what has that experience been like?
Hi kingslav, and thanks for your comment. We hope that you continue to air your concerns and suggestions about DOT’s rule. However, opinions alone, without more explanation and reasoning, are not useful to DOT because they do not help them figure out what is wrong with the proposed rule and what should be changed. Is there anyplace you could point DOT and other commentors to that shows that airlines would do this on their own without regulation if they could save on labor costs?
Welcome to Regulation Room, htebazile, and thank you for your comment. DOT has proposed to make airlines responsible for ensuring that online ticket agents meet accessibility requirements, but the Agency is seeking comment as to the best way to implement this proposal and has not yet decided upon the specifics of enforcement. DOT has clear authority under the Air Carrier Access Act to regulate discrimination on airlines’ websites, but it is less clear whether it has authority to regulate the OTA websites in the same way. If making airlines responsible is the only way for DOT to regulate accessibility on OTA websites, should it still go through with these plans?
Hi, borge689. DOT wants help from you to check the accuracy of its estimates, provide additional information, and point out things it might have missed. The data is summarized on the lefthand side of this post. The full analysis can be accessed in the Regulatory Impact Analysis (RIA).
Welcome to Regulation Room, borge689. It looks like you are addressing a potential benefit of kiosk accessibility, which can be found and discussed further Kiosks: Benefits and costs of accessibility post. Do you think there is a way for DOT to put a price on the benefits travelers will receive from not needing special assistance? DOT believes those benefits include increased independence, increased privacy, and an increased sense of inclusion.
Thanks for the link, whitneyq. Can you explain a little bit about what you think of the VVSG standard compared to DOT’s proposal? Or do you just see this as a source of standards DOT hasn’t addressed?
Thanks whitneyq. Judging from your comments so far, it seems like you might have some expertise about the accessibility issues DOT is trying to tackle. Do you have a background or training in the area that would be helpful for DOT to know as it considers your comments?
Thanks for your comment lhare. Would you feel that your privacy was protected if DOT required airlines’ non-airport kiosks to meet the same accessibility requirements as kiosks in airports? You can read about the privacy protections under the proposed accessibility standards in Section 2 of the Kiosk Accessibility Standards post.
Some commenters and DOT have expressed concerns that requiring persons with disabilities to seek assistance from an agent might be somewhat stigmatizing. DOT has also listed several benefits for travelers with disabilities from accessible kiosks. Is there a better way for DOT to address these issues?
Thanks for your comment ntwales. Do you know if passengers with disabilities are already able to use the priority/elite/premium class lines today? When 100% accessibility is achieved, is it your hope that passengers with disabilities would be able to use every line?
Thanks again for your comment, ntwales. DOT has included the benefits you mention (reduced airline staff assistance time) in its main discussion of the benefits and costs of making kiosks accessible. You can read more about what DOT says in section 3 of the Kiosk Benefits and Costs post.
Hi brianpeters, thank you for your comment. The DOJ has currently only provided ADA accessibility standards for automated teller and fare machines (ATMs, for example). Right now there is no accessibility standard for kiosk machines, either in airports or at non-airport locations. Check out Section 1 of the Kiosk Accessibility Standards post if you want to learn more.
Hi ruediix, 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 these draft summaries were posted, let us know! If you wish to comment on the substance of the proposed rule, you can still do that by the end of the day today at Regulations.gov.