I recently submitted comments on the Federal Motor Carrier Safety Administration’s Notice of Intent (NOI) to file an advance notice of supplemental proposed rulemaking on speed limiters countering the FMCSA’s premise that a speed limiter rule is neither necessary nor desired.
You can read my comments here.
Through its NOI, the regulatory agency seeks answers to questions that suggest it is pursuing a pre-conceived, antiquated 1950s solution to a 2020s' problem. It is clear from the NOI that the FMCSA seeks to apply statically set speed limiters by programming the truck’s electronic engine control unit. That in and of itself suggests that the very agency tasked with regulating the trucking industry knows little about the technology available in today’s trucks.
First, I believe that the implementation of a speed limiter final rule will have deleterious effects and will cause more accidents and damage to the economy.
In my comments, I proposed several modern, readily available technological solutions to the implementation of speed limiters that will better satisfy the objective of a speed limiter rule while also enhancing safety in a geographically diverse, dynamic environment that make a direct response to the questions posed by the FMCSA’s NOI irrelevant.
We need better speed enforcement across the board without creating a safety hazard.
The apparent lack of state and local speed enforcement, for whatever reason, is insufficient grounds to force the entire industry to bend to a speed limiter regulation that fails to justify the cost burden placed upon the industry as a whole, especially a one-size-fits-all approach that ignores the vast diversity of the nation’s geography, population and traffic patterns. If speeding is the problem that needs fixing, then speed limiters on trucks alone is a misapplication of law enforcement policy and strategy.
