More than 3,000 comments have been received by the Department of Transportation about the proposed speed limiter mandates, and the majority of the comments come from drivers and other industry stakeholders opposed to the rulemaking.
The proposal is written as more of a fact-finding request than a fully formed rule proposal. It doesn’t offer specifics on a speed trucks would be limited to. The DOT did appear to be leaning toward either a 60, 65 or 68 mph cap, however.
Many of the comments, if not most, received to the docket so far have been in opposition of the rule. Although it hasn’t filed a formal comment yet, the American Trucking Associations has said it won’t support the rule as it’s currently written, despite its past strong support for a rule mandating limiters.
There are two weeks left in the comment period, which closes at the end of the day Monday, Nov. 7.
ATA and the Owner-Operator Independent Drivers Association have both petitioned the DOT for an extension of the comment period. FMCSA has not yet responded to the requests.
Docket Management Facility: U.S. Department of Transportation
1200 New Jersey Ave. S.E., West Building Ground Floor, Room W12-140
Washington, DC 20590-0001
Some comments made to the docket so far can be seen below:
“[Florida Trucking Association] is…concerned both about the timing and the nature of the NPRM. Given that we are only a few months away from the end of the Obama Administration and that the speed limiter issue has been on USDOT’s radar screen for a decade, FTA questions the efficacy and the sincerity of a proposed rulemaking and invitation to comment being produced in the fall of 2016.
Our problem with the timing is compounded by the nature of the proposal. We are presented with an extraordinarily vague rule. No rationale or scientific basis is provided for the 60, 65, or 68 mph limits. I think it is not too much to expect that sophisticated federal agencies, with 8-10 years to prepare, should be able to present a rationale and evidence to substantiate which of the three limits it believes to be best and why it even presents these three different options. Candidly, we don’t believe the proposal is mature enough to merit serious substantive feedback.
Along with many other state trucking associations and our considerable number of members, FTA strongly supports the comments and concerns of the American Trucking Associations (ATA). We also believe that USDOT should withdraw the proposed rule and allow FMCSA and NHTSA to bring it back only if and when they resolve the issues raised in this letter.” – Florida Trucking Association
“The proposal, no matter how well-intended it may be, fails to give due consideration or offer reliable research in too many areas and in too many ways to be allowed to move forward. The proposal is vague. It offers up three options for a top-limit speed but with no evidence or rationale to support any one of the three (and logically, all three cannot be ‘the best’ maximum speed at which commercial vehicles should be limited). The rule has been under consideration for years – but is offered without any history of how, or even if, any of its recommendations have been examined, researched and tested.
The proposed rule ignores any examination or contemplation of the very real and known safety hazard of speed differentials. There is nothing offered to show the safety impacts when a 60, 65 or 68 mph limit is applied to commercial vehicles over 26,000 lbs. GVWR, while surrounding traffic of cars and smaller trucks operates at 10, 15 and perhaps even 20 mph greater speeds. This is an unconscionable omission for a rule seeking to improve highway safety.
The proposal ignores, too, the fact that many commercial vehicles, especially in the western states, often operate for hundreds of miles without interacting with other traffic. There is no immediately clear rationale for suggesting a truck traveling I-80 in Wyoming should have the same top speed as a truck on I-285 in Atlanta.” – Georgia Motor Trucking Association
“While having a speed limit, for example, in the Northeast, set at a speed, either 60, 65, or 68 mph in any of these states where the speed limits are at 55 or 60 mph, a speed limiting device will have no effect whatsoever. However, in the Western United States where municipalities are much farther apart than in the East and speed limits are higher, speed limiters will effectively serve as the least common denominator speed limit.
In these cases, where non-heavy vehicles could travel faster, or, especially in states where there is a split speed limit (i.e. one speed limit for cars and another speed limit for trucks) the effective number of truck and car interactions will be increased significantly and with a greater speed difference between the two types of vehicles. This is precisely the opposite outcome that traffic safety dictates.” – Alec Costerus, president and CEO of Aerodyne Transportation and Colorado-based independent owner-operator leased to Landstar Inway
“I have 42 years of investigating automotive collisions as a forensic engineer, with about half involving heavy trucks, and over a million miles on the interstates observing the conditions that set up accidents. It is a fact that if all vehicles traveled the same speed and no one changed lanes, there would be no collisions on the interstate. Differential speeds causes lane changes and the slower vehicle will become a moving road block… In short differential speed leads to lane changes and collisions, and is a most dangerous condition. Lowering the speed of trucks will only make things worse. Lowering the speed was tried in the 70s and failed. Why go back to something that failed?” – Luther Cox, Conyers, Ga.
“As a CDL holder/now small fleet manager speaking from one that has seen it from both sides of the windshield.. I worked for fleet where all trucks were governed the same but all drivers and loads were not…Simply limiting speed may not add anymore safety to the roadway/highways but have the opposite effect, causing companies to add more trucks (more congestion) to move the same amount of freight in the same amount of time. What took 10 trucks do now, might take 11 or 12 to do.” – Johnny Johnson, Carnesville, Ga.
“I’m governed at 62 and when I merge on the interstate and see several 60 and 62 mph trucks around me, I take the next exit to get away from the herd. A pack of similar speed trucks is so unsafe. You can’t see much of anything ahead, some try to pass even if it will take them 8 miles. It’ll make the roads so unsafe and kill so many drivers because they’ll be surrounded by other trucks. You want trucks scattered out and by themselves so they can see way up the road.” – Dennis Danger
“I have spent the last 38 years in the trucking industry and have done everything from load trailers and drive trucks to manage a trucking company. In between I ran the maintenance and operations for a 400 truck over the road fleet…There is a major safety concern if you have cars running at one road speed and truck operating at a slower speed. When the national speed limit was 55 many trucking companies forced their drivers to obey the law but the general public in their cars did not. If you will check the records you will find that rear end collisions with trucks was at an all time high during this period…The answer to the situation is not more laws requiring trucks to be governed at a particular speed. The answer is already on the books, enforce the current speed limit on all vehicles on the road.” – Mike Bradshaw, vice president, Fleetco Inc.
“I am a owner of fleet of both local and over the road trucks. I oppose the mandated rule of speed limiters for several reasons. 1) More accidents happen in high traffic zones where the speed limit is already below the proposed speed. The frequency of interactions with other vehicles by a vehicle traveling 10 mph below the posted speed limit is 227 percent higher than when moving at traffic speed. 2) The fuel mileage myth. I have had experience with this and can say without a shadow of a doubt this doesn’t hold true in our operation.” – Dwane Balmer
While most commenters were opposed to the rule, there were a few that supported it:
“I am in favor of a speed limiter rule. As a small fleet owner of seven trucks, I believe governing speed is a necessity for both safety and efficiency. From a standpoint of efficiency, lower speed is the biggest factor in saving fuel. Most large fleets already govern their trucks for the purpose of fuel economy. Most independent owner operators drive much slower for the purpose of saving fuel as well. Each 1 mph decrease in speed could save nearly 500 gallons of fuel per year for each truck on the road. From a standpoint of safety, slower speeds have been shown to decrease collisions in nearly every category. The only category that has shown an increase is in rear-end collisions due to speed differentials. However, as stated above, many trucks already have limiters which cause speed differentials. If all trucks were limited, it would be easier for vehicles traveling around the trucks to recognize that the truck may be traveling slower.” – Kenneth Long, Apopka, Fla.
“I believe speed limiters would be a great safety improvement. As one who works in the trucking safety field, I spend a lot of time [on] the road and believe that ungoverned trucks represent a highway hazard. I run the speed limit or less, drive approximately 75,000 miles a year and have done so for the last 30 years and have never been rear-ended, which is one of the claims most often set out by others claiming slower vehicles present a hazard. If the drivers are watching where they should be they will see slower moving vehicles soon enough to either change lanes or slow down. I believe 65 mph is a relatively safe speed at which most fleet vehicles operate today. The argument regarding lost productivity is a red herring. If the driver drives which they are paid to do they will meet most schedules. In addition to saving lives, slower vehicles will save fuel, require less maintenance and hopefully with fewer accidents result in lower insurance costs.” – James Henderson