MTAC has filed comments with the Federal Motor Carrier Safety Administration (FMCSA) in response to their Advanced Notice of Proposed Rulemaking (ANPRM) regarding federal Hours of Service (HOS) rules. In the ANPRM, FMCSA asks for responses to several questions. MTAC’s comments are responses to many of those questions, and were formed from information provided by members.
In the comments, MTAC supported adjusting the on-duty time limit for the short-haul exemption from Records of Duty Status (RODS) from 12 to 14 hours. MTAC commented on the importance of the adverse driving condition provision in the Hours of Service rules, and mentioned how state governments are prohibiting truck travel during snowstorms, for example. The comments support having the adverse driving condition apply to not only the 11 hour drive time limit, but also the 14 hour on-duty time limit.
MTAC’s comments support eliminating the 30-minute rest break requirement. This requirement is arbitrary, many groups and carriers are already exempt from it, and it is difficult to enforce. Since most MTAC members are local or regional carriers, they inherently wind up with breaks throughout the day.
The last major aspect of the comments touched on potentially expanding the split sleeper berth provision. MTAC wrote that a technical memorandum from the American Transportation Research Institute (ATRI) outlines how split sleeper berth flexibility would result in the savings of 2.3 million hours of driving time and $150,000,000 annual savings in truck operating costs. With split sleeper berth flexibility, drivers would have the ability to use some sleeper berth time in order to avoid congestion that they know is coming at certain places and times.
MTAC’s comments are available online.