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MTA Asks Feds to Withdraw Speed Limiter Rule

Thursday, November 10, 2016   (0 Comments)
Posted by: Kelly Snyder
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In official comments submitted to the Federal Docket on October 27, 2016 the MTA publicly stated its opposition to the speed limiter mandate rule proposed by the federal government.

“We fundamentally believe that mandating one truck speed for all new trucks through the use of speed limiters will reduce safety, not improve it,” said MTA President John Hausladen.

The MTA detailed its arguments in comments submitted to the Federal Motor Carrier Safety Administration and the National Highway Traffic Administration.

Comments submitted:

The Minnesota Trucking Association (MTA) supports uniform speed limits for all motor vehicles and consistent enforcement of the posted speed limit.  We oppose the proposal to mandate the use of speed limiters on all new Class 7 and 8 trucks.

Many MTA members voluntarily employ speed limiters to manage their fleet safety and performance.  They already establish company limits based on their unique equipment and scope of operations.  The MTA believes trucking companies, not the federal government, should be in charge of establishing speed limiter settings.

The MTA believes mandating the use of speed limiters will reduce highway safety by creating speed differentials between passenger cars and large trucks.  Any of the suggested speeds in the proposed rule (60, 65 or 68 miles per hour) would be below Minnesota’s maximum 70 mile per hour speed limit.  We believe none of the suggested speed limits are acceptable if they create a speed differential between cars and trucks. 

Establishing a uniform maximum speed via limiters for all new Class 7 and 8 trucks would create a number of highway safety risks.  If all trucks have the same maximum limited speed, they would naturally bunch together as they approach each other on roadways. Our member drivers and fleets confirm, based on practical experience today, these “rolling roadblocks” will occur. The result? Congestion will increase.

Increased truck congestion would create greater challenges for all motorists on entrance ramps trying to merge between the trucks.  Cars would likely engage in more risky behavior as they cut in front of trucks, compromising safe following distance. Merging cars would also spend more time in the truck’s right blind spot, where the highest incidence of truck-car crashes occur.

Limiters would also create challenges for trucks attempting to pass each other, if not make it practically impossible in many instances.  Under this proposed rule, trucks attempting to pass would likely impede traffic flow in two lanes, potentially for long periods of time.    

Such roadblocks will lead to more traffic backups and increase driver distraction. Truck drivers will very likely spend more time looking at the rear view mirrors while automobile drivers spend more time looking for a way around the trucks. All of this jockeying for position will only exacerbate the likelihood of road rage.

We support the longstanding policy of states establishing speed limits within their jurisdictions.  State engineering and traffic safety professionals have the best insight into what is the appropriate speed for any vehicle given the terrain and conditions.  Mandated speed limiters remove this local control and ignore the science behind local road postings.  Speed limiters should also not be a replacement for enforcement of posted speed limits among all highway users.

We also believe this rule fails to address a major paradigm shift in truck technology.  Driver assistance technology, truck platooning and fully autonomous vehicles are currently being tested under numerous state pilots. It is very likely that through a combination of GPS technology and vehicle telematics, all vehicles could be automatically and variably governed to the posted speed limit. A speed limiter mandate could actually be an impediment to new technology that may enhance road safety. 

Lastly, we believe the proposal lacks hard data.  Throughout the Notice of Proposed Rule Making (NPRM) there is a use of estimates,  references to undefined “common sense” approaches, and general assumptions due to lack of empirical data.  This lack of hard data and inability to quantify actual benefits is even acknowledged in the NPRM.  It is simply unwise to enact these new regulations using assumptions based on incomplete or missing data.

In conclusion, we believe this notice of proposed rulemaking should be withdrawn.

We appreciate the opportunity to submit these comments. Feel free to contact me with any questions or concerns.

 

Sincerely,

 

John Hausladen

President