Link to FMCSA comments on On board device

[LogsRus]

Below is a link you can view everyone's letters/comments regarding the on board regulation. Some are from drivers and some are from Companys. I find several interesting to read!
There is a way you can comment I will try hard to find out how and respond to this post!

[LINK POSTED BY MEMBER] Only Members Can View This Truck Forum Link.

[LogsRus]

Ok you can do electronic (I believe they mean e-mail) by clicking below and signing up. I suggest anyone who has an opinion to speak up! I can't stand when people don't agree, but don't speak up for themselves! SO DO IT! If you agree with it , then send in your feelings as to why! You do have a say so sometimes, unfortunately someone will be let down (as usual).

Hey maybe you all can think of a better HOS regulation and send that in also! Give it a try

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[thedragon]

Thanks guy, we'll do that.

[TurboTrucker]

Just a little note to refine what has been offered....

Submit comments on the NPRM by any of the following methods:
Web site: [LINK POSTED BY MEMBER] Only Members Can View This Truck Forum Link. . Select "Simple Search" and enter 18940 for docket number. Next, select "Reverse Order." The NPRM is 18940-357.
Fax: 1-202-493-2251.
Mail: Docket Management Facility; U.S. Department of Transportation, 400 Seventh Street, SW., Nassif Building, Room PL-401, Washington, DC 20590-0001.
Hand Delivery: Room PL-401 on the plaza level of the Nassif Building, 400 Seventh Street, SW., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal Holidays.
Federal eRulemaking Portal: Go to [LINK POSTED BY MEMBER] Only Members Can View This Truck Forum Link. . Follow the online instructions for submitting comments.

For access to the docket to read background documents including those referenced in this document, or to read comments received:
Web site [LINK POSTED BY MEMBER] Only Members Can View This Truck Forum Link. .
Visit Room PL-401 on the plaza level of the Nassif Building, 400 Seventh Street, SW., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal Holidays.

[TurboTrucker]

Here are the comments I offered to the FMCSA

I presently work for a motor carrier that has installed Electronic on-board Recording devices on a voluntary level. I have now been driving an EOBR equipped truck and as well as logging electronically, for a period of 120 days to date. Any apprehension that I ever had about the devices, and whether or not it would represent a problem to me, are out the window. I fully embrace the technology and the peace of mind that comes with it.

I signed on with this company 13 months ago in part, due to it's excellent safety record. When asked if I would be among the first to operate under an EOBR and to log electronically, I absolutely jumped at the chance. I wanted to know what it was all about.

The system we utilize is provided by PeopleNet, a communication system that I was already familiar with. As I understand it, the only adapting necessary was to make a software change in both the unit aboard the truck, and in all computers in the main office. There are added costs associated with the service, but since most of the system was already in place and used by the company for tracking purposes, the changeover to a full fledged EOBR was not complicated or represented a cost disadvantage to the company.

Of course, this would not be the case for a business that does not presently equip their trucks with electronic communication devices that are taylored for the industry. The start-up costs would be rather substantial.

From a driver's point of view, my job is somewhat less complicated. The unit is there to view, and my status in regard to the 11,14, and 70 hours rules are updated by the minute. It let's me know an hour in advance before I will go into violation. If I use the 8/2 split sleeper berth exemption, it automatically updates the hours available on each side of those breaks, leaving me with confidence that I remain legal at all times, and will not make any errors in those calculations. It does present to me, a need to plan my time as needed to make deliveries, and not every day works out as planned, but the amendments are made in the scheduling by the company, rather than a burden placed upon me to make it work, not that this was an issue pre-EOBR's.

There are frustrations. At first, a couple of times I was headed home, I had to stop short not far from home, to remain in compliance. I learned to measure my time, so that this did not occur without any unforeseen circumstances. I plan my rest breaks just as I plan my scheduled stops when dealing with pickups and deliveries. My advantage there is that I run the same general routes each week, with an occasional abnormal trip, and knowing where parking is available is essential.

After 120 full days of logging and being held to the standard of an EOBR, I am proud to state that I have had not one hours-of-service violation, something that I have never achieved previously when utilizing paper logs.

The peace of mind in all of this stems from the fact that I can cross inspection locations and greet enforcement personnel with no reservation whatsoever or fear of being found in violation. Another aspect that appeals to me, and one that I hope is never tested in reality, is that because I remain in compliance at all times, an accident investigation where my log entries may be called into question, will never make me nervous. There is an indelible record of my movements at all times for the previous six months that can be faxed to any investigating agency. I am under no illusion that I will forever be in 100% compliance, because the day will come that something will not work out as planned or that an unforeseen circumstance will present itself as na obstacle to this goal, but the system allows me to explain those instances should they occur, just as it should be.

I fully understand some of the reservations out there in regard to this proposed change to the way drivers will have to operate, but this is a positive step and long overdue in my personal opinion. Whether or not the implimentation of EOBR's will accomplish all the goals that those who have called for these devices hope that they will, remains to be seen, but I for one am on board with the on-board recorders.

[IH Truck Guy]

So what's the latest update on this?
Are the feds going to mandate this for O-O"s too?
If so,this would be another reason to retire.