Livestock Haulers Request More Drive Time – Comment Period Open
Comment period closes on March 8, 2019.
On February 6, 2019, LMA’s petition requesting a temporary modification of hours of service (HOS) requirements for livestock, fish, and bee haulers was posted to the Federal Register and is now open for public comment. LMA members, their producer customers/consignors, and livestock haulers are encouraged to submit comments in support of this important request. The comment period closes on March 8, 2019.
The petition would allow drivers who complete fatigue management training, have a sufficient safety record, and are willing to follow certain documentary requirements to drive 15 hours during a 16-hour work day and rest the currently required 10 hours. To read a copy of the petition click here.
Why Submit Comments
The Federal Motor Carrier Safety Administration (FMCSA) will take public comments into consideration when deciding whether to allow livestock haulers more drive time. The number of total comments, as well as the quality of those comments matter. Hearing the impact of the currently too-short drive times allowed for livestock haulers and the impact it has on livestock marketing businesses and producers directly from the source will increase the weight with which our views are heard.
How to comment:
- Go here: https://www.regulations.gov/document?D=FMCSA-2018-0334-0002
- Click “Comment Now!” in the upper right-hand corner of the screen in a blue box
- Type comments into the field. Comments are limited to 5,000 characters. If you anticipate needing more room, write your comments in a Word document, save it to your computer, and then attach it to the comment using the “Choose files” box.
- The category you should select from the drop-down category section is “public comments.”
- Click continue in the blue box in the bottom left-hand corner of the screen in a blue arrow.
- Check the “I read and understand the statement above” box
- Click “submit comment”
What to Include in Comments
The best comments are those that are professional, concise, and personal to the submitter. Begin by identifying yourself and your role in the livestock industry and how live animal transportation impacts you and your business. Then, clearly explain your support of the request for more drive time.
Some key points to include:
- How far livestock must travel from the ranch to the market and from the market to their next destination in your part of the country. Although many of those trips can be completed in the 11 hours allotted under current law, there are several trips that cannot be made in 11 hours.
- Although more drive time would be appreciated, the 4 extra hours asked for in the petition is very helpful to lots of markets, producers, and truckers.
- As the petition states, by completing extra training and conducting trip planning activities, livestock haulers can drive this extra time in a safe way.
- This request is focused on providing flexibility to a small, well-defined, specific group of livestock haulers, not a broad cross-section of the entire trucking industry.
- Livestock haulers have a great track record of safety, which is supported by data cited in the petition.
- Livestock haulers are unique to the commercial motor vehicle industry – they haul live animals.
- Give any examples of increased economic hardship your business will face if this flexibility is not granted.
If you have any questions about these resources or other industry information or legal issues, contact LMA VP of Government and Industry Affairs Chelsea Good at firstname.lastname@example.org or (816) 305-9540 or LMA legal counsel Jara Settles at email@example.com or (816) 891-0502. You also can talk to LMA VP of Membership Services Kristen Parman or your LMA Regional Executive Officer about these issues.
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