SikhsPAC devoted to the interest of the Sikh community living in the United States.
Requesting President Trump and Lawmakers to delay enforcement of the Federal Motor Carrier Safety Administration rules mandating Electronic Logging Device (ELD).
Sikh truck drivers and small business owners seek delay of enforcement of truck regulations making Electronic Logging Devices mandatory.
New truck regulations carry a $2 Billion price tag and are not adequately developed for reliability un-der mandatory conditions.
New regulations from the United States Federal Motor Carrier Administration will require almost all commercial trucks, unless a truck is in an exempted class, to buy and operate an Electronic Logging De-vice (ELD). This rule is an economic threat to truck drivers, small businesses and rural communities. The SikhsPAC is seeking a delay of any enforcement of this rule until the problems with it are solved.
Every truck driver and small business owner is being urged to contact their United States Representative and Senators through the web site at http://fightingfortruckers.com/. Ask them to help get H.R. 3282, "The Electronic Logging Device Extension Act of 2017" passed into law.
Congressman Brian Babin (TX- Congressman Brian Babin (TX-36th) has introduced this bill to amend the current ELD implementation date by two years until December 2019, allowing more time to further evaluate the readiness of the mandate.
Small businesses and truckers and those who support them can go to the White House web site at https://www.whitehouse.gov/contact and send President Trump a message asking him to help save their livelihood. They can also call President Trump at 202-456-1111.
The SikhsPAC supports and agrees with Mr. Forrest Lucas, founder of Lucas Oil who got his start as a truck driver. They are convinced that the ELDs are counterproductive and do nothing to improve high-way safety. They join with those like Mr. Lucas who are seeking a fair resolution of the problems caused by the mandate for ELDs.
"Save the Truckers and Small Businesses from the ELD mandate!" is the rallying call of Gurinder Singh Khalsa as he works tirelessly to get the word out about the problems that will be caused by the ELD mandate.
Three questions highlight the most compelling reasons to delay the FMCSA regulations that mandate electronic logging devices (ELDs):
1. How will the regulations affect truckers?
2. What impact will these regulations have on small businesses and remote communities?
3. What are the safety arguments?
Part One: How will the regulations affect truckers?
Every commercial truck, unless it falls into an exempted class, must have an ELD. The initial costs and monthly fees for the required communication links vary. Additional costs for training of the drivers and the office administrative staff are undetermined. Truck owners and operators will incur increased op-erating costs but no one knows what those costs will be.
There is no guarantee that the device purchased will be compliant with FMCSA rules under the self-certification process. The communications links may not be reliable in areas with poor cell service. The technology is still rudimentary. FMCSA cannot, or at least, has not posted clear and specific require-ments that assure a driver that his or her truck is in compliance. The self-certification plan is a slight of hand attempt to appear to comply with the Congressional directives. An increasing number of exemp-tions are being requested. The confusion is evidenced by the Frequently Asked Questions.
The regulations are a disaster for agriculture and small operations.
The livestock haulers are facing a lack of safe places to off load and biosecurity threats to the livestock if forced to off load before destinations. This is complicated and trains are not an answer.
The fiscal impact of implementation of the regulations is estimated to be two billion dollars. That esti-mate does not include the full cost of training for law enforcement. The state law enforcement agen-cies have "on the road" enforcement responsibilities and have not been trained about these regula-tions adequately. The state laws are also in flux and the training of the local agencies has not prepared those officers to knowledgeably and fairly enforce these regulations. It is unfair to force truckers to hire expensive lawyers to defend against ill-informed and unfounded violations and charges, however well meaning.
Finally, the state facilities are not ready for the pulled over drivers to wait out their ten hours off. In the last year, rest stops are overflowing with the big trucks. The state patrols are ticketing drivers for not parking in approved areas. These "revenue enhancements" are just another hidden tax.
Part Two: What impact will these regulations have on small businesses and remote communities?
The consequences on rural communities and small businesses that rely solely on trucks for all of their goods and products provide the most compelling reasons to delay the mandate. No matter how much one loves planes and trains, trucks are the only steady transportation for so many businesses and whole communities. Trucks bring life to communities.
The trucking industry is the lifeblood of the economy. Truck transport of goods cheaply and reliably is essential to keeping our economy strong.
1. Most smaller communities and particularly rural communities rely on trucks as they do not have a rail or air service.
2. One salient characteristic of rural communities is that they include nearly 93 percent of the persistently impoverished counties in the United States. (National Academies of Sciences, Engineering, and Medicine. 2016. Electricity Use in Rural and Islanded Communities: Summary of a Workshop. Washing-ton, DC: The National Academies Press. doi:10.17226/23539.)
The estimated two billion dollars' implementation costs of the regulations do not include a study of the economic impact on both the economy of the United States as a whole, as well as the adverse impact of increased costs and delays on small businesses specifically. What will be the unconsidered and un-intended consequences of these regulations?
Estimates range widely as to the amount that the costs of shipping will increase. A realistic estimate has to take into account the nature of the product as well as the send and receive locations. We do not know which remote communities, small communities, and small business will lose freight services. Trucks can only deliver where it is profitable for them to do so. The initial and repeating costs of ELDs and the rigid enforcement of unrealistic hours of service will force truckers to eliminate unprofitable deliveries.
Increased shipping costs will add another inflationary pressure to the economy.
Part Three: What are the safety arguments?
More truck regulations are not likely to improve the driving habits of the American public nor are the truck regulations likely to improve safety in significant numbers. The hours of service have NEVER prompted safe driving but, in effect, work against the conscientious drivers.
Drivers believe when they are forced to drive in the time slots set by the hours of service, they are less safe. They understand their biorhythms and fatigue issues. A driver going 30 miles an hour in traffic on Interstate 270 leaving the Washington D.C. area will have a different fatigue time frame than the driver on the I 40 between Tucumcari and Amarillo. FMCSA estimates of 26 lives saved annually by these regulations but that estimate is not based on driving factors that take road conditions and locations into account.
In 2015, 32,166 deaths total were reported due to highway crashes. (Source: Fatality Analysis Reporting System (FARS) 2006-2014 (Final File) and 2015 Annual Report File (ARF); National Automotive Sampling System (NASS) General Estimates System (GES) 2006-2015)
While a determination of fault is not available, the 2015 gross numbers are 4,067 people were killed in crashes involving large trucks. (National Center for Statistics and Analysis. (2017, February). Large trucks: 2015 data. (Traffic Safety Facts. Report No. DOT HS 812 373).
Washington, DC: National Highway Traffic Safety Administration.) Of those killed in a truck crash driver fatigue was a factor in less than one per cent.
Last, and maybe most important, if improved safety is the main aim of these regulations, the better approach is to delay the mandate until the following steps have been completed:
1. A sound technology study has been designed and completed to identify the critical and reasonable criteria for the devices to meet rewritten and clear standards.
2. A human factors study has been completed that reflects the actual physical conditions for truck drivers.
3. The hours of duty/service are realistically related to the specific loads and locations of the trucks.
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August 14, 2017
President Donald J. Trump
The white House, Washington, DC
Requesting President Trump to delay enforcement of the Federal Motor Carrier Safety Administration rules mandating Electronic Logging Device (ELD).
Dear President Trump:
New truck regulations approximately carry a $2 Billion price tag and are not adequately developed for reliability under mandatory conditions and if not delayed, it will be effective December 18, 2017.
Please save the livelihood of small businesses and truck driver from the mandate of the Electronic Logging Device (ELD) rule.
Mr. President, it appears that you are the only person who might care about business and shipping enough to understand why the enforcement of the ELD rule must be delayed. The federal bureaucracy seems bogged down in thinking that more regulations will solve problems on highways. In fact, the ELDs are counterproductive and do nothing to improve highway safety.
Please, delay the enforcement of these rules until reasonable solutions can be worked out and then the economy will be safe from the disaster of increased shipping delays and unreliability.
Thank you for taking a bold stand to Make American Great Again!
Sincerely,
Gurinder Singh Khalsa
Chairman, SikhsPAC
(317) 308- 1050, [email protected]