food shippers of america march 7, 2011 events/bill-graves… · “the benefits consist of safety...
TRANSCRIPT
A Presentation By:
Bill Graves
President & CEO
American Trucking Associations
Food Shippers of America
March 7, 2011
Large Truck Fatality Rate
1975 to 2008
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0
4.5
5.0
5.5
6.0
6.5
1975 1978 1981 1984 1987 1990 1993 1996 1999 2002 2005 2008
Large Truck-
Involved Fatalities
per 100 Mil VMT
Source: NHTSA & FHWA data
Lowest Fatality Rate Since DOT Began Keeping Records
Why Change?
Lawsuits filed by Public Citizen
FMCSA believes…
“The benefits consist of safety benefits from the reduction in fatigue-related crashes and health benefits from drivers working long hours potentially getting more sleep and reducing their mortality risk.”
2010-2011 Hours of Service Rule Regulatory Impact Analysis
FMCSA
12/20/2010
Political Trade-Off
HOS Background
2009 Settlement
2010 Proposed Rule Pending
2007 Interim Final Rule
2008 Another “New” Rule 2009 Another Legal Challenge
2005 “New” Rule
2005 Another Legal Challenge
2003 Final Rule
2003 Legal Challenge
Current Timeline
January 2012? June 2012?
Final Rule Becomes Effective
July 2011
New Final Rule Published (Not Immediately Effective)
March 4, 2011
Public Comment Period Ends
December 2010
FMCSA Published Proposed Rule
Proposed Changes
Current Rule: 11 Hour Drive Time
Proposed Rule: 10 Hour Drive Time (Sort of-Maybe?)
Current Rule: 34 Hour Restart
Proposed Rule: 2 Night Rest (12am-6am); Limit restarts to once every 7 days.
Current Rule: No Mandatory Rest Breaks
Proposed Rule: Mandatory Rest Breaks Once Every 7 Hours.
ATA’s Strategy
Inform the Industry
Request Listening Sessions
Load the Docket
Cost Benefit Analysis
Health Benefit Analysis
SBA Involvement
Congressional Support
“Dear Colleague” to FMCSA Administrator
Inform the Industry
Listening Sessions One Granted: February 17, 2011 / Crystal City, VA
ATA Witnesses – Dave Osiecki - ATA
– Don Osterberg – Schneider National
– Bob Petrancosta – Con-Way
– John Spiros – Roehl
– Tim Smith – Tennessee Commercial Warehouse
– Mike Baker – Usher Transport
– Jim Runk – PMTA
– Bob Viso – U.S. Xpress
– Frank Silio – Covenant Transport (America’s Road Team)
– Bob Weller – Hahn Transportation (America’s Road Team)
– David Heller (TCA)
– Harry Haney – Kraft (NPTC)
Load the Docket
6000 Driver Comments from Swift Transportation
Over 2000 Comments Submitted In Partnership with Transflo, Pilot, Flying J, and Love’s
Lynden Transport
Pitt Ohio
CR England
U.S. Xpress
Covenant Transport
G&P Trucking
www.safedriverhours.com
Cost Benefit Analysis
Edgeworth Findings
"…we find that FMCSA has overstated the net benefits of the proposed rule by about $700 million annually."
"We find that, in every instance, FMCSA’s new methodologies and assumptions increase the apparent net benefits of the proposed rule. However, many of FMCSA’s new approaches rely on misapplication of available data, use outdated information, or lack empirical support entirely."
Health Benefit Analysis
Cappuccio Findings:
“FMCSA’s interpretation of the paper by
Cappuccio FP et al. (2010) is incorrect…”
“the current evidence…does not support
the conclusions of the FMCSA…”
SBA Involvement
Roundtable Hosted By SBA Office of
Advocacy
– HOS Coalition
– Jim Burg, James Burg Trucking Company
Result
– Small Business Administration Submitted Letter
to the Docket
Congressional Support House Dear Colleague Letter Circulated by
Congressmen Schuster (R-PA) and Graves (R-MO)
Signed by 122 Members of the House of Representatives
Senate Dear Colleague Letter Circulated by Sen. Roberts (R-KS)
Signed by 23 Members
Second letter Circulated by Sen. Nelson (D-NE) Signed by Sen. Tester (D-MT)
Independent Letter From Chairman Mica (R-FL) and Congressman Duncan (R-TN)
“Dear Colleague” To FMCSA
Signed By All 50 State Trucking Association
Executives
FMCSA Administrator Anne Ferro Formerly
Served as President & CEO of the Maryland
Motor Truck Association
Other Prominent Issues…
EOBR’s
US / Mexico Cross Border Issues
CSA
Fuel Efficiency Standards
Food Safety Regulations
