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Speed Limiter Comment

Sep 11, 2016 at 12:01 PM CST
+ 1
Here is the comment that I posted to the FMCSA. I realize that it most likely will not do any good, but I am trying to abide by using our legal system in the proper way. I suggest that you as well post your comments, I have attached the link at the bottom for you.

The unsafe factors of Speed Limiters (Governors)

While many think that applying speed limiters or governors to big trucks increases the safety factor it indeed does the opposite. Most drivers by nature will run a limited truck at the top speed the majority of the time, because they instinctively feel that they have to run the truck as fast as they can. Drivers that drive an ungoverned truck on the other hand have a tendency to drive at the speed that is conducive to them, the road conditions, as well as the speed limits that are posted.

Here are just a few of the fallacies of speed limited trucks:

  1. The driver that is limited and drives at the top limited level constantly leaves themselves no safety margin for blow out situations. This can especially be dangerous in a steer tire blow out situation, this may explain why we see much larger carriers equipment in a roll over situation more frequently than a smaller carrier.

  2. The driver that is limited also has a tendency to drive through towns and construction zones above the safely posted speed limits. They feel the need to make up for lost time and thereby instinctively do so when they can.

  3. The driver that is limited also has a tendency to drive in adverse conditions at speeds that may not be conductive to the conditions. They feel that they can not slow down and be safe because when the opportunity arises they will not be able to run the posted speed limit.

  4. I believe you will see an increase of rear end collisions or other incidents by activating a speed limiter. The motoring public barely even notices our trucks currently, imagine that all the trucks are now running slower and impeding their progress. Just travel out on our interstates a little and watch what happens when two governor-ed trucks are trying to pass one another. The line of traffic increases, with the motoring public weaving from lane to lane trying to pass these two trucks. I have seen the motoring public go as far as to pass the trucks on the shoulders. Is this safe for anybody? You will have more and more of this kind of action going on.

We currently have a speed limiter program throughout the country, each varying depending upon the roads, cities, and states. Now we are proposing putting a nationwide speed limiter (governor) on all trucks in the name of safety. With the previous mentioned fallacies you hopefully will now see that this would be a grave mistake.

We small carriers realize that the FMCSA is under pressure from special interest groups to supposedly make a safer level playing field. The current point structure that is used is unfair to a small carrier. The electronic log program that you are getting ready to roll out will not save us money as you have stated but cost us money. Current cost for paper logs are roughly $5.50 per month, cheapest ELD on the market $20.00 per month, where is the cost savings? We small carriers just ask that you start excising a little common sense. We do not have the monies needed to lobby you for our interest, if things continue the way they are currently going then the small carriers will be closing up their doors and by and large we are the main reason for your organizations very existence. If you think you have a driver shortage, and safety issue today, what do you think will happen when the average experience of a driver is less than two years, and they only received about 6 weeks of basic training in the first place?What are going to be the additional cost for the speed limiter?

Maybe we should focus more on the enforcement of the current speed limits for all the motoring public. Maybe we should require better training for those with CDL to include them being able to read and write. I don't know but common sense goes a long way and having a better educated pool of drivers seems to be a much better choice in the long run.


COMMENT LINK: http://cqrcengage.com/ooida/app/thru?ep=AAAAC2Flc0NpcGhlcjAxmJ4xdV5twaZKgfoEBtn3VxVO_TAT5H9MdnRZ_M-hn8kVXfOZ_lp_l2sz7uij9_wVffdTJYvuoIwddyRPfVjfXIZ0JdOHLjwnbnIbCgeJ5vypDwdXYPiI1HBkaBxIdP-cxb1jF5PCf-lchh7cr7xFbdaIMRGAs4NlQWVWMtl8oFs&lp=0
Replied on Sun, Sep 11, 2016 at 03:56 PM CST
If they make 60mph, imagine this scenario: I drive from stlouis to springfield almost everyday, as soon as the lane chokes from 3to2 lanes drivers get into the hammer lane all the way to their destination, with no slow poke law and no left lane law on 2 lane interstates, the traffic will be unbearable. Now if someone reared me who gets in trouble ?
Replied on Mon, Sep 12, 2016 at 08:24 AM CST
+ 1 - 1
I was coming home from Omaha Saturday morning and I saw a classic example of a rolling roadblock. At about milepost 352, I started running up behind a group of trucks. I managed to pass one or two , then the game of leapfrog started. A truck just ahead of me pulled out into the left lane and tried to pass the truck in front of him. Of course at 60 mph that wasn't going to happen. We cruised along for a few miles then the truck managed to get past the guy in the left lane. As I pulled around him another truck stepped out into the left lane and tried to pass the truck in the right lane. Traffic behind me was bunching up quite a bit and I had some clown in a little BMW sitting right on my bumper as we followed along for a few miles. The passing truck finally got around the passed truck and we moved up a couple rigs and the process started all over. In my rear view mirror I could see a truck about a mile behind me pull into the left lane and block off a little more traffic. It was quite a sight and very well organized. The one thing that I did notice was that when an ambulance pulled on the interstate the trucks all made way so that vehicle could get rolling, but as soon as the ambulance was past, the leap frog started all again. Kudos to the drivers who pulled over so the ambulance could pass. As I got closer to the 312 exit at Grand Island, I pulled into the rocking chair and watched the traffic behind me try their hardest to get around the trucks, but the process continued. This thing was very well coordinated and was working like clockwork. I wonder how far on down I 80 this continued but I am guessing it went on for quite awhile. I also would guess that this is a sign of what travel on the Interstate system will be like when the speed limiter rule goes into effect. Bring along some ice water and some munchies folks, because it looks like a truck slowdown will also mean Terry Tourist and anyone else traveling the interstate will be slowed down as well.
Replied on Mon, Sep 12, 2016 at 08:56 AM CST
Duanne, and when this happens I am going to put a bumper sticker on my trailer that says this is what happens when you're one of the deplorable 50%ers
Replied on Mon, Sep 12, 2016 at 09:22 AM CST
I have toyed with making up something similar to the "How's My Driving" signs. Only along the lines of "Truck Too Slow" or "Am I Impeding Traffic", "Call 1-800-832-5660".

Replied on Mon, Sep 12, 2016 at 09:25 AM CST
+ 1
Quote: "I have toyed with making up something similar to the "How's My Driving" signs. Only along the lines of "Truck Too Slow" or "Am I Impeding Traffic", "Call 1-800-832-5660". "

Hey Chris this might be a little harsh but how about something along the lines of don't like my driving this is your fault you voted it in tough s*** call your congressman
Replied on Mon, Sep 12, 2016 at 09:32 AM CST
Quote: "Hey Chris this might be a little harsh but how about something along the lines of don't like my driving this is your fault you voted it in tough s*** call your congressman"

I'm open to suggestions. Listing congressmen/women's phone numbers from the respective states crossed my mind as well. As far fetched as it might seem, if they pass this nonsense, the general motoring public could be used to our advantage. If enough unhappy constituents call and complain, maybe speed limiters would go away. Again, a very far fetched thought, but still not completely out of the realm of possibility.
Replied on Mon, Sep 12, 2016 at 09:37 AM CST
It is actually starting to hit the mainstream I talk to 2 of my shippers last week told them they might govern my truck to 60 or 65 mph. I showed them the math and that I could not do two loads per day anymore. I told them they will either have to extend their unload hours or higher more trucks he about had a heart attack said he's barely making it now. I said Tuff shit this is what happens when everybody sits around and does nothing tough shit that's all I can think of like what's happening to this to our government what's happening to our country tough shit we did this to ourselves Tuff shit
Replied on Mon, Sep 12, 2016 at 09:38 AM CST
+ 1 - 1
It Costs Money SQUARED... Ohio Was A Split Speed Limit State. Trucks 60 Cars 70. They FINALLY Passed The Law To Keep All Vehicles The Same At 70. They Found Out There Were MANY Less Accidents And Less Fatigue Among Commercial Drivers....
Replied on Mon, Sep 12, 2016 at 09:58 AM CST
What about when it was 55 and if you were doing 55.5 or 56 within the first 10 miles upon entering that state on Interstate 70 coming from the West you were given a safety award, ahhhh those were the days
Replied on Mon, Sep 12, 2016 at 12:22 PM CST
Take the time to post your facts. It can't hurt and you can say I told you so. ;-) Thanks for starting this post. Lets stick together for once!

Fact: Limiting the speed by 10% will result in trucks spending 10% more time on the roadway and increase traffic congestion by 10%.

Fact: Limiting the speed will force more trucks into the right lane making it more dangerous when entering and exiting the highway.

Fact: A congested right lane makes it difficult for passing trucks to merge safely back into the right lane. Trucks will find themselves necessarily spending more time passing creating even more congestion behind them. It often takes a minimum of 3 to 5 miles for traffic patterns to return to normal after an event like this.

Fact: Because a driver has to spend more time driving he will have less time for breaks while trying to make his deadlines, resulting in more fatigued driving.

Fact: Slowing a loaded truck by 5 to 10 mph in hilly terrain will result in a speed drop of 10 to 20 mph when climbing the following hill, creating even more congestion in mountainous terrain than is presently the case.

I have not seen the studies, but it seems to me that the slower a heavy truck travels and the longer it spends on the highway system the more damage there will be to the surface. Most areas where heavy trucks are moving slow are in bad shape because of the dwell time of the truck.

If this is truly an effort to improve safety it is missing the most important aspect of promoting safety. There should be an incentive package to motivate safe driving. If a driver is safe and has the skills to drive safe under the current laws he or she should not be penalized just because the inexperienced have not yet acquired these skills and proven themselves.

If this is all about safety, limit only those who don’t have a proven safety record. (Something like 2 years accident free??) This would ensure new drivers have 2 years’ experience before they are exempt from the speed limiter. Also the careless experienced driver with a high accident rate would have an incentive to be safer and keep his record clean. If slower speeds do actually improve safety this would be the most practical way of helping to ease congestion.

The only other way to make the highways safe at lower speeds is to lower the speed for all vehicles. Do realize, this may not be an option because of the increased congestion due to the 10% increase in travel time.

As a side note State and Federal fuel tax revenue will also take about a 10% hit with the increase fuel savings.
Replied on Mon, Sep 12, 2016 at 12:59 PM CST
Quote: "Take the time to post your facts. It can't hurt and you can say I told you so. ;-) Thanks for starting this post. Lets stick together for once! Fact: Limiting the speed by 10% will result in trucks spending 10% more time on the roadway and increase traffic congestion by 10%. Fact: Limiting the speed will force more trucks into the right lane making it more dangerous when entering and exiting the highway. Fact: A congested right lane makes it difficult for passing trucks to merge safely back into the right lane. Trucks will find themselves necessarily spending more time passing creating even more congestion behind them. It often takes a minimum of 3 to 5 miles for traffic patterns to return to normal after an event like this. Fact: Because a driver has to spend more time driving he will have less time for breaks while trying to make his deadlines, resulting in more fatigued driving. Fact: Slowing a loaded truck by 5 to 10 mph in hilly terrain will result in a speed drop of 10 to 20 mph when climbing the following hill, creating even more congestion in mountainous terrain than is presently the case. I have not seen the studies, but it seems to me that the slower a heavy truck travels and the longer it spends on the highway system the more damage there will be to the surface. Most areas where heavy trucks are moving slow are in bad shape because of the dwell time of the truck. If this is truly an effort to improve safety it is missing the most important aspect of promoting safety. There should be an incentive package to motivate safe driving. If a driver is safe and has the skills to drive safe under the current laws he or she should not be penalized just because the inexperienced have not yet acquired these skills and proven themselves. If this is all about safety, limit only those who don’t have a proven safety record. (Something like 2 years accident free??) This would ensure new drivers have 2 years’ experience before they are exempt from the speed limiter. Also the careless experienced driver with a high accident rate would have an incentive to be safer and keep his record clean. If slower speeds do actually improve safety this would be the most practical way of helping to ease congestion. The only other way to make the highways safe at lower speeds is to lower the speed for all vehicles. Do realize, this may not be an option because of the increased congestion due to the 10% increase in travel time. As a side note State and Federal fuel tax revenue will also take about a 10% hit with the increase fuel savings."

That would make a good comment to the FMCSA. Last time that we truckers had the ability to comment on the ELD issue very few of us did. If all we do is bitch and complain among ourselves and don't even comment to the FMCSA, then how the heck are they supposed to know we are opposed to the issues. I am suggesting that all truckers, company drivers, owner operators, small carriers start commenting on these issues. If we outnumber the ATA (MegaCarriers) they may actually think before they act. I doubt it but we will at least have tried peacefully before taking a stronger approach.

They give you 5000 keystrokes to state your comment. I believe yours will fit right in there.
Replied on Mon, Sep 12, 2016 at 01:13 PM CST
Everything is absolutey correct, and you got my support, except one small detail, my truck is set up to run 72 at 1550rpm and full torque. Excellent fuel economy, if I drop out of the torque range say and run 65 , I loose over 1mpg minimum and choke up hills and dam near fall in the low range so my economy goes well under 4. Who do I bill for the lost fuel and extra wear on my junker ?
Replied on Mon, Sep 12, 2016 at 01:41 PM CST
+ 1
Jason this is what I am doing over at Facebook, this comment is not just limited to we in the trucking industry, it impacts all out there. I added this to my original posting. Right now there have been over 1500 comments made regarding this, lets push this one to the max.

We truckers need the help of the motoring public as well. Imagine for a minute that all trucks out there ran at the same speed as those bigger carriers. 57-63 mph, each and every one of you most likely have been behind two of these trucks trying to pass one another going down the interstate. Imagine if you will that there will be over 2 million such trucks now running like that. This is an attack on the small trucking companies by the bigger trucking companies. The bigger trucking companies claim that we small guys have an unfair advantage, we all know that this is an outright lie. If you are tired of the big companies getting their way then here is an opportunity for you to post your grievance with the government. Who knows if enough of us tell them how much this idea sucks they just might listen for once. You will never know until you try.


Replied on Mon, Sep 12, 2016 at 05:27 PM CST
Quote: "That would make a good comment to the FMCSA. Last time that we truckers had the ability to comment on the ELD issue very few of us did. If all we do is bitch and complain among ourselves and don't even comment to the FMCSA, then how the heck are they supposed to know we are opposed to the issues. I am suggesting that all truckers, company drivers, owner operators, small carriers start commenting on these issues. If we outnumber the ATA (MegaCarriers) they may actually think before they act. I doubt it but we will at least have tried peacefully before taking a stronger approach. They give you 5000 keystrokes to state your comment. I believe yours will fit right in there."

I posted it to FMCSA about an hour before I shared it here but not sure if it is up yet.
Replied on Tue, Sep 13, 2016 at 10:24 AM CST
+ 1
So last night as we were driving to the Royals game, we got stuck behind two of the Mega-Carriers trucks that were out there drag racing on the interstate. It was quite funny to say the least and sad at the same time. I asked my nephew what he thought about this and he just chuckled and said well at least your trucks don't have to run like that. When I informed him of the current plight that we have with the FMCSA and the speed limiters, he was actually quite shocked. His wife then said nobody will be able to go anywhere, what kind of idiots do we have up there in Washington D.C. I said exactly, just imagine if tomorrow 2 million trucks instead of 200,000 trucks were now running at a top speed of 65 mph. I let them know that drivers would by and large just set the cruise and forget it, and the events that we were currently experiencing would now be a constant instead of the occasion.

This made both of them pissed, because they now realized that they would have to leave for work even earlier to arrive on time. I suggested that both of them comment on the FMCSA comment as the general motoring public and let them know exactly how this made them feel.

I have had pretty good response from others over at Facebook, we now have the general motoring public getting pissed off about this as well. This is how we need to approach this, get the general motoring public behind this. Tell you friends, family, hell tell anybody to go to the comment section and state their thoughts, for once the FMCSA is touching a topic that will also impact their lives in a negative fashion.

I realize that this may still not have any impact. Their decision has basically been bought and paid for, but when the people see that their government does not listen to even a basic common sense topic, it will cause them to question a lot more.
Replied on Tue, Sep 13, 2016 at 11:32 AM CST
I wasn't smart enough to figure out where to post comments on the FMCSA. I found an article in Transport Topics where the ATA is requesting a 30-Day Extension for Speed Limiter Comments. This article has a link that took me to the Federal Register, a Daily Journal of the United States Government. It appears that your comments are registered and posted directly on the Regulations.gov page to be reviewed by the organizations that are proposing the rule, NHTSA and FMCSA. It also gives you other ways and places to post your comements. Hope this helps
Replied on Tue, Sep 13, 2016 at 11:38 AM CST
Just a discussion in case anybody else might have the same problem on who to contact to pay for this. My route this week consist of Kansas City Missouri down to the Springfield Missouri area every night this week big deal anywhoo I loaded at 80,000 pounds going to Kansas City last night at 72 miles per hour I got 6.4 miles per gallon on the way back at 79680pds. and it's a lot easier coming back I set the cruise at 65 miles an hour not only did my truck use additional fuel it pulled considerably harder. I refueled in Springfield this morning I used an additional 11.2 gallons simply because my truck was not in the torque range and my truck struggle. My question is when the post speed limit law who do I start billing for my additional business cost? And yes this was posted to the comment section of FMCSA
Replied on Wed, Sep 14, 2016 at 07:21 AM CST
Quote: "Just a discussion in case anybody else might have the same problem on who to contact to pay for this. My route this week consist of Kansas City Missouri down to the Springfield Missouri area every night this week big deal anywhoo I loaded at 80,000 pounds going to Kansas City last night at 72 miles per hour I got 6.4 miles per gallon on the way back at 79680pds. and it's a lot easier coming back I set the cruise at 65 miles an hour not only did my truck use additional fuel it pulled considerably harder. I refueled in Springfield this morning I used an additional 11.2 gallons simply because my truck was not in the torque range and my truck struggle. My question is when the post speed limit law who do I start billing for my additional business cost? And yes this was posted to the comment section of FMCSA"

Elevation of KC, 909'
Elevation of Springfield 1299'
Mileage 167 miles

If if reading your post correctly:
Springfield to KC at 72mph, got 6.4mpg, declining 400ft, using 26.09 gallons
KC to Springfield at 65mph, climbing 400ft, used 11.2 more gallon, which would give you 4.47mpg

I have never ran that route, but it doesnt look like it would easier coming back. You gotta climb in elevation somewhere. I dont think the loss in mpg can fully be attributed to speed. You also cant just base it one round. Run it for a week at 65, then a week at 72. Gonna cost you about 15 mins each way at the slower speed.

I agree this speed limiter is gonna be a big PIA, not just in traffic congestion, but also in increased costs to all of us. But like anything else, we gotta pass it onto the customer. The strong and the smart will survive, and like it always has been, the stupid will go bankrupt and disappear. There will always be the stupid, heck that lease to own deal gets a sucker everyday. But each of us need to protect and service our customers. Having loyal customers that see that service is worth something is what will keep you in business.
Replied on Wed, Sep 14, 2016 at 08:26 AM CST
Quote: "Elevation of KC, 909' Elevation of Springfield 1299' Mileage 167 miles If if reading your post correctly: Springfield to KC at 72mph, got 6.4mpg, declining 400ft, using 26.09 gallons KC to Springfield at 65mph, climbing 400ft, used 11.2 more gallon, which would give you 4.47mpg I have never ran that route, but it doesnt look like it would easier coming back. You gotta climb in elevation somewhere. I dont think the loss in mpg can fully be attributed to speed. You also cant just base it one round. Run it for a week at 65, then a week at 72. Gonna cost you about 15 mins each way at the slower speed. I agree this speed limiter is gonna be a big PIA, not just in traffic congestion, but also in increased costs to all of us. But like anything else, we gotta pass it onto the customer. The strong and the smart will survive, and like it always has been, the stupid will go bankrupt and disappear. There will always be the stupid, heck that lease to own deal gets a sucker everyday. But each of us need to protect and service our customers. Having loyal customers that see that service is worth something is what will keep you in business."

He runs that route every week, and was just experimenting to see what the cost difference would be. Customer loyalty is a thing of the past, they will jump on the first carrier or broker that undercuts you, regardless of the superior service. Then they will be calling you whining in about six months about how the new guy does not measure up. They even have the audacity to ask you to come back cheaper then you were doing it for before. My motto is here today gone tomorrow, I am loyal to those that are loyal to me. Basically as long as your check is still good for the amount we agreed on, then you will get the service that we agreed to provide.

Before the FMCSA took over for the ICC, we all still had a little protection as far as a standardized rate structure. Now we have an organization that just wants to keep on pressing more and more rules and regulations in the name of safety. It will not matter how well you service your customer in the future, when the regulations make it near to impossible to service them with a smaller operation, your customer will choose to use a larger carrier that can provide the service they desire at a lower price to boot.

Throw into the mix, individuals that just finished the lease op program and that believe they will make it on $1.25 per mile, this is why we are where we are. If things continue like they are going then all of us Independent Carriers will just become glorified lease operators running Power Only with a Mega-Carrier or Mega-Broker.
Replied on Mon, Sep 19, 2016 at 08:13 AM CST
We are up to 1877 comments made. Keep up the fight.
Replied on Mon, Sep 19, 2016 at 05:07 PM CST
Quote: "We are up to 1877 comments made. Keep up the fight."

I’ve already commented to the FMCSA but here are some thoughts about leveling the playing field that I failed to mention in my comment.

In a free enterprise system this would be very easy to accomplish. All that any Mega Carrier out there that wants a level playing field has to do is raise the speed limiters in their trucks and it’s level.

Now if you truly want a level playing field and you want to use a socialistic approach it gets much more complicated.

1. You will need to lower the speed limit because not all trucks want to drive the speed limit. Some may not even be capable of running the speed limit.
2. If you truly are in favor or a level playing field you will need to attach a mandate to make it possible for the small carrier to buy fuel at the same price as the Megas which is 5 cents over cost at Flying J, Pilot, Petro, TA, etc. That’s about 30 cents a gallon under the pump price many of us pay. That’s a $5000 a year unfair advantage.
3. You will also need to make it possible for the independents to purchase insurance for the same as it costs for the Megas because we don’t have the volume of trucks to negotiating those rates.
4. We should get the same discounts on new trucks as those buying 500 at time.
5. The same goes for new trailers, tires, filters, oil, permits, license, etc.

But that’s SOCIALISM. I’m not in favor of a socialist setup but if the goal is to “level the playing field” let’s at least be fair about it.

Our law makers have no idea what this one little Speed Limiter law will cost them in the USA. There is a reason the majority of states have raised their speed limits. They know it takes more power and more fuel the faster you run and they need the fuel tax money. Limiting the truck speed by just 5 or 6 mph will slow all traffic and they will lose about 10% of their fuel tax revenue. The increased congestion on the roadways will cause more accidents and place a greater demand on law enforcement and our court system. Rest areas and parking will also take a hit along with our roadways. The list goes on.

The ATA only represents about 10% of the industry. So let your state law makers know how this law is going to affect their ability to balance thier state's budget.