SD Cattlemen: Comment on ELD regs by March 8
A funding package passed by Congress in early February includes a continued ELD exemption for livestock haulers through September 30, 2019. As we’ve written about previously, the ELD mandate, coupled with existing hours of service (HOS) regulations, pose significant challenges for the livestock industry.
Current rules limit drive time to 11 hours and limit on-duty hours to 14. A petition filed by NCBA and others in the livestock industry with the US DOT last October requests that livestock haulers be granted approval to drive up to 15 hours with a 16-hour on-duty period, following a 10-hour consecutive rest period. Any livestock hauler wishing to operate under the extended drive time would be required to complete pre-trip planning and increased fatigue-management training.
Comments on the livestock industry petition are due Friday, March 8. To comment, visit: https://www.regulations.gov/document?D=FMCSA-2018-0334-0002. Click “comment now” and type in your comments. 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.
In your comments, be sure to identify 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. Key points you may want to address in your comments include:
How far your livestock must travel from the ranch to the market and from the market to their next destination.
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.
SDCA will file comments on behalf of our members as well. For more information, visit NCBA’s website at http://www.beefusa.org.
–South Dakota Cattlemen’s Association
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