09 Nov KARA joins coalition supporting FMCSA pilot program to allow drivers 18-20 years old to operate commercial motor vehicles in interstate commerce
The U.S. Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) is proposing to create a pilot program to allow truck drivers aged 18-20 to drive across state lines. This is an effort to make federal law more consistent with state laws. Currently, in 49 states, the minimum age for intrastate truck operation is 18, while the federal minimum is 21 for interstate truck operation.
Required Training for Pilot Program Drivers: FMCSA proposes to allow 18- to 20-year-old CDL holders to operate CMVs in interstate commerce while taking part in a 120-hour probationary period and a subsequent 280-hour probationary period under an apprenticeship program established by an employer, as introduced in the DRIVE-Safe Act. The 120-hour probationary period would include 120 hours of on-duty time, with at least 80 hours of driving time in a CMV. In order to complete the 120-hour probationary period, the employer must make sure the younger driver is competent in each of the following areas: Interstate, city traffic, rural 2-lane, and evening driving; safety awareness; speed and space management; lane control; mirror scanning; right and left turns; and logging and complying with rules relating to hours of service. The 280-hour probationary period would include 280 hours of on-duty time, with at least 160 hours of driving time in a CMV. In order to complete the 280-hour probationary period, an employer must ensure that the younger driver is competent in each of the following areas: Backing and maneuvering in close quarters; pre-trip inspections; fueling procedures; weighing loads, weight distribution, and sliding tandems; coupling and uncoupling procedures; and trip planning, truck routes, map reading, navigation, and permits. Driver training and apprenticeship programs have been proven to provide valuable driving experience; to reduce recklessness; to help prepare the driver for real-life driving situations that he or she may experience on the road; and identify and correct poor driving behaviors. Through this probationary program, the Agency believes these drivers will obtain the necessary experience skills to operate safety in interstate commerce. Forty-eight States and the District of Columbia already allow 18- to 20-year-old CDL holders to operate CMVs in intrastate commerce.
Required Safety Technology for Pilot Program Drivers: Vehicle safety technology continues to increase and FMCSA recognizes the value of these systems. These tools can help prevent, or significantly reduce the number and severity of, crashes on our nation’s highways. FMCSA is proposing to require the following vehicle safety technologies on the CMVs operated by the study group drivers: Active-braking collision mitigation systems; forward facing video event recorders; and automatic or automatic-manual transmissions; and speed limiters set to 65 miles per hour. FMCSA believes that requiring these technologies on the CMVs operated by younger drivers will assist in preventing crashes. As an added benefit, FMCSA will be able to analyze the data received from these technologies to determine if one safety feature is more beneficial to safety.
Submitted Electronically
November 9, 2020
Docket Operations
Federal Motor Carrier Administration
U.S. Department of Transportation
West Building Ground Floor
Room W12-140
1200 New Jersey Ave., SE
Washington, D.C., 20590-0001
RE: Docket No. FMCSA-2018-0346
Dear Acting Administrator Deck:
The undersigned organizations commend the Federal Motor Carrier Safety Administration (FMCSA) for proposing a pilot program to allow drivers 18, 19 and 20 years old to operate commercial motor vehicles (CMVs) in interstate commerce, and strongly support the agency implementing such a pilot at its earliest opportunity.
The farmers, ranchers, food and beverage manufacturers, processors, package suppliers, farm supply dealers and agricultural product marketers that make up our memberships believe the pilot program has the potential to remove a significant impediment to driver eligibility and the efficient movement of goods in interstate commerce – the inconsistent minimum age rules for the operation of CMVs for drivers operating in interstate versus intrastate commerce. Currently, in 49 states, the minimum age for intrastate CMV operation is 18 (or under), while the federal minimum is 21 for interstate CMV operation.
As you know, the proposed pilot program closely resembles the DRIVE Safe Act (H.R.1374/S.569) legislation that enjoys large bipartisan support in both the House and Senate. This legislation has been driven in part by the driver shortage confronting our nation. It is estimated that the commercial trucking sector currently has an estimated shortage of 60,000 drivers, a number that is expected to increase to 1.1 million drivers over the next decade. This shortage is attributable to growing demand for trucking service and an aging workforce, issues that the agricultural sector is facing as well. This shortage inevitably will lead to higher transportation costs, resulting in increased prices for consumers of agricultural and food products domestically, while making U.S. agricultural exports less competitive.
While 49 states already allow Commercial Driver’s License (CDL) holders 18, 19 and 20 years old to operate CMVs in intrastate commerce, we strongly support the opportunity to further demonstrate that training and driver development are more critical than merely making eligibility determinations based upon a driver’s age. It is important to note that the current federal age threshold raises a significant barrier to entry for those interested in operating CMVs. It is often the case that many individuals already have chosen a profession or career path prior to turning 21. This understandably limits the potential driver pool, exacerbating an already significant driver shortage that has become more acutely evident and problematic during the Covid-19 pandemic. This pilot program is crucial in demonstrating that a driver can just as safely operate a CMV for an interstate movement from Oakland, CA, to Reno, NV as they can from San Diego to Sacramento, CA.
In addition, our organizations are pleased that FMCSA is considering undertaking a pilot program with broad driver eligibility to ensure a statistically significant sample is collected that we believe will demonstrate that CMV drivers aged 18, 19 and 20 can operate CMVs safely in interstate commerce. While we support the previous pilot program – the Under 21 Military CDL Pilot Program – we believe the newly proposed pilot with its broader driver eligibility will provide a more robust sample size that will enable FMSCA to draw conclusions about the safety data gathered.
In conclusion, we concur with FMCSA’s proposed minimum pilot program requirements for drivers aged 18-20, such as the apprenticeship program and driver education. And we agree that FMCSA should permit 19- and 20-year-old commercial drivers who have operated CMVs in intrastate commerce for a minimum of one year and driven 25,000 miles to participate in the younger driver CDL pilot program, given their requisite experience to operate safely.
Thank you for your consideration of our comments. The proposed pilot program has the potential to foster a well-trained pool of safe younger drivers to help our industries and others contribute to serve domestic and global consumers. We would be pleased to respond to any questions you may have.
Sincerely,
Agricultural and Food Transporters Conference
Agricultural Retailers Association
Agriculture Teachers Association of Texas
American Beverage Association
American Forest and Paper Association
American Frozen Food Institute
American Honey Producers Association
Catfish Farmers of Arkansas
Florida Tropical Fish Farms Association
Grain and Feed Association of Illinois
Hardwood Federation
Kansas Grain and Feed Association
Kansas Agribusiness Retailers Association
Montana Agricultural Business Association
Montana Grain Elevator Association
National Aquaculture Association
National Council of Farmer Cooperatives
National Grain and Feed Association
National Grange
North American Millers’ Association
North Dakota Grain Dealers Association
Ohio AgriBusiness Association
Renew Kansas Biofuels Association
Specialty Soya & Grains Alliance
Texas Agricultural Cooperative Council
Texas Forestry Association
Texas Grain and Feed Association
Texas Logging Council
The Texas Cotton Association
United Fresh Produce Association
Wisconsin Agri-Business Association
Wisconsin Paper Council