moose
Veteran Expediter
The Expansion of the Q-Data appeal process to accommodate the enforcement of HOS via an EOBR mandate.
This letter is to be addressed To Anne Ferro, the FMCSA and other Gov. Officials at the upcoming MATS.
Thank you so very much for making this forum available,
Everyone following Miss Ferro sees that this is not done by accident just to satisfy a court challenge.
The FMCSA have reached out for drivers input for some time now.
The FMCSA is a regular visited on the XM trucking radio show.
It was actually a remark made at the Dave Nemo show by the agency 2 weeks ago, that made me wrights this letter, and provide a solution.
In that show, an administrator said they recognized the needs for a rule that can apply for individual fatigue operation needs, but are forced to a one size fits all rule.
This letter will provide the agency with the tool they need to allow the FMCSA an individual focus while still hold to the one size fits all HOS rules.
And May we say it is about time the administrator will realize who are its customers, and who will be the end user of your product.
It is about time you have a listening session in places that provide for a trucks parking. We can only hope that in near future you will have a same sessions regarding HOS, drivers health, sleep apnea, and other issues, in places where truckers park.
You do so, and I will be there to provide solutions for those issues.
Let’s see what happens when you have a meeting in places that do not provide for truck parking.
Let’s see what happens just last week, when you had a meeting in WDC regarding crash accountability. You had the ATA there. As a result, the person representing the ATA in that meeting told XM world, they attended that meeting to make sure the agency hear the voice of the trucking industry.
Miss Ferro, let me make it very clear, The ATA does not represent the trucking industry. Yet the Agency relay on input provided by those self interests groups in the rule making process.
Industry records speak of 92% of all trucking carriers, operating a fleet of 20 trucks or less. Many of which have already endures the voluntary, and now illegal, used of E-Logs. Drivers harassment virtually dose not exists for small carriers. Using EOBR’s to harass drivers is only the problem in large fleets. There’s a good rezone for that. Small fleets know their drivers, the supply chain knows the drivers, they care about them and will work with the carrier to accommodate safe operation of a truck.
You want to find a solution, you speak with truckers, not self interest groups, not safety advocates, not no one that does not share the roads with us, and you defiantly do not form an advisory comity base sully on individuals that are poised to make a buck, or whole lotta money, as a results of a future regulations. You speak to those guys, or an association that spends over 352 million dollar a quarter in lobbying WDC, and you will continue to be fed with the same wrong and incorrect data.
Thank you very much for today opportunity, and we can only hope you will repeat this practice in the future.
The whole point of today gathering is to find a way to address the court concern regarding drivers harassment, so the agency can come up with a long lasting EOBR rule that can not only withstand a future court action, but can also work in the real world for professional drivers.
This letter will do just that.
It WILL protect the agency from the likelihood of a future court challenge.
It will create a system where drivers can endorse Electronic logs,
& more importantly, it will build the supply chain working environment in which truckers can continue to stribe, make a buck, and enjoy our industry, while still be in full compliance with HOS regulation. This letter will challenge the administration to say out loud that they are indeed looking for safety improvements, via enforcements of the HOS.
Before I am continuing reading this letter, we would like the administrator to say it out loud in front of everyone in the room, that you are committed to that statement. That you are indeed looking for a tool that will allow you an enforcement of HOS via mandatory electronic logs. We can’t stress this enough, we need your commitment to make this happens, and we need this upfront.
.
Thank you so very much.
And without further delay, let me please introduce my letter.
This letter called:
“The Expansion of the Q-Data appeal process to accommodate for the enforcement of HOS via an EOBR mandate.”
We all know what the Q-Data appeal process is. It is a place for drivers to challenge a violation. The Q-Data appeal process is not perfect. Not at all. We goanna make it better. Via the Q-Data drivers can file an appeal, and then the agency goes back to the officer that gave the violation on the side of the road asking the LEO if that violation still needs to be filed. Basically asking the cat to watch the milk bowl. This system is all we got, for now, it is by far not perfect, but with some hard work we can make it better. So much better that I do believe we can use that tool to allow for an industry wide electronic log mandate. All we need to do is allow the system to collect a driver’s input data, once an HOS violation occur.
Here is how it will work.
Let us please take a look at the DAC report system. Under that system, the DOT, via a privet company, is collecting carriers input for rezones of driver termination. DAC only has 6 predetermined options for carriers to choose from. And the carrier does not need to provide detailed records. It has, and still is affecting the ability of drivers to find work. The DAC report is by far the largest stick carriers have to harass drivers. When we go away with the DAC report, and instead incorporate such report into the Q-Data system, Carriers will no longer have that option of harassing drivers. What carriers will have, under Q-Data is the accountability for provide supporting documents of an entry, and the option of going through an appeal process.
Frankly once the Q-data system is up and running, there’s no rezone anymore for a parallel DAC report. Especially once the agency determined under the BASIC that driver’s turnover indeed effect road safety.
Drivers that are instructed to move their rigs, while in violation of HOS, drivers that will be forced to drive to do their jobs, meet impassible schedules, or make it back home, needs to be allow to report this happening. This is very important. As this will allow drivers to stay in business over time, and will hold the supply chain accountable for their actions.
In places where trucks can stop, In places that provide for a truck parking safe heavens, in places that are stuffed to accommodate trucks when those trucks are allowed to be moved, in those places, and only in those place, log book moving violation do not occur.
From that point on, the FMCSA will have data showing the location, and type of violation, and can use such data to prevent violations from repeating in those locations. If choose to, the agency can provide for an intervention fresh hold, just like in the SMS system, determining percentage wise places that abused drivers, and finely doing something about it.
As long as the FMCSA will not take an active role, to force the supply chain to accommodate for a safe truck operation, the expected EOBR rule will rightly be challenge at court by professional drivers.
Problem is, the DOT dose not imposed regulations over shippers/receivers/carriers/brokers/local municipality’s/county’s/and states… this is correct, up until we consider the federal hwy funding system.
If this letter will be accepted, we will see places that do business with trucks, working together with carriers, and local jurisdictions to provide for truck parking. We will see shippers and receivers staffed up and open long hours to accommodate for truck operation, and we will see ample opportunity for local and regional operations. It will be newfound lands for small business, where we can compete with the big boys. Industry records show that 92% of our industry is made out of small trucking operations, 20 trucks or less. These new regulations will not change that.
However, on the local delivery level, we see most of the freight being moved in town by large carriers. This is due to a decade of regulations placing trucks safe heaven out of reach for small business. Ignoring trucker’s voice and allowing for shippers input.
A short look at the new Clean Energy LNG fueling stations, that are being build today all across the country by the Obama administration, is all we need to prove just that.
Miss Ferro, your job is to improve safety on our hwy’s and streets. The Gov. has no place managing free markets. If all, Gov. Job is to stay out of the way of business, and to provide for same business opportunity, for small business, which is the hardcore of our economy.
This new regulations will do just that, it will place the burden of providing safe truck operations on the shoulder of businesses that pay to move freight, and at the shoulders of places that consume truck operations. Once we are protected from the supply chain abuse, we can accommodate for E-Logs.
Miss. Ferro, this is the choice the administrations need to make, you have a big stick, and you can use it at will. You have the authority to hold carriers that in the wrong, you have the authority to hold brokers responsible for their actions, you have the tools to tell shippers and receivers they need to provide for truck parking, and you have the tools to force city’s counties and states to build safe haven that will accommodate for the trucks traffic going through and doing business with them.
You can do all of that, or you can leave the poor o’l trucker holding the stick, in which case we will meet once again in court.
Every professional trucker out here today will say the same thing. Carriers and brokers are in business to abused truckers time, they do so by abusing truckers, one at a time, and by spinning the revolving door. You are the only one that in a position to stop this abused.
Not excepting this letter will show everyone that you do not stands for promises you made today, and by far it will show that you in business to promote big money over truckers back.
The golden egg laying cash cow drivers stop here, if you so wisely choose to.
Driver harassment will only stop, when we vacant the financial incentive for carriers to harass drivers.
Or you can choose a peel that treats the symptoms,
Your choice.
This letter is to be addressed To Anne Ferro, the FMCSA and other Gov. Officials at the upcoming MATS.
Thank you so very much for making this forum available,
Everyone following Miss Ferro sees that this is not done by accident just to satisfy a court challenge.
The FMCSA have reached out for drivers input for some time now.
The FMCSA is a regular visited on the XM trucking radio show.
It was actually a remark made at the Dave Nemo show by the agency 2 weeks ago, that made me wrights this letter, and provide a solution.
In that show, an administrator said they recognized the needs for a rule that can apply for individual fatigue operation needs, but are forced to a one size fits all rule.
This letter will provide the agency with the tool they need to allow the FMCSA an individual focus while still hold to the one size fits all HOS rules.
And May we say it is about time the administrator will realize who are its customers, and who will be the end user of your product.
It is about time you have a listening session in places that provide for a trucks parking. We can only hope that in near future you will have a same sessions regarding HOS, drivers health, sleep apnea, and other issues, in places where truckers park.
You do so, and I will be there to provide solutions for those issues.
Let’s see what happens when you have a meeting in places that do not provide for truck parking.
Let’s see what happens just last week, when you had a meeting in WDC regarding crash accountability. You had the ATA there. As a result, the person representing the ATA in that meeting told XM world, they attended that meeting to make sure the agency hear the voice of the trucking industry.
Miss Ferro, let me make it very clear, The ATA does not represent the trucking industry. Yet the Agency relay on input provided by those self interests groups in the rule making process.
Industry records speak of 92% of all trucking carriers, operating a fleet of 20 trucks or less. Many of which have already endures the voluntary, and now illegal, used of E-Logs. Drivers harassment virtually dose not exists for small carriers. Using EOBR’s to harass drivers is only the problem in large fleets. There’s a good rezone for that. Small fleets know their drivers, the supply chain knows the drivers, they care about them and will work with the carrier to accommodate safe operation of a truck.
You want to find a solution, you speak with truckers, not self interest groups, not safety advocates, not no one that does not share the roads with us, and you defiantly do not form an advisory comity base sully on individuals that are poised to make a buck, or whole lotta money, as a results of a future regulations. You speak to those guys, or an association that spends over 352 million dollar a quarter in lobbying WDC, and you will continue to be fed with the same wrong and incorrect data.
Thank you very much for today opportunity, and we can only hope you will repeat this practice in the future.
The whole point of today gathering is to find a way to address the court concern regarding drivers harassment, so the agency can come up with a long lasting EOBR rule that can not only withstand a future court action, but can also work in the real world for professional drivers.
This letter will do just that.
It WILL protect the agency from the likelihood of a future court challenge.
It will create a system where drivers can endorse Electronic logs,
& more importantly, it will build the supply chain working environment in which truckers can continue to stribe, make a buck, and enjoy our industry, while still be in full compliance with HOS regulation. This letter will challenge the administration to say out loud that they are indeed looking for safety improvements, via enforcements of the HOS.
Before I am continuing reading this letter, we would like the administrator to say it out loud in front of everyone in the room, that you are committed to that statement. That you are indeed looking for a tool that will allow you an enforcement of HOS via mandatory electronic logs. We can’t stress this enough, we need your commitment to make this happens, and we need this upfront.
.
Thank you so very much.
And without further delay, let me please introduce my letter.
This letter called:
“The Expansion of the Q-Data appeal process to accommodate for the enforcement of HOS via an EOBR mandate.”
We all know what the Q-Data appeal process is. It is a place for drivers to challenge a violation. The Q-Data appeal process is not perfect. Not at all. We goanna make it better. Via the Q-Data drivers can file an appeal, and then the agency goes back to the officer that gave the violation on the side of the road asking the LEO if that violation still needs to be filed. Basically asking the cat to watch the milk bowl. This system is all we got, for now, it is by far not perfect, but with some hard work we can make it better. So much better that I do believe we can use that tool to allow for an industry wide electronic log mandate. All we need to do is allow the system to collect a driver’s input data, once an HOS violation occur.
Here is how it will work.
Let us please take a look at the DAC report system. Under that system, the DOT, via a privet company, is collecting carriers input for rezones of driver termination. DAC only has 6 predetermined options for carriers to choose from. And the carrier does not need to provide detailed records. It has, and still is affecting the ability of drivers to find work. The DAC report is by far the largest stick carriers have to harass drivers. When we go away with the DAC report, and instead incorporate such report into the Q-Data system, Carriers will no longer have that option of harassing drivers. What carriers will have, under Q-Data is the accountability for provide supporting documents of an entry, and the option of going through an appeal process.
Frankly once the Q-data system is up and running, there’s no rezone anymore for a parallel DAC report. Especially once the agency determined under the BASIC that driver’s turnover indeed effect road safety.
Drivers that are instructed to move their rigs, while in violation of HOS, drivers that will be forced to drive to do their jobs, meet impassible schedules, or make it back home, needs to be allow to report this happening. This is very important. As this will allow drivers to stay in business over time, and will hold the supply chain accountable for their actions.
In places where trucks can stop, In places that provide for a truck parking safe heavens, in places that are stuffed to accommodate trucks when those trucks are allowed to be moved, in those places, and only in those place, log book moving violation do not occur.
From that point on, the FMCSA will have data showing the location, and type of violation, and can use such data to prevent violations from repeating in those locations. If choose to, the agency can provide for an intervention fresh hold, just like in the SMS system, determining percentage wise places that abused drivers, and finely doing something about it.
As long as the FMCSA will not take an active role, to force the supply chain to accommodate for a safe truck operation, the expected EOBR rule will rightly be challenge at court by professional drivers.
Problem is, the DOT dose not imposed regulations over shippers/receivers/carriers/brokers/local municipality’s/county’s/and states… this is correct, up until we consider the federal hwy funding system.
If this letter will be accepted, we will see places that do business with trucks, working together with carriers, and local jurisdictions to provide for truck parking. We will see shippers and receivers staffed up and open long hours to accommodate for truck operation, and we will see ample opportunity for local and regional operations. It will be newfound lands for small business, where we can compete with the big boys. Industry records show that 92% of our industry is made out of small trucking operations, 20 trucks or less. These new regulations will not change that.
However, on the local delivery level, we see most of the freight being moved in town by large carriers. This is due to a decade of regulations placing trucks safe heaven out of reach for small business. Ignoring trucker’s voice and allowing for shippers input.
A short look at the new Clean Energy LNG fueling stations, that are being build today all across the country by the Obama administration, is all we need to prove just that.
Miss Ferro, your job is to improve safety on our hwy’s and streets. The Gov. has no place managing free markets. If all, Gov. Job is to stay out of the way of business, and to provide for same business opportunity, for small business, which is the hardcore of our economy.
This new regulations will do just that, it will place the burden of providing safe truck operations on the shoulder of businesses that pay to move freight, and at the shoulders of places that consume truck operations. Once we are protected from the supply chain abuse, we can accommodate for E-Logs.
Miss. Ferro, this is the choice the administrations need to make, you have a big stick, and you can use it at will. You have the authority to hold carriers that in the wrong, you have the authority to hold brokers responsible for their actions, you have the tools to tell shippers and receivers they need to provide for truck parking, and you have the tools to force city’s counties and states to build safe haven that will accommodate for the trucks traffic going through and doing business with them.
You can do all of that, or you can leave the poor o’l trucker holding the stick, in which case we will meet once again in court.
Every professional trucker out here today will say the same thing. Carriers and brokers are in business to abused truckers time, they do so by abusing truckers, one at a time, and by spinning the revolving door. You are the only one that in a position to stop this abused.
Not excepting this letter will show everyone that you do not stands for promises you made today, and by far it will show that you in business to promote big money over truckers back.
The golden egg laying cash cow drivers stop here, if you so wisely choose to.
Driver harassment will only stop, when we vacant the financial incentive for carriers to harass drivers.
Or you can choose a peel that treats the symptoms,
Your choice.
