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NLA Submits Comments to FMCSA on Proposed Hours of Service Changes

Monday, October 21, 2019   (1 Comments)
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On behalf of its members, the National Limousine Association submitted the following comments to the FMCSA regarding proposed changes to Hours of Service.


October 21, 2019


Mr. Raymond P. Martinez


Federal Motor Carrier Safety Administration

U.S. Department of Transportation

1200 New Jersey Avenue SE, West Building

Washington, DC 20590–0001


RE: Docket ID FMCSA–2018–0248


Dear Administrator Martinez:


                The National Limousine Association (NLA) supports the Federal Motor Carrier Safety Administration (FMCSA) Hours of Service of Drivers (HOS) proposal to revise rules for commercial drivers to provide greater flexibility for drivers without adversely affecting safety. We are providing comments here to address the specific needs of passenger carrying operations as they relate to changes to HOS rules.

                As a matter of principle, NLA urges FMCSA to properly account for passenger carrying operations when considering changes to HOS rules. The passenger carrying industry shares many of the same challenges with the HOS rules as the property carrying industry. Just as Electronic Logging Device (ELD) requirements apply to both property and passenger motor carrier operations in the same way, any changes to HOS rules should fully consider both types of carriers in finalizing the HOS rules.

                NLA supports increasing the number of drivers able to take advantage of the short-haul exception. The existing requirement does not allow drivers using the short haul exception to be on duty more than 12 hours. The proposed changes would extend the maximum duty period under the short-haul exception from 12 hours to 14 hours. NLA believes that extending the maximum duty period to 14 hours more closely harmonizes the short-haul exception with passenger carrier hours of service and the 15-hour duty period.

                For the same reasons, NLA supports the extension of the maximum distance for short-haul operations from a 100 to a 150 air-mile radius. NLA believes this extension will give passenger carriers equal treatment as property carriers in terms of the flexibility granted under the short-haul exception.

                NLA supports changes to the existing adverse driving conditions requirements to promote flexibility and use of the adverse driving provision. The existing requirements related to adverse driving conditions, which do not currently extend the maximum “driving window,” are not flexible enough. The proposed changes would allow property- and passenger-carrying drivers alike to use adverse driving conditions provisions to extend the maximum “driving windows.”

                NLA believes FMCSA must modify the definition of “adverse driving condition.” Examples of adverse driving conditions include: unexpected road detours, severe weather impacting visibility or traffic passability, extreme traffic congestion without access to alternative routes such as while on a toll road, sudden insect swarms, and migrating or thruway blocking farm animals. As such, NLA respectfully requests that FMCSA slightly modify the definition of “adverse driving condition” in 49 CFR 395.2 by adding the phrase “unusual road and traffic conditions, including crash situations that necessitate a traffic detour …”

                With regard to the 30-minute rest break, which does not apply to passenger-carrying drivers, NLA believes that passenger-carrying drivers are able to get enough rest without a mandatory 30-minute break. Drivers need a national, uniform system of HOS rules to govern breaks in a manner similar to other traffic safety regulations.

                Finally, NLA would comment that FMCSA should consider reviewing Electronic Logging Device (ELD) records to better understand driver usage of the short-haul exemption in addition to the adverse driving conditions provisions. ELD records could also assist the agency in determining any difference between the practical ramifications to property- and passenger-carrying drivers of the proposed changes.

                Thank you for your consideration of these comments.


Respectfully submitted,



Gary Buffo

NLA President


Blue Bird Global Chauffeured Transportation says...
Posted Thursday, November 7, 2019
I totally agree with the NLA on these measures. This will help us give are clients a better experience and lower prices.

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