IST and RSA Comments on Pronto.Ai Request for Exemption from HOS Rules

Comment from the Institute for Safer Trucking and Road Safe America

On

Pronto.ai, Inc.’s Application for Exemption from Hours of Services Rules for Motor Carriers Using Certain Advanced Driver Assistance Systems

The Institute for Safer Trucking (IST) and Road Safe America (RSA) submit these comments in response to the Federal Motor Carrier Safety Administration’s (FMCSA) request for comments on Pronto.ai, Inc’s application for exemption from 49 CFR 395.3(a)(2) and 395.3(a)(3) for Motor Carriers Using Certain Advanced Driver Assistance Systems.

While driver assistance technologies, including automatic emergency braking, adaptive cruise control, and driver facing cameras, all offer the potential to reduce truck crashes, several questions must be answered to determine if this proposal will make trucking safer. Even after these questions are answered, performing a pilot program on the proposed exemption would be a more prudent approach to evaluate safety performance and protect the driving public.

Questions

1) Is there a demand for an additional two hours of driving time and one hour of working time?

a. Does the petitioner have evidence to demonstrate that these two exemptions are being requested by motor carriers and truck drivers?

b. If yes, do the recently released changes to the Hours of Service rules change these findings?  With the added flexibility, there may not be a need for those additional hours.

2) What are the safety implications of increasing driving time by two hours?

3) What are the safety implications of increasing the working time from 14 hours to 15 hours?

a. Will this change have any effect on a truck driver’s 24-hour sleep cycle?

b. Does a 15-hour workday increase fatigue in the short-term and/or cumulatively?  

4) Does the usage of driver assistance technologies impact driver behavior?

a. If so, does it lead to an over-reliance on assistance technologies?

b. Does the usage of driver assistance technologies impact driver focus and/or adversely impact driver fatigue?

Pilot Program

Rather than granting an exemption, the agency should explore performing a pilot program to better help the public understand the implications of Pronto.ai, Inc.’s proposal. Through a pilot, FMCSA will be able to:

-Set a specified scope,

-Define the operating environment,

-Collect data throughout the program, and

-Establish reporting requirements for safety and operational performance.

Conclusion

With truck crash fatalities up 46.5 percent from 2009 and expected to increase one percent from 2018 to 2019, we must act urgently and collaboratively to identify the solutions that can make trucking safer. While this proposal certainly contains promising components through the use of driver assistance technologies, we urge the agency to provide the public with answers to our important questions and perform a pilot program instead of granting a five-year exemption.