Comment to the FMCSA concerning the Canadian Trucking Alliance's endorsement of electronic on-board

December 8, 2004 The Honorable Annette M. Sandberg Administrator Federal Motor Carrier Safety Administration 400 Seventh Street S.W. Nassif Building, Room PL-401 Washington, D.C. 20590-0001 Electronic On-Board Recorders for Hours-of-Service Compliance Advance Notice of Proposed Rulemaking Docket No. FMCSA-2004-18940, FMCSA-2004-17286 Dear Ms. Sandberg: On November 26, 2004, the Canadian Trucking Alliance (CTA) called for the mandatory use of electronic onboard recorders (EOBRs) to monitor compliance with Canadian hours-of-service rules. CTA is a federation of the seven provincial trucking associations. Its statement and accompanying press release are attached. According to CEO David Bradley, the “days of the paper log book should be numbered.” He stated that EOBR technology is “imperative from a safety point of view, which of course is paramount, but also in terms of providing responsible carriers with a level playing field with competitors who might otherwise choose to bend or break the rules to increase driving time.” CTA called on federal and provincial governments to work with the trucking industry to make this a reality. The Institute applauds CTA’s progressive stance and submits this as further evidence that an EOBR mandate in the United States is long overdue and will, in fact, be embraced by many segments of the North American trucking industry. We urge the Federal Motor Carrier Safety Administration to bring the ...