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Dear FMCSA …

Yesterday, I submitted my comments to the FMCSA regarding speed limiters.

Most of what I wrote first appeared in blogs on our website, or on the air as comment line responses, or as part of our Friday Rants series. So, essentially, I am saying nothing I haven’t said publicly before.

Because of the importance of this issue, I wanted to share what I wrote with all of you. And I hope you will join me in offering some advice to FMCSA regarding this proposal.

I am writing in opposition to the FMCSA’s proposed rule to require speed limiters in trucks.

I have long researched this. I have talked with members of the Transportation Research Board, looked over their peer-reviewed work, looked into accident statistics, and so on.

I have several points to make:

First, the bulk of the research, conducted from the birth of the Interstate highway system to recent times, has long concluded that the closer all traffic is to the same speed, the safer it is. The so-called 85th percentile rule is used across the country to set speed limits. And in terms of safety, it works. Why, then, are we considering doing something that is the exact opposite of more than a half-century of national highway policy and research? Professor Steven Johnson, Ph.D., is a researcher and professor at the Mack-Blackwell Transportation Institute at the University of Arkansas. He once said that if he were in control, people would get a ticket for 1 mph over the speed limit – or 1 mph under. Both, he said, are equally dangerous in terms of causing accidents.

Second, lowering the speed of trucks will not reduce the impact of rear-end collisions in which cars hit trucks – which happens far more often that trucks hitting cars. Limiters actually increase the force of those collisions. That is basic physics: At the same speed, the collision can’t occur; with a 1 mph difference, the impact would be minor; the larger the difference in speed, the greater the force of the impact. If the goal is to reduce the impact of crashes, then again we are doing the opposite of what we know works.

Third, most accidents, including most fatal accidents, occur in places where the speed limit is below any of the proposed speeds listed in the regulation. How does the proposal address those? It does not. A limiter set at 65 miles per hour does not affect a traffic interaction occurring at 55 or 45 or even 35 mph. In fact …

Fourth, a survey of truckers who are employed by major motor carriers who use speed limiters show that they are incentivized to drive at their trucks’ limit, even when conditions call for a lower speed. Speed limiters in that case are again increasing the likelihood of an accident in construction zones, lower-speed limit highways, and on ordinary streets. We should not do something that incentivizes less safe behavior.

Fifth, if a truck hits you at 70 miles per hour, yes, a fatality is likely. It is also likely at 60 mph, 55 mph or 50 mph. It is an 80,000-0pound GVWR vehicle. You cannot reduce speed enough to truly reduce the level of impact to a non-fatal level in those cases in which the truck is causing the impact. Do we want to rely on this fantasy (of reducing force of impact enough to prevent fatality), or is it better to prevent the accident from occurring in the first place? I would contend that no accident is always safer than any accident.

Sixth, trucks – as shown by statistics derived from the accident reports used in federal research – are not responsible for most accidents involving a truck. In fact, they are not responsible for roughly 75 percent. Again, this is information derived from the same source as federal statistics, the ones the DOT relies on. We are not addressing the real problem here.

Seventh, we’ve already seen with existing speed-limited trucks how just two can tie up an entire highway, creating congestion where none need occur. Truckers themselves call them “turtle races” or “elephant races.” That congestion creates the perfect conditions for an accident to occur. This is already a problem on our roads with the number of limited trucks now. Why would we want to take something known to cause congestion and accidents, and amplify it?

Eighth, Congress – in ending the national 55 mph speed limit – clearly intended that states should control speed limits, that they have the knowledge to set the speed limit at the right level for the conditions, population and terrain, etc., that best contributes to safety on their roads. This is a clear-cut violation of the will of Congress in taking that action. FMCSA, NHTSA and DOT are supposed to create regulations that enact the will of Congress, not violate it.

Ninth, many state governments have decided to eliminate any differential of speed between trucks and other vehicles, based on safety concerns. Should a federal agency, acting outside the clear will of Congress, negate actions taken by numerous state governments concerning activity within their own borders?

Tenth, some of the larger motor carriers that have speed limiters also have trucks that crash far more frequently than other carriers. What sense does it make to emulate trucking companies that crash when your goal is to reduce or eliminate that behavior?

Eleventh, some of the “research” FMCSA relies on originally concluded that speed limiters were not helpful to safety. So the study was pulled back, information was added using a standard never before used in trucking research, and the conclusion changed. Also, the study compared speed-limited trucks from less-than-truckload carriers with non-limited fleets in the truckload sector, which run far more miles. That’s not just apples and oranges; it’s apples and small Wankel rotary engines. What’s even more, most of the industry is made up of very small motor carriers, who were not even represented in the study. This research is dishonest at best, fraudulent at worst. Such research should be discarded and ignored in the face of the other, honestly conducted and overwhelming research about the safety of uniform speeds.

Twelfth, the American Trucking Associations, one of the groups that first petitioned for speed limiters, now says the regulation as proposed is “flawed.” When the group asking for a reg says it does not want it, why pursue it, especially as it is not linked to greater safety?

Thirteenth, situations do arise in which – to avoid a potential accident – a truck needs the ability to accelerate. While these are not common, they occur on a somewhat regular basis. Again, limiters will not reduce these potential accidents; they will turn them into actual accidents, removing all potential for avoiding them.

Finally, while a case can be made for speed limiters adding to fuel economy (an economic benefit), truckers themselves stand to lose significant pay, as the system pays them only for the miles they run. That was never taken into account, as if individual human beings and their needs to pay for food, clothing and shelter were of no import. What’s more, truckers have many other methods for obtaining higher fuel economy. Why not put the decision of when to run what speed into the hands of the people who are present, who can see the whole situation and who have the ability to affect the outcome – the truckers themselves? When truckers look at their situation and determine that a slower speed is possible, they will typically do so to conserve fuel. But when it’s a safety sensitive situation and a higher speed is necessary, they will accommodate the reality on the ground.

Truckers have every incentive to stay safe, and for those who own their trucks, every incentive to save fuel. Let’s enable those instincts instead of hampering these people from doing their jobs.


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