On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy group specializing in regulatory issues, I respectfully submit this comment letter on the Federal Motor Carrier Safety Administration’s (hereinafter FMCSA or the Agency) proposed rule, Hours of Service of Drivers (hereinafter HOS Rule). This comment letter develops the following points:
- The HOS Rule would disproportionately impact compliant commercial motor vehicle (CMV) owner-operators.
- Adjusting limits on hours-of-service (HOS) is an inappropriate mechanism for improving highway safety, as high-risk CMV operators have a strong economic incentive to engage in noncompliant behavior.
- FMCSA’s largely unenforceable and overly complicated regulatory regime crowds out private arrangements between CMV operators and CMV insurers.