To the FMCSA, we oppose your speed limiter mandate. This mandate will make the roads more dangerous for everyone.

In your proposal you said “In 2019, there were 860 fatal crashes in areas with posted speed limits of 70 to 75 miles per hour. 24 fatal crashes in areas with posted speed limits between 80 to 85 miles per hour.” That’s 884 fatalities. 

NOTICE HOW HIGHER THE SPEED 

LESS THE FATALITIES? 

However Your reasoning for your proposal was cleverly worded and inflated to make it seem that the speed of the truck was the factor in those 884 fatalities and that the trucks seemed to be responsible for the accident. What you failed to mention was that in 2019 out of the 3.97 million Class 8 trucks on the road there was only 4949 Truck related fatalities and only 376 or 7.6% was a result of the truck speeding. 821 or 16.6% was a result of the car speeding. Also what you failed to mention is that also out of those 4949 truck fatalities that 806 or 16.7% was a result of the car rear ending the truck and that Out of 3.97 million trucks on the road only a mere 183 or 3.7% of the 4949 fatalities was resulted by the truck rear ending the car. I bet you a million dollars that even those 183 were not even all the trucks fault either. I Wonder how many were brake checked or the car did an unsafe maneuver beyond the trucks capabilities to stop. Rear-end crashes are the most frequently occurring type of collision, accounting for approximately 29% of all crashes. Mostly by cars not Trucks even though we already have radar braking systems and need more space. We use the Smith System. Car drivers don’t even know what that is. They think it’s a gardening technique to make non-gmo organic Granny Smith Apples plump and juicy without pesticides. These accidents were caused by a slower vehicle in front or a really fast vehicle from behind. You then want to slow down 4 million of the already slow and already speed limited of the safest demographic even more because of 884 unfortunate fatalities that were mostly caused by the car to make things safer for the car by creating the same conditions but on a bigger scale with more obstacles? Does that even make sense? How Does that actually sound like a solution? Also I would like to add that out of the 4949 truck fatalities 885 or 17.9% was due to an oncoming car drifting in the trucks lane(head on collision) and only 108 or 2.2% was due to the truck drifting into the cars lane. So far out of the 4949 truck crash fatalities just with these figures illustrated cars are responsible for at least 2512. The rest of the fatalities were sideswiping fatalities probably due to the car not merging properly or the car trying to pass while making a right turn. 

Also I would like to note that 679 truck drivers lost there lives in 2019. I wonder how many of those 679 sacrificed their lives to swerve out of the way to avoid an accident or killing a family that put themselves in harms way because they were never taught or properly trained by the government how to drive around a truck when they went to get their license.

“The FMCSA envisions the rule as a commonsense approach to reducing crashes and saving lives as the agency continues to work with drivers and advocates for the CMV community towards a goal of zero lives lost on our nation’s roadways.” Here’s my common sense opinion based on fact. Based on information from the American Truck Association (ATA), about 80% of truck accidents across the country can be linked more to a car driver’s mistakes than those of the truck driver. The National Highway Traffic Safety Administration (NHTSA) conducted its own study and found the percentage of car-caused truck accidents to be closer to 90%.

Truck Drivers are not the issue even though a small nominal amount are. Even though more destructive, Trucks don’t kill as much as you say we do but Cars kill themselves. So what are you gonna do about the 36,835 car fatalities of 2019 that had nothing to do with trucks? 

If you truly want to work towards the goal of zero lives lost as much as I do then figure out a way to actually fix the problem instead of always trying to work around it expecting different results; CARS. They are uneducated about other vehicles on the road or how to drive in different scenarios. They drive offensively not defensively. They think it’s a race, they don’t plan ahead, they follow too close to each other, they drive erratically, they don’t adjust speed for conditions, they don’t check their mirrors. They constantly hang around and don’t go any where else. They brake check, they go 45 mph because their exit is in 3 miles. They don’t use turn signals. They have lights that don’t work. They can’t merge. They wait till the last second to cut over when the right lane ends. They don’t pass other cars they hang next to them blocking lanes. When you are supposed to speed up they slow down when you are supposed to slow down they speed up. They do the opposite of what is supposed to be done in most situations. Why? no common sense, awareness or training. Look at Germany and their car drivers requirements to get a license. All drivers are professional drivers. They go 80, 100, 200, 300mph and have less accidents and fatalities then us. We are definitely doing something wrong and not actually solving the problem. Don’t try to solve a problem by creating 3 more. Stop focusing on the already safe demographic and start to address the real problem. Then you will see better results and more people arrive alive. Stop making us pay for other peoples lack of training. You want us to pay for trailer under guards so people don’t end up under our trailer when they chose to be there. Even with that extra equipment they still will die they just won’t get chopped in half. Just teach them how to drive around trucks. Simple.