I support the Small Business in Transportation Coalition's ("SBTC") request on behalf all property-carrying operators of commercial motor vehicles (“CMVs”) operating in interstate commerce who operate such vehicles whenever accompanied by any domestic animal, for the following two exemptions to be approved by USDOT each for five years:
 
(1) Exemption from the Electronic Logging Device (“ELD”) requirement codified at 49 C.F.R. § 395.8(a) provided that such drivers track their compliance with the hours of service (“HOS”) regulations using paper record of duty status logs; and
 
(2) Exemption from the HOS requirements that: (1) limit the maximum driving hours for property-carrying drivers to 11 hours (49 C.F.R. § 395.3(a)(3)); and (2) limit the total consecutive on-duty hours for those drivers to 14 hours (49 C.F.R. § 395.3(a)(2)).  We request approval, after 10 consecutive hours off duty, to (1) drive through the 16th consecutive hour after coming on duty, and (2) drive a total of 13 hours during that 16-hour period.

With over 21,000 memberships sold, the SBTC, dba Truckers.com, advises 1.4 million drivers take their pets on the road. It logically follows that 1.4 million animals are currently being transported as passenger companions. Like the National Pork Producers Council successfully argued to Congress, we, too, believe the current HOS regulations and the ELD mandate pose threats to --and endanger the health and welfare of-- these animals transported daily. Drivers that have such animals on board have the added responsibility of tending to their animals’ health, safety and wellness needs in addition to looking out for public safety. They need extra flexibility to be able to reconcile all of these demands and interests… much like FMCSA tries to balance all stakeholders’ interests when promulgating rules.

Drivers need to deal with the impact of hot and cold weather conditions on their pets in order to prevent sickness and injury to these animals. Drivers need to drive slower—rather than race the clock—when animals are on board to prevent injuries, especially when negotiating rough roads so they need more than the normal hours of service to complete their runs. When drivers have an extended day beyond the 14-hour rule, they can take more breaks, feed, relieve and exercise their pets, and reduce the likelihood that they will drive fatigued. This additional two hours will reduce the current trend in large truck occupant fatalities, improve overall safety, which is clearly in the public interest, and save the lives of thousands of animals not currently being included in the large truck occupant fatality statistic by NHTSA. We suggest animals count too.