Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators

Agricultural Retailers Association 1156 15 th ST NW Suite 302 Washington, DC 20005 May 23, 2008 Docket Management Facility U.S. Department of Transportation Room W12-140 1200 New Jersey Avenue, S.E. Washington, DC 20590-0001 RE: Docket #FMCSA-2007-27748 To Whom It May Concern: The Agricultural Retailers Association (ARA) is a nonprofit trade association representing the interests of agricultural retailers and distributors across the United States on federal legislative and regulatory issues on Capitol Hill and Federal agencies. ARA's member companies have over 6,500 branch locations across the U.S. that use and transport materials requiring a Commercial Drivers License (CDL) and often a hazmat endorsement. As the political voice of agricultural retailers and distributors, ARA not only represents its membership but also educates members on the political process and important issues affecting the industry including safety and security. ARA supports driver training, driver safety and security practices; but the proposed rule has not been proven to enhance any of these goals. ARA opposes the rule for several reasons: First, additional training requirements will only exacerbate the existing CDL driver shortage. The American Trucking Associations (ATA) estimates the driver shortage is already at 20,000 and they expect that number to grow to 100,000 in just a few years. We ask FMCSA to form an industry advisory group to study the safety issues and how best to address them as this non-performance based training misses the mark. Second, internal training programs for new drivers could be discontinued, or at least seriously disrupted if driver-training programs need accreditation by FMCSA. The existing training systems work very well; FMCSA should direct training concerns to individual companies who warrant improvement. The proposed CDL driver-training program has not undergone rigorous review to identify potential conflicts with existing programs: thus, the rule would increase compliance confusion without enhancing safety. Third, at a time when the agricultural industry is struggling with rising costs, the potential internal and external costs, associated with this proposal are very burdensome. ARA truly understands the recently heightened security and safety concerns raised in the U.S. but this ill-considered rule further restricts agricultural carriers, which exacerbates the problems with driver shortage, cost of food production and world food shortages. ARA is not against driver training that leads to a better safety record, but this rule does not address that need. The rule does not allow performance training to take the place of classroom education, which may have some value but less impact than performance training. The rule is costly, does not assist agriculture with additional drivers and takes away retailer training and self -accreditation programs. ARA asks FMCSA to withdraw this proposal and initiate meaningful industry meetings that can lay the groundwork for driver safety initiatives, which are positive for all parties. ARA thanks FMCSA for this opportunity to convey our views to the docket. We encourage you to work more closely with affected parties to address driver safety concerns. Sincerely; James D. Thrift Vice President Regulatory Policy and Corporate Relations

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