Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators

The National Agricultural Aviation Association (NAAA) is writing to express concerns with the Federal Motor Carrier Administration's notice of proposed rulemaking (NPRM): "Minimum Training Requirements for Entry-Level Commercial Vehicle Operators." Our Association supports enhancing driver training, however, the provisions of this proposed rule are untenable and would seriously hamper our industry's ability to recruit and train new drivers during peak times of aerial application in this country. NAAA represents licensed commercial applicators that use aircraft to enhance food, fiber and bio-fuel production, protect forestry, and control health-threatening pests. There are approximately 1,600 aerial application businesses in 48 states throughout the U.S. According to the U.S. Department of Agriculture, aerial application accounts for almost 25% of commercial crop protection applications and nearly 100% of forest protection applications. Our Association's members service farmers and ranchers in their efforts to produce agricultural crops. This NPRM will make it virtually impossible to recruit, hire and train drivers to service farmers and ranchers during the peak time in which they need our services to protect their crops from damage. We operate heavily in the spring, summer and the fall to support our customers. These peak seasons force us to rely on various and sparce sources for new drivers, including entry-level drivers. With the proposed rules, we would have to start our hiring process at least four weeks earlier and incur huge costs to pay these employees to train and retain them through the season. We are concerned that the one-size fits all hours based approach will not work for the short-term drivers our industry would be hiring. Under this rule drivers would use our Association's member's companies to pay for their training and then seek employment with a long term company for employment, rather than with an aerial application company that has seasonal employment. Our industry is already experiencing this trend with CDL drivers. Under the FMCSA NPRM this situation would only be exacerbated. The accredited trainer qualifications that are proposed would take away our Association's member's ability to train these potential drivers on how to drive the back roads and field roads that we commonly operate on. It would mean that after they came out of the accredited school, we would have to incur more cost and still have to do our own personalized training to show these individuals the different characteristics of operating under these conditions. The National Agricultural Aviation Association believes that the proposed entry- level driver-training rule is fundamentally flawed and needs to be reconsidered. At a minimum FMCSA should: develop a performance-based rule for training and testing of entry-level drivers; allow motor carriers and training schools to self- certify; and, consider the possibility of exempting farm suppliers, such as aerial application operations from these potential regulations. Thank you for the opportunity to comment on this important issue. Most sincerely, Andrew Moore Executive Director National Agricultural Aviation Association