Graduated Commercial Drivers Testing and Licensing Standards

June 18, 2003 U.S. Department of Transportation Dockets Management System Room Plaza -401 400 Seventh Street, S.W. Washington, D.C. 20590-0001 Re:Docket No. FMCSA-2002-12334 Dear Docket Clerk: The Truckload Carriers Association (TCA) submits the following comments in response to the Federal Motor Carrier Safety Administration (FMCSA) Docket No. 2002-12334, 68 Fed. Reg. 8798 (February 25, 2003). TCA is the national trade association representing the truckload segment of the trucking industry. Truckload carrier's account for approximately 97 percent of the for-hire freight tonnage annually transported by motor carriers. Matters relating to and affecting the licensure of the industry's drivers are of vital interest to our members and we appreciate the opportunity to submit our thoughts and concerns regarding FMCSA's evaluation of a graduated license system for truck drivers. As a preliminary – but highly critical – matter, TCA believes it is extremely important to comment on FMCSA's characterization of the Congressional directive that underlies this proceeding. As stated more specifically in the Notice, the agency states that it was directed to initiate this proceeding by Section 4019 of the Transportation Equity Act of the 21st Century (TEA-21) in order to "assess the merits of implementing a graduated commercial driver's license (GCDL)" (emphasis added) 68 Fed. Reg. 8798. TCA is concerned by the potential implications of FMCSA's use of the term "merits" to characterize the purpose of this proceeding. By FMCSA's specific use of the term "merits," TCA understands FMCSA to imply that it perceives its role and responsibility in undertaking this proceeding is to evaluate a graduated license system solely from the standpoint of potential safety "merits" (i.e., benefits) and, therefore, that FMCSA has little if any need to give equal consideration to the potential economic burdens and costs to carriers and the economy overall that such a system could impose. It is extremely noteworthy, however, that Section 4019 does not use the word "merits" in giving its direction to FMCSA to initiate this proceeding. Rather, and more specifically, Section 4019 directs FMCSA to "identify[] the benefits and costs of a graduated licensing system" (emphasis added). Docket No. FMCSA-2002-12334 Page 2 The importance for FMCSA to give appropriate consideration to the costs that a graduated license system could impose on carriers and drivers cannot be stressed enough. While inflation has increased over 95 percent since 1980, when the industry was deregulated, the average revenue per mile has clearly not kept pace, increasing a mere 14 percent during the same time period. However, this small increase in average revenue per mile was directly attributable to the efforts of carriers to operate at significantly lower operating costs and extremely lean margins. It was not the result of the willingness of shippers to pay carriers anything more to transport their freight. Indeed, the significant difficulty carriers are having just meeting their operating expenses is evidenced by the fact that over 10,000 trucking fleets closed their doors during the three-year time period 2000-2002 alone; and this number only represents those motor carriers operating five or more trucks. As FMCSA is well aware, the trucking industry has also been facing an annual shortfall of new drivers. In recent years the shortfall has been running as high as 80,000 drivers according to a number of experts. Even if the shortfall number is lower than 80,000 at the present time due to the continuing weak economy, the number of additional drivers needed is nonetheless significant. Moreover, the shortage of drivers will not be going away in the foreseeable future! Indeed, countless numbers of drivers have left the industry and are unlikely to return. To compound the shortage even further, the average age of truck drivers in 2000 was 42, which already exceeded the average age…