Wyatt Hammond

President

It was a day planned with fun in mind around here . . . the date was December 23, 2010. We were scheduled to work a half-day and then enjoy a friendly relaxed Holiday Luncheon together. About two hours before the event, our Regulatory Manager Rich Wilson began ranting at his computer screen as his printer was spitting out page after page of a proposed rule on Hours of Service. Information about this rule was published almost a week prior to the actual Federal Register publish date of Dec. 29, 2010. Needless to say, this was one Christmas gift that no one around here wanted. It became a topic at our luncheon and was our long holiday weekend reading assignment. All I could think was . . . here we go again.

The feds are famous for waiting until the Holiday season to publish something controversial or wait until near the end of the year to make decisions that affect our industry. And frankly, after working here 32 out of the 54 years our business has been in business, I am disgusted by it. The feds have had this on their active plate for over a year, and it gets published when most of the country is in low-key mode (well at least as far as work is concerned). Plus, it was released as a non-official document nearly a week before it was published in the Federal Register, just so it would be out before the Christmas break. Fifty-two weeks in a year, and the feds choose these two weeks to publish something so controversial.

No logical real world experience was used to write this proposal. To me it seems as if it was written and published to 'appease' certain groups of the public. And to me it seems the proposal was written and handled in such a way that they (the feds) are begging for negative feedback . . . perhaps to give them more time to screw it up even more! Please take time to read the proposal, and all information you can find, and comment, comment, comment. The only way the feds will know just how bad they will make things if this becomes a final rule is by your input. Let them know about the locations you established based on the current rule for issues such as overnight accommodations, Just-in-time deliveries for manufacturers and retailers, fuel stops, etc. Also, let them know if you understand the proposal. I am not saying anyone is less than intelligent, but, really, is this proposal easy to understand?

I have written in the past about "Zero Base Review." These rules were supposed to be written so someone with (I believe) a sixth grade reading level could understand them. With this proposal it seems a degree collegiate will be the one who understands it and the rest of us will need to spend an entire Holiday weekend reading it to understand it.

In closing, I want to say that I am deeply concerned about the future of the FMCSA regulations. As well as, deeply concerned about our industry in general. Between politics, economics, difficult to understand regulations, and overcrowded roadways, it seems we are headed in the wrong direction. All we want to do is move our freight and conduct our business. Why is it getting harder and harder to accomplish this? Just as I have learned how to balance work/home/family, shouldn't the FMCSA be helping us to balance safety/freight movement/profitability?