October 7, 2014

The Honorable Tom Latham

Chairman
Subcommittee on Transportation,
Housing and Urban Development,
and Related Agencies
House Committee on Appropriations
2358A Rayburn House Office Building
Washington, DC 20515
The Honorable Ed Pastor
Ranking Member
Subcommittee on Transportation,
Housing and Urban Development, and
Related Agencies
House Committee on Appropriations
2358A Rayburn House Office Building
Washington, DC 20515


Dear Chairman Latham and Ranking Member Pastor:

We write in support of Section 425 of H.R. 4745, and urge that this provision, which prohibits
the Department of Transportation from moving forward with increases in the minimum level of
financial responsibility for commercial property and passenger motor carriers, including private
school bus operators and other private carriers, be included in the final Department of
Transportation appropriations legislation for Fiscal Year 2015.

Our organizations represent thousands of individual businesses who operate trucks and buses
located in every state and congressional district. These businesses, the vast majority of which
are small businesses, are both critical to our nations economy and committed to safety on our
nations highways. With this perspective, we are concerned about the negative impacts that an
increase in financial responsibility requirements will have on the ability of our member
companies to remain in business, and on highway safety.

The Department announced in April 2014 that it was moving forward with the development of
regulations to increase minimum financial responsibility requirements for truck and bus
companies. This is despite the fact that the Departments own data shows that less than 0.2
percent of truck-involved accidents result in damages that exceed the current requirements. On
the bus side, the Department has not even analyzed passenger motor carrier data or accident
claims history. The determination did not include any consultation with insurance experts or
study of actuarial data, nor did it consider the impacts of higher insurance costs on truck and bus
companies, especially small businesses and private fleets.

What is especially troubling about this rulemaking is that the Department cannot show any
connection between higher minimum insurance requirements and improved safety performance
by a truck or bus company. Indeed, with the Department already referencing insurance increases
close to 500 percent, the resulting premium increases per truck or bus will lead to a significant
number of our member companies significantly downsizing their fleets or leaving the industry
altogether.

We are proud to represent thousands of safe truck and bus companies and thousands of
professional drivers with millions of accident-free miles behind the wheel. These are the
companies and drivers we need on the road. Policies that simply lead to higher operating costs,
with no resulting safety improvements, only serve to drive them away from the truck and bus
industries.

This rulemaking action, described as high priority, has been taken up by the Department
without direction from Congress, and is moving forward while other actions with a direct impact
on motor carrier safety languish with little to no action by the Department. At the very least, the
Department should halt this action until the issue can be fully examined by Congress through
hearings and legislative direction, as occurred when the current minimum financial responsibility
requirements were enacted into law.

Section 425 would provide Congress with an opportunity to conduct oversight hearings and
debate on a topic that will impact hundreds of thousands of motor carriers, both for-hire and
private. As your Committees work to finalize Fiscal Year 2015 appropriations legislation for the
Department of Transportation, we urge you to include the Houses Section 425 in the final
agreement.

Thank you for your consideration of this request.

Sincerely,


Owner-Operator Independent Drivers Association

National School Transportation Association

United Motorcoach Association

American Bus Association

National Federation of Independent Businesses

Petroleum Marketers Association of America

American Truck Dealers

National Ready Mixed Concrete Association