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Owner-Operator Independent Drivers Association

National Headquarters: 1 NW OOIDA Drive, Grain Valley, MO 64029


Tel: (816) 229-5791 Fax: (816) 427-4468
Washington Office: 1100 New Jersey Ave, SE, Washington, DC 20003
Tel: (202) 347-2007 Fax: (202) 347-2008

January 27, 2015


The Honorable Robert Goodlatte
Chairman
Committee on the Judiciary
2138 Rayburn House Office Building
Washington, DC 20515
Dear Chairman Goodlatte
As the representative of our nations small business truckers and professional drivers, the Owner-Operator
Independent Drivers Association (OOIDA) writes in strong support of H.R. ___, the Small Business Regulatory
Flexibility Improvements Act of 2015.
Trucking is an industry dominated by small businesses, with around half of the nations 500,000 for-hire motor
carriers operating as one-truck/one-driver owner-operator businesses. Indeed, more than 90 percent of all of our
nations trucking businesses are small businesses, with fleets comprising of 20 or fewer trucks. Given the nature of
trucking, it is critical that any rulemaking action fully evaluate the impacts to small businesses.
Unfortunately, the history of trucking-related regulations issued by the Federal Motor Carrier Safety Administration
(FMCSA) and others is filled with examples where the small business impacts of a proposal were not fully evaluated
or that evaluation used improper methodology. For instance, a study recently issued to form the basis for justifying
and calculating the safety benefits for a regulation examined only eleven motor carriers. Of those carriers, nine
possessed over 1,000 trucks while the remaining two operated between 100 and 500 trucks. 1 This is hardly
representative of the trucking industry.
Further, trucking-related regulations are frequently evaluated in isolation from other rulemakings, even those
completed or underway by the very same agency, resulting in significant cumulative impacts that a large trucking
business may be able to deal with, but become absolutely crippling to a small business. In recent years, small
business truckers have seen more restrictive hours-of-service rules that negatively impact both safety and income,
diesel emissions rules that make new trucks more expensive and more likely to break down 2, yet, the FMCSA and
other agencies are moving forward with even more regulations, requirements, and mandates. No one is stopping to
ask if all this regulatory action happening at the same time is having the wrong impact on highway safety and the
environment.
The Small Business Regulatory Flexibility Improvements Act of 2015 includes common-sense improvements to the
regulatory development process that expand analysis and review to ensure that rules are focused on addressing true
problems at limited impact to small businesses. With these changes, the concerns of small business truckers
outlined above, along with others, will begin to be addressed. We urge all Members of Congress to support this
legislation.
Sincerely,

Todd Spencer
Executive Vice President
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Federal Motor Carrier Safety Administration, Evaluating the Potential Safety Benefits of Electronic Hours-of-Service Recorders Final Report, April 2014, AVAILABLE:
http://ntl.bts.gov/lib/51000/51800/51846/13-059-Evaluating_the_Potential_Safety_Benefits_of_Electronic_HOS--Full_Report.pdf. For a critique of the study from the OOIDA Foundation, visit
http://www.ooida.com/MediaCenter/PressReleases/pressrelease.asp?prid=354.
See, for example, American Truck Dealers, A Look Back at EPAs Cost and Other Impact Projections for My 2004-2010 Heavy-Duty Truck Emissions Standards, February 2012,
AVAILABLE: http://www.nada.org/legislativeaffairs/fuel-economy-environment/truck_emissions_standards/.
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