Letters, Petitions and Comments

CVSA and CVBMC Submit Comments to AEB NPRM

On Sept. 5, CVSA, on behalf of the Commercial Vehicle Brake Manufacturers Council (CVBMC), submitted comments regarding the joint notice of proposed rulemaking (NPRM) from NHTSA and FMCSA proposing automatic emergency braking (AEB) and other related requirements for heavy duty vehicles.

Petition to Clarify What Qualifies as a Valid CDL

On April 4, the Commercial Vehicle Safety Alliance (CVSA) petitioned the Federal Motor Carrier Safety Administration (FMCSA) to amend Title 49 CFR § 383.25(a)(1) to clarify what qualifies as a “valid commercial driver’s license (CDL)” for the purposes of accompanying a commercial learner’s permit (CLP) holder for behind-the-wheel training in a commercial motor vehicle (CMV).

Petition to FMCSA Regarding Wheel Components

On March 30, the Commercial Vehicle Safety Alliance (CVSA) petitioned FMCSA to amend CFR § 393.205 to clearly identify several hazardous conditions that correspond to regularly observed conditions of wheel components that result in high risk of a crash or breakdown.

CVSA Files Comments Regarding ADS-Equipped CMVs

On March 20, CVSA filed comments on FMCSA’s Supplemental Advanced Notice of Proposed Rulemaking (SANPRM) seeking input on which factors the agency should consider in amending the Federal Motor Carrier Safety Regulations to establish a regulatory framework for commercial motor vehicles (CMV) equipped with Level 4 and Level 5 automated driving systems (ADS).

CVSA Submits Updates to 396.3(a)(1) Petition

On Feb. 2, CVSA submitted an update to the Alliance’s March 30, 2021, petition to FMCSA asking the agency to amend Title 49 CFR Part 393 of the FMCSRs by incorporating changes in Subparts B, C, E, F, G and J…

Petition to Update Level VI OOSC Incorporation by Reference

On Jan. 6, CVSA submitted a petition to FMCSA requesting an amendment to the hazardous materials safety permit regulations to update the incorporation by reference of CVSA’s “North American Standard Out-of-Service Criteria (OOSC)…

Comments to Unique Electronic Identification of CMVs ANPRM

On Nov. 21, CVSA submitted comments in response to FMCSA’s ANPRM exploring whether the agency should amend the FMCSR to require every CMV operating in interstate commerce to be equipped with electronic identification technology…

Comments to Electronic Logging Devices ANPRM

On Nov. 14, CVSA submitted comments in response to FMCSA’s ANPRM regarding potential updates and changes to the electronic logging device regulations. In the comments, CVSA provided feedback…

Comments Opposing NPGA HOS Exemption Request

On Oct. 27, CVSA submitted comments to FMCSA in opposition to the National Propane Gas Association’s (NPGA) request for an exemption from several hours-of-service (HOS) regulations. NPGA is seeking relief…

Comments on FMCSA COVID-19 Waiver

On Sept. 28, CVSA submitted comments in response to FMCSA’s request for comments concerning the extent to which motor carriers currently rely on the COVID-19 emergency declaration…