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Letters, Petitions and Comments

Petition to Define Yard Moves

CVSA submitted a petition to FMCSA to publish guidance on how “yard moves” apply to the hours-of-service regulations and conduct a rulemaking to define the terms “yard move” and “yard”.

Comments on SBTC ELD Exemption Request

CVSA submitted comments to FMCSA in opposition to an exemption request from the Small Business in Transportation Coalition for exemption from the ELD requirement.

Comments Regarding VSNA Rear-Vision Mirror Exemption Request

CVSA submitted comments to an exemption request from Vision Systems North America Inc. (VSNA) seeking to allow motor carriers to operate commercial motor vehicles equipped with the company’s SmartVision camera monitor system as an alternative to two rear-vision mirrors.

Comments to FMCSA NPRM to Update the Incorporation by Reference of the CVSA Level VI OOSC

CVSA submitted comments to FMCSA supporting the amendment of the hazardous materials safety permit regulations to update the incorporation by reference of CVSA’s “North American Standard Out-of-Service Criteria and Level VI Inspection Procedures and Out-of-Service Criteria for Commercial Highway Vehicles Transporting Transuranics and Highway Route Controlled Quantities of Radioactive Materials as Defined in 49 CFR Part 173.403.”

Comments to FMCSA Part 350 NPRM

CVSA submitted comments to FMCSA’s NPRM on updates to Part 350 and the Motor Carrier Safety Assistance Program (MCSAP) allocation formula.

Comments to FMCSA Inspector Certification NPRM

CVSA submitted comments to FMCSA’s NPRM that would amend the regulations to incorporate by reference CVSA’s “Operational Policy 4: Inspector Training and Certification,” which outlines the required training and certification of those conducting driver or vehicle roadside inspections.

Comments on NHTSA ADS Regulatory Barriers ANPRM

CVSA submitted comments to the National Highway Traffic Safety Administration’s (NHTSA) advance notice of proposed rulemaking (ANPRM) on regulatory barriers for vehicles with automated driver systems (ADS).