Letters, Petitions and Comments

Comments on U.S. DOT AV 4.0

CVSA submitted comments on the “Ensuring American Leadership in Automated Vehicle Technologies: Automated Vehicles 4.0” (AV 4.0) document published by the U.S. Department of Transportation.

Comments on Hemp IFR

CVSA submitted comments to the U.S. Department of Agriculture’s Agricultural Marketing Service’s interim final rule (IFR) on the production of hemp.

Comments on Harris ELD Exemption Request

CVSA submitted comments to the FMCSA in opposition to an exemption request from Harris Companies Inc. for exemption from the electronic logging device (ELD) requirements.

Petition to Update the CVSA Level VI OOSC Incorporation by Reference

CVSA submitted a petition to FMCSA requesting 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 (OOSC) 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” to reference the April 1, 2020, edition.

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.”