Good Afternoon!

Are you opposed or in favor of CMV speed limiting devices? Please send your comments soon to the Federal Motor Carrier Safety Administration (FMCSA), Department of Transportation (DOT). COMMENTS DUE BY JULY 18:

 
General Questions: 
Setting and Maintaining ECUs 
1. What percentage of the CMV fleet currently uses speed limiting devices? 
2. If in use, at what maximum speed are the devices generally set? 
3. What skill sets or training are needed for motor carriers’ maintenance personnel to adjust or program ECUs to set speed limits? 
4. What tools or equipment are needed to adjust or program ECUs? 
5. How long would adjustment or reprogramming of an ECU take? 8 
6. Where can the adjustment or reprogramming of an ECU be completed? 
6.a Can the adjustment or reprogramming of an ECU be made on-site where the vehicle is ordinarily housed or garaged, or would it have to be completed at a dealership? 
7. Do responses to questions 3 through 6 change based on the model year of the power unit? 
8. Since publication of the NPRM, how has standard practice or technology changed as it relates to the ability to set speed limits using ECUs? 
9. Are there any challenges or burdens associated with FMCSA publishing a rule without NHTSA updating the FMVSS? 
10. Should FMCSA revisit using the 2003 model year as the baseline requirement for the rule? 
11. Should FMCSA consider a retrofit requirement in the rule and, if so, should it be based on model year or other criteria, and what would the cost of such a requirement be? 
12. Should FMCSA include Classes 3-6 (i.e., 10,001 – 26,001 lbs. GVWR) in the SNPRM?  
Thank you,
Patricia Cowley 
Executive Director 
Telephone: 717-236-9042 
Email:  director@pabus.org 
Website: www.pabus.org