FMCSA has no credible data on the relationship between the use of EOBRs and HOS compliance, and even less data on the relationship between HOS compliance and highway safety. The entire cost-benefit analysis is based upon 2003 data that it previouslyvrejected as a basis for an EOBR mandate and that has never been updated. FMCSA attempts to hide its failure to update its data collection and analyses behind its current euphemism that it has layered data analysis in each successive rulemaking since 2003. But all that has been layered is one unsupported assumption upon the next unsupported assumption, coupled with conjecture inspired by an excess dose of wishful thinking. There is virtually nothing in the record that would allow one to defend FMCSA‘s cost benefit analysis as the product of seasoned decision-making.
TK: A delay of sorts, but another contested regulation from the Obama Administration is moving forward. This one also figures to add to trucking costs for produce operators.
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