Docket Management Facility (M-30)
U.S. Department of Transportation
West Building Ground Floor, Room W12 – 40
1200 New Jersey Avenue SE
Washington, DC 20590-0001
Docket No. NHTSA-2016-0087
Docket No. FMCSA-2014-0083
Federal Motor Vehicle Safety Stands; Federal Motor Carriers Safety Regulations;
Parts and Accessories Necessary for Safe Operation;
Speed Limiting Devices
SUBMITTED BY:
Kansas Motor Carriers Association, Inc.
2900 SW Topeka Boulevard
Topeka, Kansas 66611
November 1, 2016
To Whom it May Concern:
The Kansas Motor Carriers Association supports uniform speed limits for all motor vehicles
and strict enforcement of the posted speed limit. We oppose efforts by the Federal Motor
Carrier Safety Administration and the National Highway Traffic Safety Administration to
adopt rules that require all new Class 7 and 8 trucks to have their top speed electronically
limited to no more than 62, 65 or 68 miles per hour. Should FMCSA move forward with a
requirement that Class 7 and 8 trucks be equipped with an electronic speed limiter, the
maximum threshold for the speed limiter should correspond to the maximum speed limit set by
the states.
There are different maximum speed limits across the United States. The states having the
lowest maximum speed limits are located along the congested East and West coast. Kansas’
maximum speed limit is 75 miles per hour on the interstate system. Additionally, Kansas has a
10 mile per hour “buffer” that dates to the time of the nation-wide 55 miles per hour speed
limit. This “buffer” allows for a speeding ticket to be issued but the violation is not reported to
the Division of Vehicles and doesn’t appear on a driver’s motor vehicle record; nor can the
violation be used by insurance companies to set insurance rates. The “buffer” allows for a de
facto 85 miles-per-hour maximum speed limit.
Mk;fldk
Docket No. NHTSA-2016-0087
Docket No. FMCSA-2014-0083
Page 2
Many trucking companies choose to place speed limiters on their trucks to control CSA scores, reduce fuel
consumption or to comply with lower speed limits on the routes they operate. These are company choices, not
a Federal nation-wide mandate. FMCSA already has the tools through CSA scores to intervene with trucking
companies that have a history of speeding violations. We understand that fatalities on our highways are
increasing, but we believe the main causes of the increase are a result of distracted driving and more vehicle
miles traveled because of low fuel prices and states adopting higher speed limits.
KMCA is also deeply concerned that significant differential created by reduced truck speeds would increase
the amount of rear end collisions between passenger vehicles and large trucks. Further, an increase in “road
rage” will happen when a governed truck governed at 68 miles-per-hour attempts to pass a truck governed at
65 miles-per- hour causing a significant back up in the flow of traffic.
A study completed by the Michigan Office of Highway Safety Planning entitled “Establishing Realistic Speed
Limits” sets out the recommendation for setting maximum speed limits. The recommendations for realistic
speed limits are:
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Represent maximum speeds under ideal conditions and when conditions change, drivers must
accordingly reduce their speed;
Reinforce the credibility and acceptance of all traffic control devices;
Provide smooth orderly flow of traffic, a major factor in preventing highway crashes;
Offer an effective traffic enforcement tool for police by clearly separating the flagrant violator from
the majority of drivers; and
Based on the 85th percentile speed which is the most critical criterion in establishing realistic speed
limits.
A study produced by the Texas Department of Highways and Public Transportation entitled “Speed Zoning on
Texas Highways” supports the latter recommendation presented in Michigan’s “Establishing Realistic Speed
Limits.” The lowest chances of being in an accident are achieved when the speed limit is set at the 85th
percentile speed.
These studies show that the chances of accidents increase when traffic is not flowing at the 85th percentile
speed, whether moving faster or slower. Forced use of speed limiters on Class 7 and 8 trucks with a top speed
lower than the 85th percentile speed will indeed result in greater chances of collisions between cars and trucks.
In summary, KMCA supports a uniform speed limit for all vehicles and strict enforcement of the posted speed
limit.
In conclusion, we believe that the proposed regulation is unnecessary and should be withdrawn.
Sincerely,
Tom Whitaker
Executive Director
Kansas Motor Carriers Association, Inc.