TRUCKERS UNITED FOR FREEDOM
  • Home
    • Truckers Independent Broadcasting Networks
  • Contact
  • Mission Statement
  • CB 10 Codes/Slang
  • D and R
  • Articles
  • Truckers 4 Trump 2024

                         A Letter For Cybersecurity Issues


To whom it may concern,
​
Truck drivers have numerous concerns in regards to the federal regulations, one of which is the forced use of use the electronic logging device to keep track of the driver's hours of service ( hours of service is a rule that drivers are not allowed to drive more than 11 hours in a 14 hour period with a 30 minute break within the first 8 hours  and must take 10 hours off duty ). These devices may be hacked by "bad actors", which will allow for them to hijack a truck and it's cargo or be used to commit an act of terrorism. America's truck drivers are the safest drivers on the road but are heavily regulated, for the supposed purpose for safety, by the Federal Motor Carrier Safety Administration, an agency under the Department of Transportation. Other concerns include:
 
Electronic Logging Device
Due to the aforementioned issues, we require that the electronic logging device should be a choice. 

Reasonable HOS 
Currently, the FMCSA is working on creating new hours of service rules. Our issue with what they are doing is that they are using the same failed techniques in doing so. They are thinking in a linear fashion by attempting to cut up a 24 hour period to make a one size fits all approach for a problem that exists because that is what they have done in the past. The truck drivers require a more sensible approach by using conceptual reasoning to address this very important issue.

Tr
aining 
The FMCSA has developed a training curriculum that the truck drivers deem insufficient. The truck drivers require a training and education system that would genuinely be beneficial to the new to the industry drivers.

Parking
Municipalities in the United States will commonly prohibit large commercial motor vehicles from parking or overnight parking with the boundaries of their municipalities. We feel that it is imperative to require States to create truck parking and staging areas within a reasonable distance from municipalities that require outside truck deliveries. These parking and staging areas should be adequate to accommodate the flow of truck traffic that services their area.

Advisory Committee 
Due to the fact that truck drivers are individuals being regulated for the job that they perform, they should be granted the opportunity to form a committee of truck drivers from all sectors of the trucking industry to act as advisers to the U.S. Congressional oversight committees and the Department of Transportation. We require this committee to be funded in order to adequately compensate the committee members and cover the cost of doing business. 
 
In its entire nineteen years of existence the FMCSA has not created safer roads as they pertain to the trucking industry. According to the American Trucking Associations, the trucking industry may be responsible for up to 20 percent of the accidents that they are involved. If on average there are 4,000 fatalities a year then the trucking industry may be responsible for up to 800 fatalities a year. Nearly that many truck drivers perish every year in work-related accidents.  If there are 40,000 fatalities on America's roads a year then the trucking industry may only be responsible for as much as 2 percent of all highway fatalities, while yet they are being highly regulated in inappropriate ways. This is subjugating America's truck drivers to abuses that are unwarranted and we want that to change. However, we are willing to accept our responsibility in what accidents that we are responsible and hold the highest expectation for the respect that we deserve to be allowed to be an instrumental part of the process for achieving safer travel conditions on America’s roads. Federal regulatory agencies have violated many statutory laws to push an agenda for self-serving interest and the interest of special interest groups. The Federal Motor Carrier Safety Administration is no exception in that regard. 

We would like for you to view these links as evidence to some of our claims in regard to cybersecurity issues related to the electronic logging device.
  • The Federal Motor Carrier Safety Administration report on the risk for the electronic logging device to be hacked.                                                                          https://www.fmcsa.dot.gov/research-and-analysis/technology/cybersecurity-best-practices-integrationretrofit-telematics-and 
  • The National Highway Traffic Safety Administration report on the Best Practices for Modern Day Vehicles.                                                                             https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/documents/812333_cybersecurityformodernvehicles.pdf
  • National Highway Traffic Safety Administration "Radio Software Security Vulnerabilities" July 23, 2015. They claim that this is the only time that hacking a vehicle has occurred but how would they know?www.nhtsa.gov/vehicle/2015/CHRYSLER/300/4%252520DR/FWD#recalls
  • Secretary of Transportation Elaine L. Chao delivers a  speech at an autonomous vehicle symposium on July 10, 2018.                                                                                   https://www.transportation.gov/briefing-room/7-10-2018-autonomous-vehicle-symposium
  • Jose Carlos Norte gives insight on how to hack industrial vehicles from the internet. http://jcarlosnorte.com/​
 
  • Truck drivers feel that the FMCSA has purposefully and willingly skirted the Regulatory Flexibility Act. "FMCSA states that because small businesses constitute a large part of the demographic FMCSA regulates, providing exemptions to small business to permit noncompliance with safety regulations is not feasible and not consistent with good public policy.  Accordingly, the agency will not allow any motor carriers to be exempt from coverage of the rule based solely on a status as a small entity.  Lastly, FMCSA concluded that because it is not a covered agency as defined in section 609(d)(2) of RFA, it has taken no steps to minimize the additional cost of credit for small entities."         
                           
  • Truck drivers also feel like the FMCSA has violated the Unfunded Mandate Act. "FMCSA states that title II of the Unfunded Mandates Reform Act of 1995 requires agencies to evaluate whether an agency action would result in the expenditure by state, local, and tribal governments, in the aggregate, or by the private sector, of $155 million or more (which is $100 million in 1995, adjusted for inflation) in any 1 year, and, if so, to take steps to minimize these unfunded mandates.  FMCSA concluded that this rule making would result in private sector expenditures in excess of the $155 million threshold for each of the options.  According to FMCSA, however, gross costs are expected to be more than offset in savings from paperwork burden reductions."  

How do they determine that paperwork reduction will offset the cost of the mandate when a logbook cost $3.50 a month and the electronic device will cost $25.00 a month just in data service?                                                          
  https://www.gao.gov/products/D12715#mt=e-report

To force an individual person or business to use an electronic device that may place them in harm's way, physically and financially, is abusive and tyrannical. The Federal Motor Carrier Safety Administration has made claims that the hours of service rule is broken and the Department of Transportation has failed to complete a parking study to determine in what ways we need to properly accommodate parking for large trucks so that drivers may get proper rest. Highway fatalities that involve crashes with large commercial trucks have risen through the years and the blame for that has rested on the shoulders of truck drivers. 

 "That is how government works — we tell you what you can do today. We give you the flexibility to get it done yourself and we send a long-term market signal that is going to open up innovation moving forward."  - Former Administrator of the EPA, Gina McCarthy
The truck drivers of America want to know where those tools are when we are being so heavily regulated by such an unrealistic means.

Thank you and God bless,
The American truck driver

Home    TIBN Contact     Mission Statement    Articles    
​CB 10 Codes/Slang
    D and R



  • Home
    • Truckers Independent Broadcasting Networks
  • Contact
  • Mission Statement
  • CB 10 Codes/Slang
  • D and R
  • Articles
  • Truckers 4 Trump 2024