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Electronic Stability Controls and Speed Limiters

Electronic Stability Control

Speed Limiters


Electronic Stability Control for Heavy Vehicles

 

Ready mixed concrete industry position: While use of electronic stability control (ESC) systems for heavy vehicles has promise of decreasing the number of annual truck rollovers and crashes, the practicality of installation of such systems does not exist with current in-service vehicles. While NRMCA supports the required installation and use of ESC systems on new heavy vehicles, such as ready mixed concrete mixer trucks, NRMCA strongly opposes broadening such a mandate to include retrofitting currently in-service vehicles, whether tractor-trailer or single-unit heavy trucks.

 

Background: On May 23rd, 2012 the National Highway Traffic Safety Administration (NHTSA) published the proposed rule Federal Motor Vehicle Safety Standards; Electronic Stability Control Systems for Heavy Vehicles (77 FR 30766). The intent of the proposal is to “establish a new Federal Motor Vehicle Safety Standard… to require electronic stability control (ESC) systems on [new] truck tractors and certain buses… ESC systems in truck tractors and large buses are designed to reduce untripped rollovers and mitigate severe understeer or oversteer conditions that lead to loss of control by using automatic computer-controlled braking and reducing engine torque output.”

 

How it affects our industry: The proposed rule places the cost of installation during manufacture at $520 to $1,160 per truck. Regardless of upgrading from Rollover Stability Control (RSC) to ESC or installing ESC outright, aftermarket installation of either system will be a considerably higher cost. As much, the older the truck, the cost for installation per truck dramatically rises. Since the installation, when achievable, is aftermarket it requires a great deal of improvisation, meaning increased instances of maintenance, resulting in unacceptable higher continued maintenance costs. As well, there will be certain cases with in-service trucks where retrofitting simply will not be an option. Issues preventing a successful retrofit range from the age of the truck, to other interfering aftermarket integrated safety and electronic features, to unworkable truck designs.

 

Establishing an appropriate performance level for such retrofits is unfeasible. Each in-service truck operates differently than the next; a “one-size fits all” level of performance would not be attainable. Compliance with an ESC performance standard on retrofits for potentially decades' worth of different year trucks, makes, and models may be unachievable as well.

 

Finally, ready mixed concrete producers regularly purchase new ready mixed concrete trucks rendering retrofitting of currently in-service vehicles as duplicative. Requiring a heavy truck purchaser to retrofit a currently in-service vehicle shortly before a new truck containing an ESC is purchased to replace the currently in-service vehicle is does not provide an adequate balance between cost, feasibility and safety.

 

Required action: Any finalized mandate for electronic stability control (ESC) systems for heavy vehicles should be limited to new heavy vehicles, and prohibit the required use and installation of ESC on currently in-service vehicles, whether tractor-trailer or single-unit heavy trucks.

 

Speed Limiters for Heavy Vehicles

 

Ready mixed concrete industry position: While use of speed limiter systems for heavy vehicles may have promise of decreasing the number of annual truck crashes, increasing overall safety and decreasing fuel and maintenance costs, the feasibility of installation of such systems becomes problematic with current in-service vehicles. NRMCA supports the mandated installation and use of 68 miles-per-hour (68 mph) speed limiter systems on new heavy vehicles, such as ready mixed concrete mixer trucks, however NRMCA strongly opposes expanding such a requirement to include retrofitting currently in-service vehicles, whether tractor-trailer or single-unit heavy trucks.

 

Background: Currently, the National Highway Traffic Safety Administration (NHTSA) and the Federal Motor Carrier Safety Administration (FMCSA) are jointly in the process of drafting a proposed rule to require the installation and use of speed limiters on heavy vehicles. The aim for such a rule would be to reduce heavy truck crashes, provide a greater amount of overall safety on our nation’s road and highways, and reduce fuel and maintenance costs. A NHTSA official, as recently as October 2013, confirmed that their proposal aim to cover both new and currently in-service heavy vehicles. NHTSA and FMCSA plan to publish the proposed rule as early as March 2014.

 

How it affects our industry: As with many other electronic monitoring systems, such a rule would place a considerable cost and complex technological installation burdens on owners of currently in-service vehicles. As well, the older the truck, the cost for installation per truck dramatically rises. Since the installation, when achievable, is aftermarket it requires a great deal of improvisation, meaning increased instances of maintenance, resulting in unacceptable higher continued maintenance costs. As well, there will be certain cases with in-service trucks where retrofitting simply will not be an option. Issues preventing a successful retrofit range from the age of the truck, to other interfering aftermarket integrated safety and electronic features, to unworkable truck designs. According to the American Trucking Associations (ATA), Timothy Blubaugh, executive vice president of the Truck & Engine Manufacturers Association has stated that such retrofits are “not practicable.” As well, ATA’s own Senior Vice President for Policy and Government Affairs, David Osiecki, recently stated that retrofitting currently in-service vehicles may not even be “doable.” Establishing an appropriate performance level for such retrofits is also unfeasible. Each in-service truck operates differently than the next; a “one-size fits all” level of performance would not be attainable. Compliance with a speed limiter performance standard on retrofits for potentially decades' worth of different year trucks, makes, and models may be unachievable as well.

 

Finally, ready mixed concrete producers regularly purchase new ready mixed concrete trucks rendering retrofitting of currently in-service vehicles as duplicative. Requiring a heavy truck purchaser to retrofit a currently in-service vehicle shortly before a new truck containing a speed limiter is purchased to replace the currently in-service vehicle is does not strike and appropriate balance between cost, practicality and safety.

 

Required action: Any finalized mandate for speed limiter systems for heavy vehicles should be limited to new heavy vehicles with a maximum speed limit of 68 mph, and prohibit the required use and installation of speed limiters on currently in-service vehicles, whether tractor-trailer or single-unit heavy trucks.