Speed limiter proposal: 6 slides on the basics

DOT estimates, for 60 mph setting:

• Lives saved: 162 to 498
• Serious injuries prevented: 179 to 551
• Minor injuries prevented: 3,356 to 10,306
• Annual costs associated with increased delivery time: $1.534 billion
• Annual fuel savings/GHG reduction: $848 million
• Annual total benefits: $2.695 to $6.522 billion

DOT estimates, for 65 mph setting:

• Lives saved: 65 to 214
• Serious injuries prevented: 70 to 236
• Minor injuries prevented: 1,299 to 4,535
• Annual fuel savings/GHG reduction: $848 million
• Annual costs associated with increased delivery time: $514 million
• Annual total benefits: $1.564 to $3.281 billion

DOT estimates, for 68 mph setting:

• Lives saved: 27 to 96
• Serious injuries prevented: 30 to 106
• Minor injuries prevented: 560 to 1,987
• Annual fuel savings/GHG reduction: $376 million
• Annual costs associated with increased delivery time: $206 million
• Annual total benefits: $684 million to $1.469 billion

New vehicle

To determine compliance of new vehicles with the operational requirements for the speed limiting device (i.e., that the vehicle is in fact limited to the set speed), NHTSA is proposing a vehicle-level test that involves accelerating the vehicle and monitoring the vehicle’s speed, similar to the validation procedures currently used in Europe.

However, NHTSA is not proposing requirements to prevent tampering or restrict adjusting the speed setting as part of its portion of the proposal.  Instead, to deter tampering with a vehicle’s speed limiting device or modification of the set speed above the specified maximum set speed after the vehicle is sold, the proposal calls for FMCSA to require motor carriers to maintain the speed limiting devices at a set speed within the permitted range.

NHTSA also is proposing to require that the vehicle set speed and the speed determination parameters be readable through the On-Board Diagnostic (OBD) connection, and that the two most recent modifications of the set speed of the speed limiting device and the two most recent modifications of the speed determination parameters be readable and include the time and date of the modifications.  

Retrofits?

In addition to the new vehicle requirements included in the proposal, NHTSA is considering whether to require commercial vehicles currently on the road to be retrofitted with a speed limiting device with the speed set to no more than a specified speed. 

The agency notes that a retrofit requirement is not included because of concerns about the technical feasibility, cost, enforcement, and small business impacts.  However, DOT is seeking public comment to improve its understanding of the real-world impact of implementing a speed limiting device retrofit requirement.  As an alternative to a retrofit requirement, the agencies are also requesting comment on whether to extend the set speed requirement only to all 26,000-lb. CMVs that are already equipped with a speed limiting device. 

The filing does note the previously expressed concerns of the Truck and Engine Manufacturers Assn. (EMA), which pointed out problems retrofitting vehicles manufactured from 1990 to approximately 1994 to 1996, frequently equipped with mechanically controlled engines and mechanical speed limiting devices.  EMA indicated that it would be impractical to retrofit these vehicles with modern ECUs and estimated that it would cost $1,000 to $1,500 per vehicle.

Given the agencies’ concerns about technical feasibility, cost, enforcement, and impacts on small businesses, DOT seeks public comment to improve its understanding of the real-world impact of implementing a speed limiting device retrofit requirement on existing vehicles and whether it is appropriate to have different requirements for these vehicles.

Penalties

Drivers and carriers would be subject to Federal civil penalties if they are determined to have operated CMVs in interstate commerce when the speed limiting device is (1) not functioning, or (2) set at a maximum speed in excess of the maximum specified set speed.

They would be subject to Federal civil penalties of up to $2,750 for drivers and up to $11,000 for employers who allow or require drivers to operate CMVs with speed limiting devices set at speeds greater than the maximum specified set speed.