Box Dawg Freight Services LLC - Petition for Rulemaking

Date: December 1, 2025 The Honorable Derek D. Barrs Administrator Federal Motor Carrier Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 RE: Petition for Rulemaking — Establishment of “Bona Fide Independent Dispatch Agent” (BFIDA) Under 49 CFR Part 371 and Adoption of the Compliance Accountability Matrix (CAM) Standard Dear Administrator Barrs, On behalf of the Road Dawg Compliance & Accountability Initiative and the broader coalition of independent motor carriers, dispatch professionals, and Georgia’s freight community, I respectfully submit this Petition for Rulemaking. Executive Summary: The "Missing Link" in National Safety This petition requests that FMCSA formally recognize the Bona Fide Independent Dispatch Agent (BFIDA) as a regulated safety role and adopt the Compliance Accountability Matrix (CAM) digital standard. This proposal addresses a critical anomaly in federal safety oversight: The Trucking Dispatch Gap. Congress has long recognized that those who direct transportation assets must be as accountable as those who operate them. In aviation, an FAA-licensed Aircraft Dispatcher shares joint legal responsibility for flight safety. In rail, a federally certified Train Dispatcher controls track movements. Yet, on our nation's highways, the dispatch sector remains completely unregulated, allowing anonymous and often fraudulent actors to direct 80,000-lb commercial vehicles without federal vetting or accountability. Technical Feasibility & Pilot Readiness The proposed “Compliance Accountability Matrix” (CAM) is not merely a conceptual framework. We have actively developed the verification system, a cloud-native tool engineered to automate CAM compliance by linking physical freight movements with federally recognized digital records. In parallel, we have deployed a specialized Learning Management System (LMS) to standardize the training requirements for the BFIDA role. Together, these systems demonstrate that the industry possesses the technological capability and operational readiness to implement these standards immediately. Appendix H (Technical Feasibility) and Appendix E (Georgia Pilot) detail exactly how this framework functions. We respectfully request that FMCSA open a rulemaking docket to adopt these standards, bringing motor carrier oversight into alignment with the safety standards already established for aviation and rail. Respectfully submitted, Kevin Lewis Road Dawg Compliance & Accountability Initiative 404-468-6821 kevin@roaddawgtech.com cc: The Honorable Sean Duffy, Secretary of Transportation Jesse Elison, Chief Counsel, FMCSA Michael Rutherford, Assistant Secretary for Multimodal Freight Infrastructure