Comment from Paul McEachern

I have been certified by ASE as a master automobile and heavy duty truck technician for more than 30 years. I'm also a CDL driver. The first thing is that this rule makes no mention of Electronic Brake Signaling (EBS). I find it amazing and disgusting that in the year 2023 U.S. specification air brake trucks still use pneumatic valves little changed from what George Westinghouse designed for steam trains in 1870 to signal their brakes. The difference between truck/trailer brakes signaled pneumatically at less than the speed of sound versus them being signaled electronically via high speed data at near the speed of light is 200 milliseconds or more depending on pneumatic valve condition. That 200 millisecond gain in brake response time is the most important and consequential 200 milliseconds of a panic stop/AEB event/ESC event because it's the first 200 milliseconds. The result of that 200 millisecond gain is base/foundation brakes with significantly shorter stopping distances, It also enables Automatic Emergency Braking and Electronic Stability Control systems that function faster and more intelligently. EBS has been in use and saving lives for more than two decades now in Europe. The fact that Electronic Brake Signaling is not mentioned in this rule is a telling testament to either the incompetence or corruption of NHTSA and FMCSA. The simple hard truth is that it's more profitable for billionaires and corporations to pay a corrupted government for the entitlement-in-law to murder random common people on public property than it is to pay for trucks that use mature and current technologies that have proven themselves to be lifesavers. That is exactly why this nation's pneumatic brake heavy trucks have brake systems that are excellent at saving the life of tires but very bad at saving the lives of people. We have heavy trucks that will engine derate and grind to a halt because emission controls are only accomplishing 95% of targeted emissions reduction yet nothing similar for brake systems on 80,000 pound trucks when self monitoring brake systems have been around for some time now. I'm pretty sure that this rule is written in such a way as to be easily shut down by the trucking industry lobby. Diagnostic experience has taught me that corruption is a more likely cause than incompetence for EBS not having been addressed or even mentioned in this rule.