Comment from Hot Shot Brothers Trucking, LLC

Implementing rules requiring Automatic Emergency Brakes (AEB) on Commercial vehicles is a step in the right direction, with many challenges to overcome. Our current fleet of trucks (International) have AEB installed however, the systems are fundamentally flawed and often create hazardous situations. The system installed on our current fleet also audibly alerts drivers of inadequate braking distance, inadequate height of overhead obstructions (i.e., bridges, tunnels, etc.) and occupying vehicles in passenger side blind spots. The issue with current commercial AEB radar type systems is that environmental conditions, luminescent coatings, alignment, and essentially “Ghost” images, fauna, all affect their performance thereby inducing potential emergency situations. Below are several examples where AEB’s induce dangerous situations. •A commercial traveling at 65 mph, weighting 78,000lbs, needs a minimum greater minimum braking distance than a passenger vehicle. A passenger vehicle passes the commercial vehicle and changes lanes in front of the commercial vehicle, if the distance between the passenger vehicle and the commercial is not adequate, and most often it is not because non-commercially licensed drivers are unaware of the braking distance, the AEB properly works resulting in sudden, unexpected deceleration potentially resulting in load shift, or loss of load. •Commercial proceeds around a curve in the inside lane. The AEB radar identifies another vehicle in the outside lane, at the apex of the corning radius resulting in sudden, unexpected deceleration. •If the AEB radar also includes height obstructions and decelerates, rain, fog, reflective coatings, road elevation changes, all can cause existing systems to immediately decelerate when in fact no obstruction exist. •Fauna often create AEB radar faults resulting in unexpected deceleration. Large mosquitoes, fling birds or bug residue alone over time will cause malfunctions. •Snow and Icing render these devices inoperable. •Reporting above cause-and-effect situations to Original Equipment Manufacturer (OEM) does not result in suitable long-term solutions that fully resolve the issue. If this rule proceeds will its mandate allow a grand-father clause for older vehicles? If so, why? Older trucks are exempt from Electronic Logging Devices (ELD’s) with “Glider kits” market available to avoid using ELD’s. Diesel Exhaust Fluid (DEF) system requirements are another example of exclusions. Both ELD’s and DEF systems were implemented to ensure safety and reduce environmental impacts. Why implement and then exclude? Below are recommendations for consideration of mandatory implementation of AEB systems on commercial vehicles. •Non-class A or B driver's license training and testing (i.e., regular passenger vehicles) need a federally mandated awareness course regarding safe driving requirements around commercial vehicles. •AEB devices alone are not enough, vehicles also need side and rear sensors auditory alerts when their distance is too close in front of the vehicle behind them to allow the trialing vehicle adequate reactionary time to brake in effort to prevent the AEB unnecessary activation. •AEB implementation should have no exceptions, only a grace period before compliance. •OEM’s must develop and test commercial vehicle AEB’s/ Radar to ensure they are not inadvertently activated as per the above examples. I fully support mandating AEB’s on all vehicles, especially commercial vehicles. I believe that many challenges exist with current technology and is adaptation and application as it pertains to commercial vehicles. At present these devices work well in optimal conditions, sub-optimal they are downright scary if activated unexpectedly due to malfunction.