Comment from Paul McEachern
Paul McEachernOpposeIndividual
Summary: The commenter opposes the proposed rulemaking, arguing that the National Highway Traffic Safety Administration's information regarding heavy trailers and AEB systems is "grossly deficient." They argue that the proposal fails to account for the technical requirements of braking on trailing axles and suggests that mandating Electronic Brake Signaling (EBS) would be a more effective safety measure.
National Highway Traffic Safety Administration is proposing mandating Electronic Stability Control (ESC) and Automatic Emergency Braking (AEB) for trucks. The lie told in footnote #4 gets to the root of the issue "This NPRM excludes heavy trailers because they typically do not have braking components necessary for AEB". An AEB system is going to use the brakes on that trailer is it not? Of course it is! Why not tell the American people exactly how long it takes for an AEB system to actually apply the wheel end brakes on the trailing axle of a U.S. specification 53 foot semitrailer? Why not tell the American people why the Electronic Brake Signaling (EBS) found on current technology safe European specification trucks and trailers is going to allow AEB to signal application significantly faster? Why not tell the American people that mandating EBS on U.S. trucks and trailers is going to result in an AEB system that can be calibrated for less false activations? Why ignore those facts and the remainder of the currently available mature safety technologies? Because the information in this rulemaking is so grossly deficient and what little information that is provided at best questionable, it's clear that this rulemaking does not comply with the law as written.