TCIA Files Comments on ELDT Proposed Deadline Extension

Due to unforeseen delays in completing the IT infrastructure of the Training Provider Registry (TPR), the Federal Motor Carrier Safety Administration proposed to extend by two years the compliance dates for the requirement that training providers upload driver-specific training certification information to the TPR” and “the requirement that State Driver Licensing Agencies (SDLAs) confirm driver applicants are in compliance with the ELDT requirements prior to taking a skills test for a Class A or Class B CDL. The result is that effective February 7, 2020, training providers must meet the eligibility requirements, electronically register with the TPR, and remain subject to the documentation and recordkeeping requirements of the final rule, despite FMCSA’s acknowledgement that the TPR will not be able to accept or transmit the ELDT training certification information needed for SDLAs to confirm that drivers are meeting their training requirements nor permit training providers to register electronically.

TCIA’s position is that for FMCSA to create a compliance date for a final rule and then wait until five months prior to that date to inform industry that neither FMCSA nor the SLDAs are ready to uphold their part of the rule places an unanticipated and undue burden on industry, and nullifies all the feasibility analysis FMCSA used to justify this rule in the first place. The FMCSA’s and the SDLAs’ collective ability to track and share information is the very basis for this rule to work. If anything, FMCSA’s idea of delaying enforcement deadlines is exactly backwards: get the IT infrastructure, the TPR and SLDAs running first, then implement the training requirements.

TCIA submitted formal comments that can be viewed here