Alabama Metal Coil Securement Act; Petition for Determination of Preemption, 14403-14405 [2013-05114]
Download as PDF
Federal Register / Vol. 78, No. 43 / Tuesday, March 5, 2013 / Notices
(C) is designed or used to transport
more than 15 passengers, including the
driver, and is not used to transport
passengers for compensation; or
(D) is used in transporting material
found by the Secretary of Transportation
to be hazardous under section 5103 of
this title and transported in a quantity
requiring placarding under regulations
prescribed by the Secretary under
section 5103.’’ (49 CFR 390.5.)
Public Comments Invited
FMCSA requests that you comment
on any aspect of this information
collection, including: (1) Whether the
proposed collection is necessary for
FMCSA to perform its functions, (2) the
accuracy of the estimated burden, (3)
ways for the FMCSA to enhance the
quality, usefulness, and clarity of the
collected information, and (4) ways that
the burden could be minimized without
reducing the quality of the collected
information. The agency will summarize
or include your comments in the request
for OMB’s clearance of this information
collection.
places an unreasonable burden on
interstate commerce.
DATES: This decision is effective April 4,
2013.
FOR FURTHER INFORMATION CONTACT:
Genevieve D. Sapir, Office of the Chief
Counsel, Federal Motor Carrier Safety
Administration, 1200 New Jersey
Avenue SE., Washington, DC 20590,
(202) 366–7056; email
Genevieve.Sapir@dot.gov.
SUPPLEMENTARY INFORMATION:
Federal Motor Carrier Safety
Administration
Electronic Access
You may see all the comments online
through the Federal Document
Management System (FDMS) at https://
www.regulations.gov.
Docket: For access to the docket to
read background documents or
comments, go to https://
www.regulations.gov at time or Room
W12–140 on the ground level of the
West Building, 1200 New Jersey Avenue
SE., Washington, DC, between 9 a.m.
and 5 p.m., Monday through Friday,
except Federal holidays. The FDMS is
available 24 hours each day, 365 days
each year.
Privacy Act: Anyone may search the
electronic form of all comments
received into any of our dockets by the
name of the individual submitting the
comment (or of the person signing the
comment, if submitted on behalf of an
association, business, labor union, etc.).
You may review DOT’s Privacy Act
Statement for the Federal Docket
Management System (FDMS) published
in the Federal Register on December 29,
2010 (75 FR 82132).
[Docket No. FMCSA–2011–0318]
Background
Alabama Metal Coil Securement Act;
Petition for Determination of
Preemption
The Metal Coil Securement Act
The Act, adopted in 2009, prohibits a
motor carrier from transporting metal
coils in a movement that originates or
terminates in Alabama unless the driver
is certified in load securement (Ala.
Code § 32–9A–2(a)(4)a.). The law, as
originally enacted, also required the
driver to carry a copy of the certification
in the vehicle and produce it upon
demand (Ala. Code § 32–9A–2(a)(4)b.).
Maximum penalties for violating these
requirements include fines of between
$5,000 and $10,000, jail time and/or a
court order prohibiting the driver from
operating a CMV in the State (Ala. Code
§ 32–9A–4(d)—(g)). Alabama
Promulgated Rule No. 760–X–1–.16,
adopted on April 5, 2011, offers CMV
drivers three options to become certified
in load securement: (1) Obtain a Metal
Coil Certificate by taking and passing
the ‘‘Securing Metal Coils Course’’
available for $25.00 on the web site,
www.metalcoiltraining.com; (2) obtain a
Issued on: February 26, 2013.
G. Kelly Leone,
Associate Administrator, Office of Research
and Information Technology and Chief
Information Officer.
[FR Doc. 2013–05092 Filed 3–4–13; 8:45 am]
BILLING CODE 4910–EX–P
DEPARTMENT OF TRANSPORTATION
Federal Motor Carrier Safety
Administration (FMCSA), Department
of Transportation (DOT).
ACTION: Order; Grant of Petition for
Determination of Preemption.
emcdonald on DSK67QTVN1PROD with NOTICES
AGENCY:
SUMMARY: FMCSA grants a petition
submitted by the American Trucking
Associations (ATA) requesting a
determination that the State of
Alabama’s Metal Coil Securement Act
(the Act) is preempted by Federal law.
Federal law provides for preemption of
State commercial motor vehicle (CMV)
safety laws that are more stringent than
Federal regulations and (1) Have no
safety benefit; (2) are incompatible with
Federal regulations; or (3) would cause
an unreasonable burden on interstate
commerce. FMCSA has determined that
there is insufficient support for the
claimed safety benefits and that the Act
VerDate Mar<15>2010
15:14 Mar 04, 2013
Jkt 229001
PO 00000
Frm 00140
Fmt 4703
Sfmt 4703
14403
commercial driver’s license (CDL)
endorsement that allows the driver to
haul metal coils in the issuing State; or
(3) obtain a Metal Coil Certificate from
a motor carrier authorized by the
Alabama Department of Public Safety
(ADPS) to issue the Certificate, which
would require the carrier’s safety
compliance officer to submit a notarized
affidavit that he/she has personal
knowledge that the carrier requires
every driver to be trained in the
requirements of 49 CFR 393.120 before
hauling metal coils. Federal regulations
for securing metal coil loads, codified in
49 CFR 393.120, do not require any such
driver certification.
In June 2011, Alabama amended the
Act, rescinding the requirement that
drivers carry copies of their metal coil
load securement certification in their
vehicles. Currently, the Act continues to
require drivers to obtain certification, as
specified in Alabama Promulgated Rule
No. 760–X–1–.16, but drivers are no
longer required to produce the
certification upon demand.
FMCSA and ATA Responses
On June 26, 2009, FMCSA sent a letter
to then-Governor Bob Riley of Alabama
stating that the Act appeared to be
incompatible with the requirements of
FMCSA’s Motor Carrier Safety
Assistance Program. FMCSA also drew
attention to two Federal laws
authorizing preemption of State
legislation (49 U.S.C. 14506 and 31141)
and indicated that they might be
applicable. The Agency urged State
officials to work together with FMCSA
officials to resolve any conflict between
State and Federal law. Governor Riley
responded on August 26, 2009,
explaining that the Act was adopted in
response to a number of accidents in
Alabama involving the transport of
metal coils. Governor Riley took the
position that Alabama’s metal coil load
securement certification requirements
were not preempted by Federal law.
On December 22, 2010, ATA
petitioned FMCSA for a determination
that Alabama’s metal coil load
securement certification requirements
and penalties create an unreasonable
burden on interstate commerce and are
preempted under 49 U.S.C. 31141. ATA
contended that Alabama’s requirement
that drivers obtain certification in metal
coil load securement is more stringent
than and incompatible with Federal
metal coil safety regulations.
In its December 22, 2010 letter, ATA
also requested a determination that the
requirement that the driver carry the
certification and display it upon
demand is preempted by 49 U.S.C.
14506. The recent amendment to the
E:\FR\FM\05MRN1.SGM
05MRN1
14404
Federal Register / Vol. 78, No. 43 / Tuesday, March 5, 2013 / Notices
emcdonald on DSK67QTVN1PROD with NOTICES
Act, however, removed this
requirement, rendering this aspect of
ATA’s request moot.
By letter dated January 25, 2011, the
ADPS responded to ATA’s petition.
ADPS acknowledged that the
requirements of the Act are more
stringent than Federal regulations, but
stated that the requirements should not
be preempted because they have safety
benefits and do not place an
unreasonable burden on interstate
commerce.
Applicable Law
Section 31141 of title 49, United
States Code, prohibits States from
enforcing a law or regulation on CMV
safety that the Secretary of
Transportation (Secretary) has
determined to be preempted. To
determine whether a State law or
regulation is preempted, the Secretary
must decide whether a State law or
regulation: (1) Has the same effect as a
regulation prescribed under 49 U.S.C.
31136, which is the authority for much
of the Federal Motor Carrier Safety
Regulations (FMCSRs); (2) is less
stringent than such a regulation; or (3)
is additional to or more stringent than
such a regulation (49 U.S.C.
31141(c)(1)). If the Secretary determines
that a State law or regulation has the
same effect as a regulation based on
§ 31136, it may be enforced (49 U.S.C.
31141(c)(2)). A State law or regulation
that is less stringent may not be
enforced (49 U.S.C. 31141(c)(3)). And a
State law or regulation the Secretary
determined to be additional to or more
stringent than a regulation based on
§ 31136 may be enforced unless the
Secretary decides that the State law or
regulation (1) Has no safety benefit; (2)
is incompatible with the regulation
prescribed by the Secretary; or (3)
would cause an unreasonable burden on
interstate commerce (49 U.S.C.
31141(c)(4)). To determine whether a
State law or regulation will cause an
unreasonable burden on interstate
commerce, the Secretary may consider
the cumulative effect that the State’s law
or regulation and all similar laws and
regulations of other States will have on
interstate commerce (49 U.S.C.
31141(c)(5)). The Secretary’s authority
under § 31141 is delegated to the
FMCSA Administrator by 49 CFR
1.87(f).
Comments
FMCSA published a notice in the
Federal Register on November 23, 2011
(76 FR 72495) seeking comment on
whether the Act is preempted by
Federal law. Although preemption
under § 31141 is a legal determination
VerDate Mar<15>2010
15:14 Mar 04, 2013
Jkt 229001
reserved to the judgment of the Agency,
FMCSA sought comment on what effect,
if any, Alabama’s metal coil load
securement certification requirement
has on interstate motor carrier
operations. FMCSA received thirteen
comments in response. The five
comments opposing preemption
included one each from an individual
driver, a motor carrier, Advocates for
Highway and Auto Safety (AHAS), the
Alabama Trucking Association and the
ADPS. The eight comments supporting
the preemption petition included four
from motor carriers, and one each from
an owner-operator, ATA, an Alabama
aluminum coil producer and the OwnerOperators Independent Drivers
Association (OOIDA).
Commenters opposing the petition
stated that the Act is appropriate
because there is a lack of Federal
enforcement of training requirements;
cargo load securement is a leading cause
of crashes; and there have not been any
metal coil spills in Alabama since the
Act was enacted. Commenters
supporting the petition stated that the
Act should be preempted because it is
simply an administrative requirement
and does not have safety benefits; it
imposes costs on the motor carrier and
metal coil industries; it is likely to lead
to a proliferation of other State
requirements with burdensome
cumulative effects; it unfairly affects
less-than-truckload (LTL) carriers; and
safety risks other than improper load
securement (such as excessive speed at
a crash-prone Interstate highway
junction) are contributing factors to the
coil spills cited as justification for the
Act.
Decision
The Agency concludes that the Act
does not meet the standards set forth in
49 U.S.C. 31141 and may not be
enforced. The Act imposes certification
requirements on interstate CMV drivers
that are not required under FMCSA’s
regulations. As a result, and as the
ADPS has acknowledged, the Act
imposes requirements more stringent
than those imposed by Federal law. The
only remaining issue, therefore, is
whether the Act (1) Has a safety benefit;
(2) is incompatible with FMCSA’s
regulations; or (3) would cause an
unreasonable burden on interstate
commerce. The Agency concludes that
there is insufficient support for the
claimed safety benefits and that the Act
places an unreasonable burden on
interstate commerce.
Although several commenters argued
that the Act’s requirements have safety
benefits, the only evidence presented—
by ADPS—was a paper showing that
PO 00000
Frm 00141
Fmt 4703
Sfmt 4703
there were eight metal coil spills in
Jefferson County (i.e., the Birmingham
area) in the three years prior to adoption
of the Act and apparently none
thereafter. ADPS implied that there was
a correlation between reduced crashes
and the adoption of the Act, but that is
easier to assume than to demonstrate.
For example, other commenters
observed that the majority of the metal
coil spills that occurred in Alabama
were at ‘‘Malfunction Junction,’’ a
particularly dangerous Interstate
highway junction in Birmingham, and
that speed was a factor in many of these
spills. They also commented that in
2007, the State reduced the speed limit
at this junction in an effort to reduce
crashes. Crashes typically have multiple
causes; determining the ‘‘basic’’ cause is
therefore difficult, if not impossible.
Identifying the reason or reasons for a
reduction in crashes is even more
problematic, especially when the annual
number of incidents—like those
involving metal coils in Alabama—is
small enough to be affected significantly
by random variations. Given the variety
of factors that may have contributed
both to the occurrence of and reduction
in metal coil spills, attributing the
reduction to a single piece of legislation
is unwarranted.
In addition, the Act’s requirements
are largely administrative; Alabama
does not test a driver’s skills in securing
a load. As one commenter observed, in
the case of the on-line certification
option, there is no way of determining
whether the person taking the test is
even the driver being certified. In the
case of motor carrier certification
option, individual drivers are not tested;
the motor carrier simply certifies that its
drivers have been trained in the Federal
regulations. In either case, all the driver
or motor carrier is required to do is
demonstrate knowledge of Federal
regulations—knowledge the driver is
required to have in any case. (See 49
CFR 390.3(e)(1)–(2)). In short, the Act
imposes costs on interstate carriers and
drivers that are not commensurate with
any readily identifiable safety benefits.
Moreover, not preempting the Act
could have wide-ranging implications.
For example, an individual driver
commented that he was required to
obtain an Alabama Metal Coil Certificate
before being hired by a Minnesota-based
motor carrier. Although the carrier did
not haul coils into or out of Alabama,
it apparently wanted to be prepared to
handle that kind of business should the
opportunity arise. Similarly, two LTL
motor carriers stated that, because of the
nature of their business, they would
require all drivers to obtain an Alabama
Metal Coil Certificate to cover the
E:\FR\FM\05MRN1.SGM
05MRN1
Federal Register / Vol. 78, No. 43 / Tuesday, March 5, 2013 / Notices
possibility that a driver would be asked
to transport a load of metal coils in or
out of Alabama at some point during
their employment. The ripple effect of
the Act in imposing both potential
burdens and costs beyond dedicated
metal-coil transporters is extensive.
Finally, the cumulative effect of
multiple States requiring their own
metal-coil certifications, each with an
associated fee, would create an even
more unreasonable burden on interstate
commerce. Several commenters noted
that other States have metal coil
certification requirements, but that they
apply only to intrastate operations. If
these and other States extended their
metal coil certification requirements to
interstate carriers, the effect would be a
patchwork of requirements, with
accompanying burdens and costs.
Conclusion
Accordingly, FMCSA grants ATA’s
petition for preemption. Alabama may
no longer enforce the Act on interstate
motor carriers.
Issued on: February 27, 2013.
Anne S. Ferro,
Administrator.
[FR Doc. 2013–05114 Filed 3–4–13; 8:45 am]
BILLING CODE 4910–EX–P
DEPARTMENT OF TRANSPORTATION
Federal Motor Carrier Safety
Administration
[Docket No. FMCSA–2013–0023]
Qualification of Drivers; Exemption
Applications; Vision
Federal Motor Carrier Safety
Administration (FMCSA), DOT.
ACTION: Notice of applications for
exemptions; request for comments.
emcdonald on DSK67QTVN1PROD with NOTICES
AGENCY:
SUMMARY: FMCSA announces receipt of
applications from 3 individuals for
exemption from the vision requirement
in the Federal Motor Carrier Safety
Regulations. They are unable to meet
the vision requirement in one eye for
various reasons. The exemptions will
enable these individuals to operate
commercial motor vehicles (CMVs) in
interstate commerce without meeting
the prescribed vision requirement in
one eye. If granted, the exemptions
would enable these individuals to
qualify as drivers of commercial motor
vehicles (CMVs) in interstate commerce.
DATES: Comments must be received on
or before April 4, 2013.
ADDRESSES: You may submit comments
bearing the Federal Docket Management
System (FDMS) Docket No. FMCSA–
VerDate Mar<15>2010
15:14 Mar 04, 2013
Jkt 229001
2013–0023 using any of the following
methods:
• Federal eRulemaking Portal: Go to
https://www.regulations.gov. Follow the
on-line instructions for submitting
comments.
• Mail: Docket Management Facility;
U.S. Department of Transportation, 1200
New Jersey Avenue SE., West Building
Ground Floor, Room W12–140,
Washington, DC 20590–0001.
• Hand Delivery: West Building
Ground Floor, Room W12–140, 1200
New Jersey Avenue SE., Washington,
DC, between 9 a.m. and 5 p.m., Monday
through Friday, except Federal
Holidays.
• Fax: 1–202–493–2251.
Instructions: Each submission must
include the Agency name and the
docket numbers for this notice. Note
that all comments received will be
posted without change to https://
www.regulations.gov, including any
personal information provided. Please
see the Privacy Act heading below for
further information.
Docket: For access to the docket to
read background documents or
comments, go to https://
www.regulations.gov at any time or
Room W12–140 on the ground level of
the West Building, 1200 New Jersey
Avenue SE., Washington, DC, between 9
a.m. and 5 p.m., Monday through
Friday, except Federal holidays. The
FDMS is available 24 hours each day,
365 days each year. If you want
acknowledgment that we received your
comments, please include a selfaddressed, stamped envelope or
postcard or print the acknowledgement
page that appears after submitting
comments on-line.
Privacy Act: Anyone may search the
electronic form of all comments
received into any of our dockets by the
name of the individual submitting the
comment (or of the person signing the
comment, if submitted on behalf of an
association, business, labor union, etc.).
You may review DOT’s Privacy Act
Statement for the Federal Docket
Management System (FDMS) published
in the Federal Register on December 29,
2010 (75 FR 82132), or you may visit
https://www.gpo.gov/fdsys/pkg/FR-201012-29/pdf/2010-32876.pdf.
FOR FURTHER INFORMATION CONTACT:
Elaine M. Papp, Chief, Medical
Programs Division, (202) 366–4001,
fmcsamedical@dot.gov, FMCSA,
Department of Transportation, 1200
New Jersey Avenue SE., Room W64–
224, Washington, DC 20590–0001.
Office hours are from 8:30 a.m. to 5
p.m., Monday through Friday, except
Federal holidays.
PO 00000
Frm 00142
Fmt 4703
Sfmt 4703
14405
SUPPLEMENTARY INFORMATION:
Background
Under 49 U.S.C. 31136(e) and 31315,
FMCSA may grant an exemption from
the Federal Motor Carrier Safety
Regulations for a 2-year period if it finds
‘‘such exemption would likely achieve a
level of safety that is equivalent to or
greater than the level that would be
achieved absent such exemption.’’
FMCSA can renew exemptions at the
end of each 2-year period. The 3
individuals listed in this notice have
each requested such an exemption from
the vision requirement in 49 CFR
391.41(b)(10), which applies to drivers
of CMVs in interstate commerce.
Accordingly, the Agency will evaluate
the qualifications of each applicant to
determine whether granting an
exemption will achieve the required
level of safety mandated by statute.
Qualifications of Applicants
David Doub
Mr. Doub, 68, has had a retinal
detachment in his right eye since 2009.
The visual acuity in his right eye is 20/
400, and in his left eye, 20/20.
Following an examination in 2012, his
ophthalmologist noted, ‘‘Has sufficient
vision left eye to operate commercial
vehicle.’’ Mr. Doub reported that he has
driven tractor-trailer combinations for
31 years, accumulating 621,000 miles.
He holds an operator’s license from
Indiana. His driving record for the last
3 years shows no crashes and no
convictions for moving violations in a
CMV.
Gregory S. Engleman
Mr. Engleman, 43, has had optic
neuritis in his right eye since 2001. The
visual acuity in his right eye is 20/200,
and in his left eye, 20/20. Following an
examination in 2012, his optometrist
noted, ‘‘It is my opinion that Mr.
Engleman has sufficient vision to
operate a commercial vehicle.’’ Mr.
Engleman reported that he has driven
straight trucks for 7 years, accumulating
245,000 miles, tractor-trailer
combinations for 19 years, accumulating
2.1 million miles. He holds a Class D
Commercial Driver’s License (CDL) from
Kentucky. His driving record for the last
3 years shows no crashes but one
conviction for moving violations in a
CMV; he violated the 14 hour rule.
Gale Smith
Mr. Smith, age 45, has a prosthetic left
eye due to a traumatic incident during
childhood. The best corrected visual
acuity in his right eye is 20/20, and in
his left eye, no light perception.
Following an examination in 2013, his
E:\FR\FM\05MRN1.SGM
05MRN1
Agencies
[Federal Register Volume 78, Number 43 (Tuesday, March 5, 2013)]
[Notices]
[Pages 14403-14405]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-05114]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
Federal Motor Carrier Safety Administration
[Docket No. FMCSA-2011-0318]
Alabama Metal Coil Securement Act; Petition for Determination of
Preemption
AGENCY: Federal Motor Carrier Safety Administration (FMCSA), Department
of Transportation (DOT).
ACTION: Order; Grant of Petition for Determination of Preemption.
-----------------------------------------------------------------------
SUMMARY: FMCSA grants a petition submitted by the American Trucking
Associations (ATA) requesting a determination that the State of
Alabama's Metal Coil Securement Act (the Act) is preempted by Federal
law. Federal law provides for preemption of State commercial motor
vehicle (CMV) safety laws that are more stringent than Federal
regulations and (1) Have no safety benefit; (2) are incompatible with
Federal regulations; or (3) would cause an unreasonable burden on
interstate commerce. FMCSA has determined that there is insufficient
support for the claimed safety benefits and that the Act places an
unreasonable burden on interstate commerce.
DATES: This decision is effective April 4, 2013.
FOR FURTHER INFORMATION CONTACT: Genevieve D. Sapir, Office of the
Chief Counsel, Federal Motor Carrier Safety Administration, 1200 New
Jersey Avenue SE., Washington, DC 20590, (202) 366-7056; email
Genevieve.Sapir@dot.gov.
SUPPLEMENTARY INFORMATION:
Electronic Access
You may see all the comments online through the Federal Document
Management System (FDMS) at https://www.regulations.gov.
Docket: For access to the docket to read background documents or
comments, go to https://www.regulations.gov at time or Room W12-140 on
the ground level of the West Building, 1200 New Jersey Avenue SE.,
Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday,
except Federal holidays. The FDMS is available 24 hours each day, 365
days each year.
Privacy Act: Anyone may search the electronic form of all comments
received into any of our dockets by the name of the individual
submitting the comment (or of the person signing the comment, if
submitted on behalf of an association, business, labor union, etc.).
You may review DOT's Privacy Act Statement for the Federal Docket
Management System (FDMS) published in the Federal Register on December
29, 2010 (75 FR 82132).
Background
The Metal Coil Securement Act
The Act, adopted in 2009, prohibits a motor carrier from
transporting metal coils in a movement that originates or terminates in
Alabama unless the driver is certified in load securement (Ala. Code
Sec. 32-9A-2(a)(4)a.). The law, as originally enacted, also required
the driver to carry a copy of the certification in the vehicle and
produce it upon demand (Ala. Code Sec. 32-9A-2(a)(4)b.). Maximum
penalties for violating these requirements include fines of between
$5,000 and $10,000, jail time and/or a court order prohibiting the
driver from operating a CMV in the State (Ala. Code Sec. 32-9A-4(d)--
(g)). Alabama Promulgated Rule No. 760-X-1-.16, adopted on April 5,
2011, offers CMV drivers three options to become certified in load
securement: (1) Obtain a Metal Coil Certificate by taking and passing
the ``Securing Metal Coils Course'' available for $25.00 on the web
site, www.metalcoiltraining.com; (2) obtain a commercial driver's
license (CDL) endorsement that allows the driver to haul metal coils in
the issuing State; or (3) obtain a Metal Coil Certificate from a motor
carrier authorized by the Alabama Department of Public Safety (ADPS) to
issue the Certificate, which would require the carrier's safety
compliance officer to submit a notarized affidavit that he/she has
personal knowledge that the carrier requires every driver to be trained
in the requirements of 49 CFR 393.120 before hauling metal coils.
Federal regulations for securing metal coil loads, codified in 49 CFR
393.120, do not require any such driver certification.
In June 2011, Alabama amended the Act, rescinding the requirement
that drivers carry copies of their metal coil load securement
certification in their vehicles. Currently, the Act continues to
require drivers to obtain certification, as specified in Alabama
Promulgated Rule No. 760-X-1-.16, but drivers are no longer required to
produce the certification upon demand.
FMCSA and ATA Responses
On June 26, 2009, FMCSA sent a letter to then-Governor Bob Riley of
Alabama stating that the Act appeared to be incompatible with the
requirements of FMCSA's Motor Carrier Safety Assistance Program. FMCSA
also drew attention to two Federal laws authorizing preemption of State
legislation (49 U.S.C. 14506 and 31141) and indicated that they might
be applicable. The Agency urged State officials to work together with
FMCSA officials to resolve any conflict between State and Federal law.
Governor Riley responded on August 26, 2009, explaining that the Act
was adopted in response to a number of accidents in Alabama involving
the transport of metal coils. Governor Riley took the position that
Alabama's metal coil load securement certification requirements were
not preempted by Federal law.
On December 22, 2010, ATA petitioned FMCSA for a determination that
Alabama's metal coil load securement certification requirements and
penalties create an unreasonable burden on interstate commerce and are
preempted under 49 U.S.C. 31141. ATA contended that Alabama's
requirement that drivers obtain certification in metal coil load
securement is more stringent than and incompatible with Federal metal
coil safety regulations.
In its December 22, 2010 letter, ATA also requested a determination
that the requirement that the driver carry the certification and
display it upon demand is preempted by 49 U.S.C. 14506. The recent
amendment to the
[[Page 14404]]
Act, however, removed this requirement, rendering this aspect of ATA's
request moot.
By letter dated January 25, 2011, the ADPS responded to ATA's
petition. ADPS acknowledged that the requirements of the Act are more
stringent than Federal regulations, but stated that the requirements
should not be preempted because they have safety benefits and do not
place an unreasonable burden on interstate commerce.
Applicable Law
Section 31141 of title 49, United States Code, prohibits States
from enforcing a law or regulation on CMV safety that the Secretary of
Transportation (Secretary) has determined to be preempted. To determine
whether a State law or regulation is preempted, the Secretary must
decide whether a State law or regulation: (1) Has the same effect as a
regulation prescribed under 49 U.S.C. 31136, which is the authority for
much of the Federal Motor Carrier Safety Regulations (FMCSRs); (2) is
less stringent than such a regulation; or (3) is additional to or more
stringent than such a regulation (49 U.S.C. 31141(c)(1)). If the
Secretary determines that a State law or regulation has the same effect
as a regulation based on Sec. 31136, it may be enforced (49 U.S.C.
31141(c)(2)). A State law or regulation that is less stringent may not
be enforced (49 U.S.C. 31141(c)(3)). And a State law or regulation the
Secretary determined to be additional to or more stringent than a
regulation based on Sec. 31136 may be enforced unless the Secretary
decides that the State law or regulation (1) Has no safety benefit; (2)
is incompatible with the regulation prescribed by the Secretary; or (3)
would cause an unreasonable burden on interstate commerce (49 U.S.C.
31141(c)(4)). To determine whether a State law or regulation will cause
an unreasonable burden on interstate commerce, the Secretary may
consider the cumulative effect that the State's law or regulation and
all similar laws and regulations of other States will have on
interstate commerce (49 U.S.C. 31141(c)(5)). The Secretary's authority
under Sec. 31141 is delegated to the FMCSA Administrator by 49 CFR
1.87(f).
Comments
FMCSA published a notice in the Federal Register on November 23,
2011 (76 FR 72495) seeking comment on whether the Act is preempted by
Federal law. Although preemption under Sec. 31141 is a legal
determination reserved to the judgment of the Agency, FMCSA sought
comment on what effect, if any, Alabama's metal coil load securement
certification requirement has on interstate motor carrier operations.
FMCSA received thirteen comments in response. The five comments
opposing preemption included one each from an individual driver, a
motor carrier, Advocates for Highway and Auto Safety (AHAS), the
Alabama Trucking Association and the ADPS. The eight comments
supporting the preemption petition included four from motor carriers,
and one each from an owner-operator, ATA, an Alabama aluminum coil
producer and the Owner-Operators Independent Drivers Association
(OOIDA).
Commenters opposing the petition stated that the Act is appropriate
because there is a lack of Federal enforcement of training
requirements; cargo load securement is a leading cause of crashes; and
there have not been any metal coil spills in Alabama since the Act was
enacted. Commenters supporting the petition stated that the Act should
be preempted because it is simply an administrative requirement and
does not have safety benefits; it imposes costs on the motor carrier
and metal coil industries; it is likely to lead to a proliferation of
other State requirements with burdensome cumulative effects; it
unfairly affects less-than-truckload (LTL) carriers; and safety risks
other than improper load securement (such as excessive speed at a
crash-prone Interstate highway junction) are contributing factors to
the coil spills cited as justification for the Act.
Decision
The Agency concludes that the Act does not meet the standards set
forth in 49 U.S.C. 31141 and may not be enforced. The Act imposes
certification requirements on interstate CMV drivers that are not
required under FMCSA's regulations. As a result, and as the ADPS has
acknowledged, the Act imposes requirements more stringent than those
imposed by Federal law. The only remaining issue, therefore, is whether
the Act (1) Has a safety benefit; (2) is incompatible with FMCSA's
regulations; or (3) would cause an unreasonable burden on interstate
commerce. The Agency concludes that there is insufficient support for
the claimed safety benefits and that the Act places an unreasonable
burden on interstate commerce.
Although several commenters argued that the Act's requirements have
safety benefits, the only evidence presented--by ADPS--was a paper
showing that there were eight metal coil spills in Jefferson County
(i.e., the Birmingham area) in the three years prior to adoption of the
Act and apparently none thereafter. ADPS implied that there was a
correlation between reduced crashes and the adoption of the Act, but
that is easier to assume than to demonstrate. For example, other
commenters observed that the majority of the metal coil spills that
occurred in Alabama were at ``Malfunction Junction,'' a particularly
dangerous Interstate highway junction in Birmingham, and that speed was
a factor in many of these spills. They also commented that in 2007, the
State reduced the speed limit at this junction in an effort to reduce
crashes. Crashes typically have multiple causes; determining the
``basic'' cause is therefore difficult, if not impossible. Identifying
the reason or reasons for a reduction in crashes is even more
problematic, especially when the annual number of incidents--like those
involving metal coils in Alabama--is small enough to be affected
significantly by random variations. Given the variety of factors that
may have contributed both to the occurrence of and reduction in metal
coil spills, attributing the reduction to a single piece of legislation
is unwarranted.
In addition, the Act's requirements are largely administrative;
Alabama does not test a driver's skills in securing a load. As one
commenter observed, in the case of the on-line certification option,
there is no way of determining whether the person taking the test is
even the driver being certified. In the case of motor carrier
certification option, individual drivers are not tested; the motor
carrier simply certifies that its drivers have been trained in the
Federal regulations. In either case, all the driver or motor carrier is
required to do is demonstrate knowledge of Federal regulations--
knowledge the driver is required to have in any case. (See 49 CFR
390.3(e)(1)-(2)). In short, the Act imposes costs on interstate
carriers and drivers that are not commensurate with any readily
identifiable safety benefits.
Moreover, not preempting the Act could have wide-ranging
implications. For example, an individual driver commented that he was
required to obtain an Alabama Metal Coil Certificate before being hired
by a Minnesota-based motor carrier. Although the carrier did not haul
coils into or out of Alabama, it apparently wanted to be prepared to
handle that kind of business should the opportunity arise. Similarly,
two LTL motor carriers stated that, because of the nature of their
business, they would require all drivers to obtain an Alabama Metal
Coil Certificate to cover the
[[Page 14405]]
possibility that a driver would be asked to transport a load of metal
coils in or out of Alabama at some point during their employment. The
ripple effect of the Act in imposing both potential burdens and costs
beyond dedicated metal-coil transporters is extensive.
Finally, the cumulative effect of multiple States requiring their
own metal-coil certifications, each with an associated fee, would
create an even more unreasonable burden on interstate commerce. Several
commenters noted that other States have metal coil certification
requirements, but that they apply only to intrastate operations. If
these and other States extended their metal coil certification
requirements to interstate carriers, the effect would be a patchwork of
requirements, with accompanying burdens and costs.
Conclusion
Accordingly, FMCSA grants ATA's petition for preemption. Alabama
may no longer enforce the Act on interstate motor carriers.
Issued on: February 27, 2013.
Anne S. Ferro,
Administrator.
[FR Doc. 2013-05114 Filed 3-4-13; 8:45 am]
BILLING CODE 4910-EX-P