In recently submitted comments, the National Grain and Feed Association (NGFA) expressed major concerns over significantly increasing current levels of insurance required for motor carriers, and questioned whether doing so would have any demonstrable impact on improving highway safety.

Instead, NGFA urged the U.S. Department of Transportation Federal Motor Carrier Safety Administration's (FMCSA) to forgo issuing such a proposed rule, or "at the very least, evaluate the impacts of additional premium costs on commercial freight transportation" before doing so.

NGFA's comments are in response to a FMCSA request for comments before the agency considers whether to issue a proposed rule. The agency indicated it is considering increasing the current minimum levels of financial responsibility for motor carriers, including liability coverage for bodily injury or property damage; establish financial responsibility requirements for passenger-carrier brokers; implement financial responsibility requirements for brokers and freight forwarders; and revise existing rules concerning self-insurance and trip insurance.

Currently, motor carriers utilizing trucks weighing more than 10,001 pounds are required to carry a minimum of $750,000 in insurance, which covers an accident or harm to a person or property. FMCSA is considering raising that minimum - right now to an undetermined level.

The NGFA said it "values FMCSA's efforts to promote safety on the roadways and supports efforts to keep drivers of commercial motor vehicles operating safely." However, it said that "while safe operation of commercial motor vehicles is in everyone's best interest for myriad reasons, the FMCSA proposal to increase the minimum levels of financial responsibility for motor carriers raises questions as to how this proposal would achieve that objective."

Further, the NGFA said it was "gravely concerned" over the impact a significant increase in financial requirements imposed on motor carriers would have on the availability and cost of truck transportation service for agriculture and other industry sectors. "The impact of such an increase - combined with existing pressures already facing the motor carrier industry (e.g., driver shortages) - will further shrink the availability and increase the cost of truck transportation; impose a hardship on industries such as ours that are reliant on a timely, efficient and cost-effective motor carrier industry; and lead to further consolidation of industries dependent on truck transportation," NGFA said. "Such a development also would have ripple effects on other transportation modes - particularly rail - that already are facing severe capacity constraints and service challenges."

NGFA noted that upwards of 60 percent of the volume of U.S. grains transported are hauled by truck, versus 28 percent for rail and 12 percent for barge.
NGFA is a longtime advocate and supporter of enhancing safety in all facets of the grain, feed and grain processing industry - including truck transportation. Commercial motor vehicles are vitally important to the agricultural industry because of the large volumes of commodities that are handled by truck and the flexibility they provide for transporting agricultural products within rural areas and from rural areas to urban markets.

However, the NGFA noted that factors other than financial requirements influence the safety of U.S. roadways, including such elements as driving conditions related to weather, the condition of roadway surfaces, vehicle maintenance and behavior of other drivers.

As such, according to its statement, "NGFA questions how increasing minimum financial responsibility requirements to an amount above $750,000 will have any effect on safety."

In its statement, NGFA concludes, "if the FMCSA proposal were to be implemented, NGFA believes it could lead to the introduction of higher truck rates and fewer for-hire motor carriers, with no demonstrable improvement in motor carrier safety."

For additional information, see NGFA's full comments.