Regulatory and Legislative Correspondence 2022

Sometimes we’re asked how actively we advocate on behalf of our small trucking companies – both NASTC members and non-members.

Below is an activity summary of actions taken, comments made, or letters written by NASTC on your behalf in 2022:

NASTC Correspondence and Public Comments Filed With Regulators

California Air Resources Board
Coalition letter led by Western States Trucking Association with 27 signatories, requesting a delay in a regulatory deadline due to supply chain shortages of requisites parts (sent March 11)

Environmental Protection Agency
Comments regarding a proposed rule titled “Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards,” Docket No. EPA-HQ-OAR-2019-0055 (sent May 10)

Federal Motor Carrier Safety Administration (FMCSA)
Letter of support for the appointment of Henry E. Seaton, Esq., to the Truck Leasing Task Force (sent May 13)

FMCSA
Comments regarding advance notice of supplemental proposed rulemaking (SNPRM), titled “Parts and Accessories Necessary for Safe Operations: Speed Limiting Devices,” Docket Number FMCSA-2022- 0004-0001, reviving withdrawn speed limiter rule (sent June 22)

FMCSA
Comments, led by Hank Seaton and signed by 13 trucking groups, responding to “Request for Comments on Definitions of Broker and Bona Fide Agents,” Docket No. FMCSA-2022-0134 (submitted July 11)

FMCSA
Comments regarding Trucking Alliance request for exemption to report positive hair drug tests, Document No. FMCSA-2022- 0127 (submitted Sept. 16)

FMCSA
Comments regarding “Qualifications of Drivers: Medical Examiner’s Handbook and Medical Advisory Criteria Proposed Regulatory Guidance,” Docket No. FMCSA-20 22-0111 (submitted Sept. 16)

FMCSA
Letter of congratulations and introduction to Administrator Robin Hutcheson (sent Oct. 26)

National Labor Relations Board
Comments, led by Hank Seaton and signed by 13 trucking groups, regarding “Standard for Determining Joint-Employer Status,” Docket No. NLRB-2022-0001-0001 (submitted Dec. 7)

Department of Labor
Comments, led by Hank Seaton and signed by 13 trucking groups, regarding “Employee or Independent Contractor Classification Under the Fair Labor Standards Act,” RIN No. 1235-AA34 (submitted Dec. 13)

NASTC Correspondence Sent to Legislators

Sen. Joe Manchin
Letter thanking Sen. Manchin for opposing elimination of the filibuster (sent Jan. 18)

Sen. Kyrsten Sinema
Letter thanking Sen. Sinema for opposing elimination of the filibuster (sent Jan. 18)

U.S. Senate Leaders Chuck Schumer and Mitch McConnell
Coalition letter of NASTC and 12 trucking organizations expressing opposition to the nomination of David Weil to head the U.S. Department of Labor Wage and Hour Division (sent Feb. 9)

U.S. Senate and House Members and Transportation Committees Staff
Expressing opposition to suspending collection of the federal fuel tax as a political gimmick that will not stem inflation but would forego $20 billion that would go into the underfunded Highway Trust Fund (sent Feb. 22)

Senators Mike Braun, Pat Toomey, Richard Burr, and Mike Crapo
Individual letters thanking each of these Senators for their writing Securities and Exchange Commission Chairman Gary Gensler urging him not to engage in human capital rulemaking that amounts to SEC regulation of independent contracting (sent March 3)

Sen. Joe Manchin
Letter thanking Sen. Manchin for opposing budget reconciliation’s including of 3.8% NIIT tax expansion to passthrough businesses taxing active business revenue (sent July 19)

Rep. Mike Bost
Letter of support for H.R. 2187, the Truck Parking Safety Improvement Act (sent July 19)

U.S. Senators
Letter expressing opposition to the Senate’s FY22 budget reconciliation legislation (sent August 2)

U.S. Representatives
Letter expressing opposition to the Senate’s FY22 budget reconciliation legislation (sent August 10)

Sens. Cynthia Lummis and Mark Kelly
Letter of support for the Truck Parking Safety Improvement Act (sent December 7)