ARA Submits Comments to DOT on FMCS Regulation in Agriculture
Aug 01 2011
ARA submits comments to the Department of Transportation (DOT) regarding the Federal Motor Carrier Safety Administration’s Regulatory Guidance for Agriculture. ARA commented on the applicability of the FMCSR to operators of certain farm vehicles and off-road agricultural equipment. Specifically, that implements of husbandry have guidelines that encompass the broad scope of agriculture, that it should not be a commercial motor vehicle (“CMV”), and the distinction between inter- or intrastate commerce is unnecessary with farm vehicles. Additionally, the transportation of grain to a grain elevator is not subject to CMV permitting when the farmer intends to sell to an in-state grain elevator.
Recent Comments and Testimony
ARA Joins Coalition Comments to OSHA regarding Proposed Rulemaking on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings
ARA Submits Comments to USDA-NRCS RFI on Climate Change Mitigation and Adaptation
ARA Joins Coalition Comments to EPA on Draft Insecticide Strategy
ARA Filed Comments to USDA NRCS on SUSTAINS Act Implementation