March 17, 2008

Comments on FMCA-2007-27748

Dear Sir/Madam:

On behalf of the Board of Directors of *R.E.A.D.I. Workforce Training
System, Inc*., I would like to comment on the effects of adopting the
FMCSA proposed Minimum Training Requirements for Entry-Level Commercial
Motor Vehicle Operators. I am a licensed CDL driver who has attended a
number of training schools and serve as the Instructor for our CDL
Program. I have conducted both the classroom and the driving portion of
our CDL training program.

From our point of view, we have these comments concerning the FMCSA
proposed Minimum Training Requirements for Entry-Level Commercial Motor
Vehicle Operators:

> [The Demand for Higher Training Standards]{.underline}: At this time,
> we see no demand for a higher standard than is currently required by
> businesses in our region of Montana. Upon passage of the written
> portion of the MVD exam and passing a driving exam, administered by
> the MVD, each employer provides additional experiences for their
> employees (in-house) according to their needs. This is an additional
> training cost covered by the employer and not a tuition cost to the
> student. Additional hours of required training will drive the cost of
> tuition up and reduce the number of individuals seeking the CDL.
> Current wages (\$9.00 -\$12.00 per hour) paid locally; do not justify
> the cost of increased tuition.
>
> [On-line vs. Classroom Training:]{.underline} We encourage you to
> recognize on-line instruction as equivalent to classroom instruction.
> On-line instruction eliminates the cost of travel for the student, the
> cost of an instructor and classroom space for the training agency.
> On-line instruction allows students to study at home, anytime, and
> proceed at their own pace. Research in other areas of study have shown
> that it take more time to complete on-line instruction and the results
> of the training are equal to if not greater than traditional
> instruction. We have a 100 percent passage rate of the written test
> and we estimate that enrollee's spend in excess of 25 hours completing
> on line instruction activities.
>
> [Increased Costs:]{.underline} Increased classroom instruction and
> longer in-cab driving requirements would triple our current basic
> tuition cost of \$1600. Most of our students would not be able
>
> to afford the increased costs and it will be much harder for students
> to get financial support from a variety of federal programs. A number
> of prospective students have declined to enroll based on our present
> fees. We have employers tell us they will put unlicensed drivers
> behind the wheel in rural areas to gain experience, hence creating a
> safety hazard. We are very concerned about the effect that these
> increases will have on the number of unlicensed drivers that will be
> on the road in our rural communities. We fail to see how the increased
> numbers of training hours will benefit the safety and economics of our
> communities.
>
> [Fewer CDL Trainees:]{.underline} The demand for CDL drivers locally
> is high. If trainees cannot afford the cost of training, fewer drivers
> will be in training to meet the demand. Currently, local newspapers
> are filled with ads for CDL certified drivers for local deliveries,
> school buses, and over the road truckers. Fewer licensed drivers will
> have a negative effect on the local economy.
>
> [Training Less Attractive to Employers:]{.underline} Higher tuitions,
> extensive time off for extended training, and disincentives to train
> in-house will make investments in training less attractive to
> employers.
>
> [Certified Instructors:]{.underline} Certified instructors would not
> be needed if on-line instruction is accepted. If certification is
> required, what will be the criteria used to determine if an instructor
> can be certified? Who will train and certify instructors? If all
> training programs must have certified instructors, how long will it
> take to create a large enough group of qualified instructors to serve
> the industry nationwide? How will that serve the needs of the
> industry? If the cost to become certified is forced upon instructors,
> that cost will be passed on in increased tuition costs, reducing the
> number of trained drivers.
>
> [Accreditation:]{.underline} Accreditation does nothing more that
> force all drivers to have the same experiences and skill set as
> beginning drivers. Curriculum needs to be flexible and dynamic to meet
> the needs of local, state and national drivers. Forcing programs like
> ours to meet accreditations standards that were created by someone
> other than local businesses does not benefit anyone. Curriculum must
> be designed to meet the needs of the community.

There are only three companies that provide CDL training in the State of
Montana, not counting in-house training by fleet operators.
Implementation of these proposed standards may eliminate all of these
training programs, hence, negatively impacting Montana's economy and
public safety on the road.

We believe we have a unique, cost effective program that is well adapted
to the needs of the students and employers in our community and fully
satisfies the requirements of the Montana DMV. At this time there has
been no call for anything beyond these requirements.

Again, I urge you to NOT approve the proposed FMCSA increases in
training requirements.

Thank You for Your Time.

Roger Hendrickson, Vice-President

R.E.A.D.I Workforce Training System, Inc.

P.O. Box 1140

Belgrade, MT 59714

<READIWorkforce@hotmail.com>