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March 4, 2008

Docket #FMCSA-2007-27748

Docket Management Facility

U.S. Department of Transportation

Room W 12-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590-0001

**Re: Notice of Proposed Rulemaking: *Minimum Training Requirements for
Entry- Level Commercial Vehicle Operators***

Dear Sir/Madam:

Professional Wireline Rentals, LLC is writing to express a number of
serious concerns with the Federal Motor Carrier Administration's notice
of proposed rulemaking (NPRM): "Minimum Training Requirements for
Entry-Level Commercial Vehicle Operators." Although our company supports
an enhanced driver training rule, the provisions of THIS proposed rule
are untenable and would seriously hamper my company's ability to recruit
new drivers.

Professional Wireline Rentals, LLC provides rental tools, equipment and
personnel used to support oil and gas drilling and well servicing
operations. We use our trucks to transport the tools we rent to the
various well site locations that we help support. We are a private
carrier and operate 51 regulated trucks, 37 trailers and employ 60
qualified drivers. We are continuing to grow as a company and expect to
double the number of drivers over the next 3-5 years. We do hire
experienced drivers from time to time; however we typically assist as
many employees as we can in obtaining their commercial license even
though they were not originally hired as drivers. Currently, we provide
the entry level driver training as outlined in Part 380.503. This
training is provided by an in-house instructor with 18 years experience.
Under the proposed rule, we would no longer be able to provide in-house
training -- adding to the expense of our operation and limiting the
availability of qualified prospective drivers.

The accreditation process and the hours-based training requirements in
the proposed rule are arbitrary and capricious. The accreditation
requirements, as proposed, are onerous, costly and would undermine the
ability of my company to recruit and train entry-level drivers. Further,
the proposed rule fails to link any safety benefit to its 120
hours-based training standards. The appropriate amount of time necessary
for driver training cannot be determined unless or until truck driver
training hours have been properly validated. FMCSA has not done this.

In my opinion, the proposed accreditation requirements will have a
negative impact on our fleet operations by greatly increasing the costs
of our fleet operations. This rule would also decrease the number of
qualified drivers available for hire and limit the number of training
centers and consultants qualified to teach the 120 hour course.
Implementing this rule would be detrimental to our operation as it would
increase the cost of providing equipment and services at prices that are
competitive within our industry.

The proposed rule would also impose qualification requirements on
classroom and skills driver training instructors which do not align with
industry practice and would severely limit the number of individuals
available to train new drivers. The Agency's proposal establishes that
trainers be state certified and requires skill instructors to have at
least two years of experience rather than one. In this regard as well,
FMCSA has set forth a provision without any empirical evidence to
support its position. The proposed requirements exceed industry practice
and, if adopted, would limit type and availability of individuals to
train entry-level drivers.

We are greatly concerned by the Agency's lack of specificity in regards
to the proposed rule's CDL licensing process for new entrants. The
integrity of the "Driver's training certificate", under the Notice of
Proposed Rule Making, is vulnerable to fraud due to the proposed rule's
lack of recommendations for standardized and tamper-proof driver
training certificates. Further, the proposed rule makes no provisions
for my company and others to view or obtain a copy of the driver
training certificate of a prospective new driver candidate. We have no
way of verifying whether or not an individual has been properly trained.

Professional Wireline Rentals, LLC believes that the proposed
entry-level driver training rule is fundamentally flawed and needs to be
reconsidered. At a minimum, FMCSA should: develop a performance-based
rule for training and testing of entry-level drivers; allow motor
carriers and training schools to self-certify; and revise the process
through which state drivers licensing agencies license, retain and share
driver training certificates.

The only benefit I can ascertain from reading the proposed rule goes to
the established CDL training schools. New training centers, in business
for less than two years, can no longer be certified. They can't apply
for certification until they have been in business for two years but
can't be in business for two years because any training they do within
their first two years will not be certified. There is a built-in "Catch
22" that will benefit established training organizations and eliminate
their competition. It also rules out the independent consultants because
they do not instruct in association with an accredited training center
(no matter how much experience they might have).

My final thoughts on this topic center on the idea that a successful
lobbying effort has been made to DOT by the established training centers
in an effort to elevate themselves at the expense of independent
consultants, upstart training centers and the trucking industry as a
whole. I know that this amount of up-front expense would increase the
cost of delivering the nations goods greatly. With the current increase
in the cost of the fuel and personnel required to operate, the addition
of regulations like these will cost consumers at all levels of the
United States economy.

Sincerely,

Ray Humphrey

Safety Director

Professional Wireline Rentals, LLC