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| ![](             | **CHEM GRO of HOUGHTON, INC.**                    |
| media/image1.jpe |                                                   |
| g){width="1.5in" | **P.O. BOX 76**                                   |
| height="1.4201   |                                                   |
| 388888888888in"} | **HOUGHTON, IA 52631**                            |
|                  |                                                   |
|                  | **(319) 469-2611**                                |
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May 21, 2008

Docket Management Facility

U.S. Department of Transportation

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue SE

Washington, DC 20590

www.regulations.gov

Re: Docket #FMCSA -- 2007 -- 27748

Dear Sir:

We are a small agricultural company with locations in rural Iowa,
Illinois and Missouri. Since our facilities are in three states, even
though they are all within a 150 mile radius, we have no choice but to
be considered an interstate carrier. We currently have 74 employees with
CDL's. Of these drivers, approximately 5 of them obtain seasonal CDL's
each season to help out in the planting/fertilizer/harvesting seasons.

Since we are a rural business, we have a very limited pool of potential
employees. We hire drivers in the local vicinity who understand the
business and know the area. A large amount of our drivers come from
farming and as such have driven tractors and trucks on the farm without
the necessity of a CDL. It is bad enough that the high fuel costs limit
our hiring circle, but drivers are also paying over \$100 for the HazMat
endorsement on their license. If they are forced to spend several
thousand dollars to obtain their CDL, they will not come to work for a
small ag company.

As a small company, we cannot afford the time or money for this
extensive training either. It would take at least a month to hire new
drivers or to have our current drivers go from a Class B to a Class A
CDL. Then, if the driver did not stay with our company, we would be out
thousands of dollars in initial training costs, in addition to the
expenses already incurred when hiring a new driver (pre-employment drug
testing and training).

There are many government regulations currently placed upon companies
like ours, such as annual OSHA training, Hazardous Material Training
every three years, Drug and Alcohol testing, fingerprinting and
background checks of all of our employees. These are required since our
company hauls hazardous materials and our drivers need a HazMat
Endorsement on their license. In addition, our company is required to
maintain a satisfactory safety rating with FMCSA in order to keep our
HazMat Registration.

Some of the drivers we have hired in the past only had limited
experience. These drivers were hired following the government
regulations currently in place and were trained by our experienced
drivers. This process has worked very well for us. There have not been
any major accidents or issues. We believe this proves more than anything
that the extra training being proposed is not necessary.

If the government burdens small agricultural companies with these types
of requirements, it will accomplish nothing but making it difficult for
agricultural companies to exist. It is hard finding people who are
willing to work in the ag industry because of the long hours required in
the spring planting and fall harvest seasons. If it will cost potential
employees this much time and money, then the task of hiring new drivers
will become almost impossible.

CHEM GRO OF HOUGHTON, INC.

Gregory Dyer