Former CVSA president Steve Vaughn, currently vice president of field operations for PrePass, stressed asking the tough questions about technology and all the infrastructure put in place to support it when it comes to roadside inspections and over-the-air communication from the truck to law enforcement. Getting answers to those questions, some of which he details in today's edition of Overdrive Radio, will be absolutely key to making any possible rulemakings around electronic ID something industry and enforcement can agree on and benefit from where the rubber meets the road. And hopefully without the unintended consequences that often arise in the rush toward federal implementation of new programs.

Overdrive's Alex Lockie wrote about the electronic-ID comment period currently open in this story from Thursday, October 6, 2022: https://www.overdriveonline.com/regulations/article/15301028/electronic-ids-for-trucks-fact-vs-fiction

PrePass' Vaughn was speaking long before the FMCSA's current request for comment on the topic, but drew connecting lines between electronic ID (sometimes referred to as "UID") and the agency's long pursuit of so-called "Wireless Roadside Inspections," or WRI, a program to automate both vehicle and driver inspections with communications technology. That's now become a more limited version of what the old WRI program envisioned, in the form of CVSA's Level 8 electronic inspection standard.

Study and technology development around WRI go back to at least 2006, when the agency was provided funding for a four-year study that morphed into at least nine years of funded research. "Congress in 2018 told them you’re no longer to spend money on it," Vaughn said, speaking in March at the Truckload 2022 conference in Las Vegas. "You’ve been looking at it for 10 years, that’s enough."

Around that same time, though, he added, "we saw it move over to CVSA in the form of a Level 8 inspection." Though the new standard for electronic inspections has been official in CVSA's inspection program since June 2017, "not a single Level 8 inspection [has been] conducted to date," Vaughn said in March.

FMCSA's September ANPRM around electronic IDs did note that the agency has been testing Level 8 inspections as a means essentially to do what CVSA Executive Director Collin Mooney described in Alex Lockie's story yesterday, assess basic safety at highway speeds and thus target only trucks, operators and carriers that truly need it.

The Level 8 electronic inspection standard itself, as Vaughn noted in his March talk, requires the capture of where the truck is via "GPS coordinates, information about the driver. ... Are they licensed to drive the class of vehicle they’re in, do they have their medical? Hours of service information -- are they current, is it up to date? Skill Performance Evaluation Certificate -- does it meet the requirements? On the vehicle -- DOT number, registration. UCR: is it current? What is the operating authority, and does [the carrier] currently have federal out of service violations?"

Vaughn noted an established electronic ID/UID system he viewed as a stepping stone to get there, and the Level 8 as another step toward what CVSA adopted at its most recent meeting, reported on just two days ago, a standard for inspections of automated vehicles.

Citing his past with the California Highway Patrol and with CVSA, Vaughn noted that during his 40 years of experience around trucking and government, he's seen the tendency particularly for governments to want to "get a program forward so quickly that they don’t properly vet it all the way through."

**Where to comment on FMCSA's electronic-ID ANPRM: https://www.regulations.gov/document/FMCSA-2022-0062-0008

**A tutorial around challenging preventable crashes in FMCSA's fairly new program conducted through the DataQs system: https://www.overdriveonline.com/channel-19/article/14897753/how-to-dataq-a-crash-in-new-fmcsa-preventability-program