IMAMS is the Intelligent Choice for Roadway Safety!

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Your voice matters and can save lives! Thank you for your interest in supporting the approval of (IMAMS) Intelligent Motorist Alert Messaging System.

Your comments are greatly appreciated! 

FMCSA Public Comment website. To Make a comment follow the instructions below.

(1) Copy & edit one of the 6 example letters provided below making sure to include "Docket No. FMCSA-2025-0688". 

(2) Go to the FMCSA website by clicking on the this link. 

(3) Paste or upload the letter and docket number where it says: "Start Typing Comment Here", or attach a pdf file with the letter and your logo. 

(4) Click on "What is your comment about?", then scroll down the categories and select  "Public Comment(s)". 

(5) Enter your email Address.

(6) Tell us about yourself > Click on one of the boxes > Individual > Organization > Anonymous

(7) Click on "Get an email confirmation".

(8)   Add your contact information and Submit the form. 

FMCSA website Public Comment page:  https://www.regulations.gov/commenton/FMCSA-2025-0688-0002       

IMAMS EXPLAINER VIDEO: https://www.youtube.com/watch?v=oB-1Aiu7VGs&t=1s

BROCHURE: https://imamstech.com/brochure

                              NOTE: The deadline for comments is December 31, 2025

Below are some examples of comment letters in favor of IMAMS approval that outline its multiple safety features.

You may use any outline that fits your situation. It is best if you can add some of your own personal thoughts about IMAMS onto your company letterhead and upload it as a pdf file.  

NOTE: See Regulatory Justification Brief at the bottom of this page.

An Individual's Comment in Support of IMAMS Exemption from 49 CFR 392.22

Edit, Copy, and Paste into the FMCSA comment section. Include Docket  No. FMCSA-2025-0688

Re: Docket No. FMCSA-2025-0688

I respectfully submit this comment in strong support of FMCSA granting the requested exemption for the Intelligent Motorist Alert Messaging System (IMAMS) as an alternative to the warning device requirements of 49 CFR 392.22.

IMAMS provides an equal or greater level of safety than the placement of reflective triangles or flares, while also delivering multiple additional safety functions that substantially reduce risk to commercial motor vehicle (CMV) drivers, motorists, and emergency responders.

Equivalency to 49 CFR 392.22
IMAMS enhances compliance with the intent of §392.22 by:

• Providing immediate, automatic, high-mount visual warning to approaching motorists when a CMV is disabled, eliminating the delay and danger associated with manual placement of warning devices.
• Reducing driver exposure to traffic during breakdowns, especially in low-visibility, high-speed, or limited-shoulder environments.
• Delivering clearer, more conspicuous alerts at driver eye level, particularly at night, in adverse weather, or on curves and hills.

Additional Safety Benefits Beyond a Disabled Vehicle Warning
Unlike passive warning devices, IMAMS delivers layered, active safety protections, including:

• High-Mount Center Brake Light (CHMSL) Functionality
      Improves rear-end crash avoidance by increasing brake signal conspicuity,      particularly for following passenger vehicles.
• High-Mount Directive Turn Signals
      Enhances lane-change and turning intent visibility for motorists following large trailers with limited sightlines.
• Rear-End Collision Avoidance Alerts
      Actively warns following motorists when closing speeds indicate an elevated rear-impact risk.
• Infrared Backup Camera and Audible Beeper
      Reduces backing collisions involving pedestrians, workers, and property in low-light or blind-spot conditions.
• Environmental Sensors
      Detect and warn motorists of hazardous conditions such as ice, fog, reduced visibility, or roadway hazards, improving situational awareness beyond the stopped vehicle itself.
• Amber Alert and Severe Weather Broadcasting
      Through integrated 4G communications and GPS, IMAMS enables authorized public agencies to broadcast Amber Alerts and severe weather warnings to millions of motorists via CMVs already traveling America’s highways — expanding public safety reach without additional roadside infrastructure.

Overall Safety Impact
IMAMS not only meets the safety objective of §392.22 but significantly exceeds it by:

• Preventing secondary crashes before they occur,
• Reducing fatalities and serious injuries from rear-end and roadside incidents,
• Supporting future autonomous and driver-assisted CMV operations where manual device placement may not be feasible.

For these reasons, granting this exemption would be consistent with FMCSA’s statutory mission to improve roadway safety through innovation and evidence-based alternatives.

I respectfully urge FMCSA to approve the IMAMS exemption.

Thanks,
[Your Name]

1B. An Individual's Detailed Comment -Shorter version 

Re: Docket No. FMCSA-2025-0688

I strongly support FMCSA granting the requested exemption for the Intelligent Motorist Alert Messaging System (IMAMS) as an alternative to the warning device requirements in 49 CFR 392.22.

IMAMS provides equal or greater safety than reflective triangles or flares by delivering automatic, high-mount, dynamic LED warnings that eliminate the risks of manual placement—especially in low-visibility, high-speed, or adverse conditions.

Key Equivalency and Benefits:

• Immediate automatic alerts to approaching traffic, reducing driver exposure to danger.
• Clearer, more conspicuous warnings at eye level, day or night.

Additional Safety Features:

• Enhanced CHMSL and turn signals to prevent rear-end crashes.
• Rear collision warnings and infrared backup camera for safer backing.
• Environmental sensors detecting hazards like ice or fog.
• Amber Alert and weather broadcasting via 4G/GPS for broader public safety.

IMAMS exceeds the intent of 392.22 by preventing secondary crashes, reducing injuries, and supporting future autonomous CMV operations.

I urge FMCSA to approve this exemption to advance roadway safety through innovation.

Thanks,                                                                                                                                                                              [Your Name]  

Edit, Copy and Paste onto Your Letterhead and include Docket No. FMCSA-2025-0688

Re: Docket No. FMCSA-2025-0688

As a commercial driver, I strongly support the IMAMS exemption from 49 CFR 392.22.

Exiting a disabled truck to place warning triangles is one of the most dangerous things we do on the road, especially at night, in bad weather, or on narrow shoulders. 

IMAMS provides an immediate, high-mount warning to approaching traffic without putting the driver in harm’s way.

IMAMS does more than replace triangles. Its high-mount brake light and turn signals make it easier for drivers behind us to see what a large truck is doing. Rear-end collision alerts and clear messaging help prevent secondary crashes, which are a constant risk when a truck is stopped on the shoulder.

The backup camera and audible alert improve safety in yards and loading areas, and the environmental sensors and emergency alert capability add another layer of protection for everyone on the road.

IMAMS meets the safety intent of §392.22 and improves on it by keeping drivers inside the cab and visible to traffic. I urge FMCSA to approve this exemption

Respectfully,
[Name], CDL Holder

Edit, Copy and Paste onto Your Letterhead and include Docket  No. FMCSA-2025-0688

Re: Docket No. FMCSA-2025-0688

As a motor carrier/fleet operator, I support granting the IMAMS exemption from 49 CFR 392.22.

Rear-end collisions involving stopped or slow-moving trucks represent a significant source of injuries, fatalities, equipment damage, and liability. IMAMS provides earlier, more conspicuous warnings to approaching motorists than passive warning devices while reducing driver exposure to roadside hazards.

High-mount brake lighting, directive turn signals, and rear-impact alerts improve communication between CMVs and surrounding traffic. These features align with industry efforts to reduce preventable crashes and insurance losses while improving driver retention and safety culture.

IMAMS achieves the safety objective of §392.22 while modernizing how warnings are delivered in today’s traffic environment. FMCSA approval would support safer operations across the trucking industry.

Respectfully,
[Name / Company]

Edit, Copy and Paste onto Your Letterhead and include Docket  No. FMCSA-2025-0688

Re: Docket No. FMCSA-2025-0688

From a roadside safety and first responder perspective, I support the IMAMS exemption from 49 CFR 392.22.

Secondary crashes are one of the greatest risks at disabled vehicle and incident scenes. IMAMS improves early warning to approaching motorists, particularly at night or in adverse weather, when visibility and reaction time are limited.

By reducing the need for drivers to walk along active roadways to place warning devices, IMAMS lowers the risk of struck-by incidents involving drivers and responders. High-mount alerts and clear messaging enhance scene awareness and compliance.

IMAMS strengthens the intent of §392.22 by reducing exposure and improving visibility. I encourage FMCSA to approve this exemption in the interest of responder and motorist safety.

Respectfully,
[Name / Role]

Edit, Copy and Paste onto Your Letterhead and include Docket No. FMCSA-2025-0688

Re: Docket No. FMCSA-2025-0688

I support FMCSA granting the IMAMS exemption from 49 CFR 392.22.

IMAMS provides an equal or greater level of safety than traditional warning devices through immediate, high-mount visual alerts that reduce secondary crashes and roadside exposure. Its additional capabilities — including enhanced brake and turn signaling, rear-impact alerts, environmental hazard detection, and GPS-enabled emergency messaging — provide benefits that passive devices cannot.

Of particular value is IMAMS’ ability to broadcast authorized Amber Alerts and severe weather warnings via commercial vehicles already operating nationwide, expanding public safety communication without additional infrastructure.

IMAMS advances FMCSA’s mission to improve roadway safety through innovation while maintaining regulatory intent. Approval of this exemption is warranted.

Respectfully,

[Name / Agency or Public Commenter] 

Edit, Copy and Paste onto Your Letterhead and include Docket  No. FMCSA-2025-0688

Re: Docket No. FMCSA-2025-0688
As a stakeholder concerned with the safety of commercial drivers, motor carriers, first responders, and the traveling public, I support FMCSA granting the IMAMS exemption from 49 CFR 392.22.

For drivers, IMAMS removes one of the most dangerous tasks they face: exiting a disabled vehicle on a high-speed roadway to place warning devices. Far too many roadside injuries and fatalities occur during these moments. IMAMS provides instant, automatic warnings without putting drivers in harm’s way.

For motor carriers, IMAMS reduces preventable rear-end collisions, equipment damage, downtime, and liability exposure. High-mount brake lighting, directive turn signals, and rear-impact alerts improve visibility and driver intent communication beyond what reflective triangles can achieve.

For first responders and roadside workers, IMAMS enhances scene safety by increasing early awareness for approaching motorists, particularly at night or in poor weather, when secondary crashes are most likely.

For public safety agencies, IMAMS offers a unique benefit: mobile alerting infrastructure. Its GPS-enabled 4G connectivity allows Amber Alerts and severe weather warnings to be displayed to millions of motorists via CMVs already operating nationwide — extending the reach of emergency messaging without new roadside installations.

IMAMS does not weaken the safety objectives of §392.22; it strengthens them through layered, active, and automated protection. Approval of this exemption would reduce injuries and fatalities while supporting innovation that reflects modern traffic conditions and vehicle technology.

Respectfully submitted,

[Your Name]

FAQ. What is a stakeholder?

In that context, “stakeholder” means anyone who is directly affected by, uses, or helps implement the system or rule being discussed. For the IMAMS exemption and similar safety issues, that would include:

· Drivers of commercial trucks and passenger vehicles who share the road.

· Motor carriers/fleets and owner-operators who buy, install, and maintain the equipment.

· First responders such as police, fire, EMS, and towing operators who work crash and breakdown scenes.

· Public safety agencies at the local, state, and federal level that oversee traffic safety and emergency response.

· The general public/road users, including families and commuters who benefit from safer highways.

Each of these groups has something at stake in how warning systems work and how well they prevent crashes and protect people.

REGULATORY JUSTIFICATION BRIEF for DOT, FMCSA, FHWA, and NHTSA Review

Regulatory Justification Brief

IMAMS Intelligent Motorist Alert Messaging System

1. Purpose

This brief outlines the regulatory justification for adopting IMAMS as a recognized alternative to physical warning devices required under 49 CFR 392.22(b)(2) for disabled commercial motor vehicles.

2. Background

49 CFR 392.22(b)(2) requires three warning devices (reflective triangles, flares, or lamps) to be physically placed beside and behind a disabled truck.

Challenges:

• Autonomous trucks cannot deploy      physical markers without a human operator.
• Drivers are put at risk when exiting the vehicle on high-speed roadways.
• Physical markers offer limited visibility, especially on curves, hills, and low-light conditions.
• Proposed Strobe lights by AV companies don’t adequately address the issue, provides no clear direct messaging and has far fewer safety features than the IMAMS Emergency Alert Messenger.

3. IMAMS System Description

IMAMS integrates a high-mounted LED display capable of showing:

• Alert/ Move Over / Slow Down/ Disable Vehicle directional safety warnings
• Disabled vehicle ahead alerts
• Crash ahead warnings
• Rear End Collision Alerts
• High-Mount 3rd Brake light
• High-mount Directive Turn Arrows
• Rear View Camera, Backup Beeper
• Environmental Sensor
• DOT-authorized alerts (Amber Alerts, weather warnings, road closures)
• Automatic activation upon roadside disablement
• GPS-enabled location reporting
• 4G Communications
• Visibility is far greater than low-elevation triangles
• Can be quickly adopted across all fleets and supported with ad revenue incentive

4. Regulatory Alignment

4.1 Meets the Intent of 49 CFR 392.22

The purpose of the regulation is to:

• Warn approaching motorists
• Prevent secondary crashes
• Increase disabled vehicle conspicuity

IMAMS exceeds these criteria by providing:

• Immediate activation (no 10-minute deployment delay)
• Elevated “line of sight” visibility hundreds of feet earlier
• Dynamic arrows, clear directive messaging
• Automatic detection and activation (for AVs)

4.2 Supports FMCSA Safety Priorities

• Reduces driver exposure in dangerous roadside conditions
• Increases advance warning time for motorists
• Aligns with FMCSA’s Connected Vehicle initiatives

4.3 Supports NHTSA Crash Mitigation Standards

• Enhances rear conspicuity
• Reduces multi-vehicle pileups
• Provides automated crash-ahead warning integrated with onboard sensors

4.4 Enhances DOT Public Safety Messaging

IMAMS can relay:

• Amber Alerts
• Severe weather alerts
• Road closures
• Travel advisories

This aligns with DOT intelligent transportation systems (ITS) objectives.

5. Autonomous Vehicle Readiness

AV fleet companies cannot fully deploy driverless trucks without an alternative to physical warning triangles. Limited high-mount strobe lights lack clear direction to motorist leaving them unclear what action they need to take to stay safe..

IMAMS enables:

• Fully autonomous roadside safety compliance
• Instant messaging without human      involvement
• Integration with AV sensor      outputs

This accelerates the responsible deployment of AV commercial trucks.

6. Retrofit Potential

The system can be installed on existing fleets to enhance safety and reduce fatalities, complementing FMCSA’s ongoing crash-reduction initiatives.

7. Conclusion

IMAMS provides a technologically superior, automated, and safer alternative to traditional emergency warning devices required under 49 CFR 392.22(b)(2), or proposed strobe lights. Adoption or pilot approval by FMCSA and DOT would:

• Increase roadway safety
• Reduce driver injuries and fatalities
• Advance autonomous vehicle safety standards
• Support modern, digital intelligent transportation systems

Thank You for Your Support

IMAMS Tech https://imamstech.com/

(800) 935-7570

https://www.youtube.com/watch?v=oB-1Aiu7VGs&t=6s