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determined that the majority of respondents expect a moderate to major impact from each of the restart provisions. These results are far different from the 15 percent of the driving population that FMCSA indicates will see a cost due to the restart provisions. ATRI also obtained and analyzed logbook

data to understand normal operating patterns within the trucking industry. The analysis tested the hypothesis that FMCSA’s average weekly work time groupings were incorrect. Comparing its logbook dataset to FMCSA’s, ATRI researchers found that between 0 percent and 2 percent of drivers actually fall into the two “Extreme” and “VeryHigh” driving groups compared to the 15 percent identified by FMCSA. ATRI next assessed how the new driver

group assignments impacted FMCSA’s estimate of productivity loss, safety benefits and health benefits. To do so, the research team reviewed the methodology described in the RIA and produced a “best-possible” replication of the calculation tables based on the available information. The normal industry operating patterns generated by the ATRI data were then incorporated into the FMCSA methodology and ATRI’s calculations

found that implementation of the 34-hour restart provisions will result in a net loss to the industry. Many additional costs were not included

in FMCSA’s analysis, particularly those related to the expected shift of some nighttime drivers to daytime operations. By limiting its productivity calculations to lost work hours for drivers in its extreme driving groups, FMCSA ignores costs related to increased congestion exposure and increased restart times which will be experienced across a much larger percentage of the driving population. Components of the restart provisions may also result in shipper costs, scheduling issues and could exacerbate the ongoing driver shortage. It is estimated that FMCSA finds a

net benefit of $133 million for the restart provisions. ATRI conducted the same analysis using driver groupings based on normal operating patterns, and identified an estimated industry cost of $95,730 annually. In addition, a series of reasonable productivity costs not captured by FMCSA were calculated by ATRI using the same driver groupings and methodology to monetize productivity loss, resulting in a projected loss to the industry ranging from $95 million to $376 million.

And, it’s important to note that none of the net benefit or cost figures include FMCSA’s estimated $40 million annual cost for motor carrier and driver training and reprogramming in response to the rule. The ATRI research team’s cost-benefit

analysis produced a strikingly different outcome than was found by FMCSA. Additionally, ATRI’s analysis identified significant errors in FMCSA’s methodology for calculating industry costs and associated benefits, resulting in a delta between FMCSA’s net benefit and actual industry costs of $322 million based on a conservative estimate of 15 minutes per week lost by the average driver due to productivity losses not captured in FMCSA’s calculations, as shown in the figure below. To learn more about ATRI and order a free

copy of the 34-hour restart analysis, visit us online at RW

Rebecca M. Brewster is President and COO of the American Transportation Research Institute. To learn more about ATRI and order a free copy of the 34-hour restart analysis, visit us online at

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ISSUE 4, 2013 |

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