the most intense driving schedules. Tis limitation forms the basis for two significant problems with the FMCSA analysis. First, many drivers in the remaining 85 percent of the population will likely experience productivity losses due to the restart provisions, yet these costs were not included in the FMCSA assessment. Second, the 15 percent of drivers with the most extreme driving schedules are practically nonexistent according to data representing normal industry operating patterns. Te result is only limited costs or benefits associated with this population. FMCSA identified this 15 percent of the


driving population using logbook data sourced from compliance reviews and safety audits as the foundation of their analysis. Tese data are by their very nature skewed toward drivers operating at the higher limits of available hours. As a result, the FMCSA analysis greatly overestimates the benefits of the restart provisions, while at the same time ignoring the productivity losses that all driver-types will experience under the new HOS rules. In order to develop a more accurate analysis of


the costs and benefits of the changes to the 34-hour restart, ATRI assembled a large and unique set of logbook and survey data, which were critical in documenting how the restart provisions would impact motor carrier and driver operations. Te ATRI research team first conducted a survey of more than 500 motor carriers and 2,000 drivers and with this data, determined that the majority of respondents expect a moderate to major impact from each of the restart provisions. Tese 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. Te 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 “Very High” 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. Te 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


10


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.


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. Te 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. Nt


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 www.atri-online.org


NEBRASKA TRUCKER — ISSUE 4, 2013 — www.nebtrucking.com


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