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included in FMCSA’s analysis, par-
ticularly 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, sched-
uling 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
restart provisions, yet these costs were each of the restart provisions. These based on normal operating patterns,
not included in the FMCSA assessment. results are far different from the 15 and identified an estimated industry
Second, the 15 percent of drivers with percent of the driving population that cost of $95,730 annually. In addition,
the most extreme driving schedules FMCSA indicates will see a cost due to a series of reasonable productivity costs
are practically nonexistent according the restart provisions. not captured by FMCSA were calculated
to data representing normal industry ATRI also obtained and analyzed by ATRI using the same driver group-
operating patterns. The result is only logbook data to understand normal ings and methodology to monetize
limited costs or benefits associated with operating patterns within the truck- productivity loss, resulting in a pro-
this population. ing industry. The analysis tested the jected loss to the industry ranging from
FMCSA identified this 15 percent hypothesis that FMCSA’s average $95 million to $376 million. And, it’s
of the driving population using logbook weekly work time groupings were incor- important to note that none of the net
data sourced from compliance reviews rect. Comparing its logbook dataset benefit or cost figures include FMCSA’s
and safety audits as the foundation of to FMCSA’s, ATRI researchers found estimated $40 million annual cost for
their analysis. These data are by their that between 0 percent and 2 percent motor carrier and driver training and
very nature skewed toward drivers oper- of drivers actually fall into the two reprogramming in response to the rule.
ating at the higher limits of available “Extreme” and “Very High” driving The ATRI research team’s cost-
hours. As a result, the FMCSA analysis groups compared to the 15 percent benefit analysis produced a strikingly
greatly overestimates the benefits of the identified by FMCSA. different outcome than was found by
restart provisions, while at the same ATRI next assessed how the new FMCSA. Additionally, ATRI’s analysis
time ignoring the productivity losses driver group assignments impacted identified significant errors in FMCSA’s
that all driver-types will experience FMCSA’s estimate of productivity loss, methodology for calculating industry
under the new HOS rules. safety benefits and health benefits. To costs and associated benefits, resulting
In order to develop a more accu- do so, the research team reviewed the in a delta between FMCSA’s net benefit
rate analysis of the costs and benefits methodology described in the RIA and and actual industry costs of $322 mil-
of the changes to the 34-hour restart, produced a “best-possible” replication lion based on a conservative estimate of
ATRI assembled a large and unique of the calculation tables based on the 15 minutes per week lost by the average
set of logbook and survey data, which available information. The normal driver due to productivity losses not
were critical in documenting how the industry operating patterns generated captured in FMCSA’s calculations, as
restart provisions would impact motor by the ATRI data were then incorpo- shown in the figure below.
carrier and driver operations. The ATRI rated into the FMCSA methodology
research team first conducted a survey and ATRI’s calculations found that Rebecca M. Brewster is President and
of more than 500 motor carriers and implementation of the 34-hour restart COO of the American Transportation
Research Institute. To learn more about
2,000 drivers and with this data, deter- provisions will result in a net loss to the ATRI and order a free copy of the 34-hour
mined that the majority of respondents industry. restart analysis, visit us online at www.
expect a moderate to major impact from Many additional costs were not atri-online.org

arkansas Trucking reporT | issue 4 2013 35