FMCSA says pushing driving time back to 10 hours would cost $2.4 billion a year

In the case of HOS, the RIA dealt primarily with trucker productivity and cost to the industry.

The Trucker Staff

12/5/2008

WASHINGTON — Lost in all the hubbub that followed last month’s announcement that the current Hours of Service rules would remain unchanged was a Regulatory Impact Analysis (RIA) which found that pushing driving hours back to 10 hours a day and eliminating the 34-hour restart would cost $2.4 billion in lost productivity a year.

An executive order first issued in 1993 by then-President Bill Clinton requires an RIA on certain proposed federal regulations, among them the HOS rule.

In the case of HOS, the RIA dealt primarily with trucker productivity and cost to the industry.

In performing the RIA, the Federal Motor Carrier Safety Administration (FMCSA) looked at two options.

Option one was the current rule.

Option two was more stringent, limiting driving time to 10 hours a day and eliminating the 34-hour restart provision.

Both options had the same sleeper berth provision that is part of the new Final Rule, mandating that the main sleeper berth period is at least eight hours long, supplemented by an additional two-hour break that may be taken outside the sleeper berth.

FMCSA said the simulation model used to estimate the costs for implementing options one and two was first loaded with data representative of shipping patterns and carrier cost structures and tested to ensure that it could realistically simulate typical lengths-of-haul, empty mile ratios and productivity.

Safety impacts were measured by feeding the on-duty and driving schedules from the carrier simulation model into an operator fatigue model to project driver performance under different schedules allowed under each HOS option, and then the fatigue model results were used to estimate the resulting changes in crash risks under each HOS option and for the different operations cases.

FMCSA said the weighted productivity impacts from implementing option two (10 hours driving, no restart) resulted in a 7.3 percent reduction in labor productivity compared to the new Final Rule.

The agency said that using 2005 dollars, the cost of each 1 percent change in productivity is $335 million.

“Multiplying the weighted average productivity impacts by the costs 1 percent decrease in productivity yields $2.4 billion in annual costs associated with implementing option two relative to option one,” the agency wrote in the Federal Register.

The FMCSA said the reduction in crash risk from implementing option two instead of option one was estimated to be approximately 0.63 percent.

That reduction in risk would result is a net savings of $214 million based on total damages per crash, the agency said.

“In summary, the total annual costs from implementing option two are roughly $2.4 billion and the total annual safety benefits are roughly $214 million, resulting in a net annual cost from implementing option two of approximately $2.2 billion in 2005 dollars,” FMCSA wrote in the Federal Register.

The agency said it also conducted a series of sensitivity analyses, where it ‘‘stress tested’’ various assumptions related to elimination of the 11th hour of driving.

“Specifically, the agency revised its assumptions with regard to several important inputs to the RIA, including the percent of all large truck crashes that are fatigue related (increasing it from 7

percent to 15 percent), the value of a statistical life (increasing it from $5.5 million to more than $10 million), and raising the relative risk of a fatigue-related crash in the 11th hour of driving

(by 1.3 times the value used in the revised TOT multiplier),” the FMCSA wrote in the Federal Register.

Each change improved the safety benefits relative to costs from eliminating the 11th hour of daily driving, but none of these changes in individual assumptions made elimination of the 11th driving hour cost beneficial, the FMCSA said.

“Although it is unlikely that FMCSA mis-specified these three assumptions in its initial analysis, the agency nonetheless combined all of the new assumptions in a way that makes elimination of the 11th daily driving hour more favorable from a benefit-cost analysis perspective. This exercise still generated net annual costs of $71 million, meaning that eliminating the 11th hour is unlikely to be cost-effective under any reasonable set of circumstances.” the RIA analysis concluded.