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The Department of Transportation's Proposed Rules: Hours of Service of Drivers; Driver Rest and Sleep for Safe Operations
This comment examines DOT's Federal Motor Carrier Safety Administration's proposal to limit the number of allowed driving hours for truck drivers and the requirement for on-board recording devices
Rulemaking:
Hours of Service of Drivers; Driver Rest and Sleep for Safe Operations
Stated Purpose:
". . . to require motor carriers to provide drivers with better opportunities to obtain sleep, and thereby reduce the risk of drivers operating commercial vehicles while drowsy, tired, or fatigued to reduce crashes involving these drivers."
Summary of RSP Comment:
DOT's proposal is based on a concern that fatigued truck drivers cause fatal highway accidents. It would limit the number of allowed driving hours per day, per week, and per time of day, and would also require electronic on board recording devices to monitor compliance. DOT does not present data to support its assertion that fatigue systematically contributes to highway fatalities, nor that its proposed solutions will address either driver fatigue or accidents. Perhaps road congestion, road quality, or other vehicle, driver, or infrastructure considerations are more important factors in accidents involving commercial motor vehicles. Depending on the causes of accidents, the approach proposed by DOT may actually increase, rather than reduce fatal accidents. This is because the proposed time-of-day driving requirements may increase congestion, and the hours-per-week restrictions may lead to less rather than more rest or sleep.
DOT's estimates of benefits are inflated and its costs are underestimated. The benefits are almost exclusively due to savings on paperwork (log keeping and firm accounting costs). DOT's fatality-reduction benefits are overstated, and sensitive to key assumptions. Its cost estimates ignore important costs, such as the cost of new trucks, and understate others, such as the cost of hiring new drivers. After adjusting for these flaws, we estimate that the proposal would impose net costs ranging from over $1 billion per year if paperwork benefits are included, to almost $5 billion per year when paperwork benefits are excluded.