FMCSA Posts EOBR FAQ, Says it is Revisiting Cost-Benefit Analysis

The Federal Motor Carrier Safety Administration indicates it will re-examine the costs-vs-benefits of mandatory electronic onboard recorders in a new list of frequently asked questions it posted this week on its website. The Owner-Operator Independent Drivers Association has criticized the FMCSA's efforts to mandate automated driver hours-of-service logs, saying such a mandate would impose a $2 billion penalty on the trucking industry -- a cost small-business truckers can ill afford to pay, it says.

The FAQ notes that OOIDA's numbers are based on the agency's Regulatory Impact Analysis for the 2011 notice of proposed rulemaking on EOBRs, which estimated total costs of $2.377 billion per year.
However, the agency said in its FAQ that it believes costs for the devices has come down since it made that estimate.

The agency notes the same 2011 RIA estimated total benefits of $2.711 billion, resulting in an annual net benefit of $344 million. A significant portion of these benefits, the agency says, would come from $1.965 billion in annual paperwork reduction - a savings of $688 per driver each year - due to drivers no longer completing and submitting logbooks.

The FAQ goes on to say the agency is currently preparing a supplemental NPRM that will re-examine the estimated costs and benefits (both paperwork savings and safety) associated with an EOBR mandate for carriers using handwritten RODS.

The agency explains that that $2 billion-plus cost estimate was actually higher than the one in its 2010 final rule (which was subsequently vacated by the court), because the 2011 rule focused on the least expensive device determined to be compliant.

"The agency chose to base its calculations on the higher cost device in the 2011 NPRM because it did not believe that a sufficient number of the cheapest units would be available for a broad industry mandate, which would cover approximately 2 million units."

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