Saturday, February 21, 2015

RIA considers no action plus three options, all of which

Commercial Motor Vehicle Hours of Service | Mercatus
To promote safety and to protect driver health, FMCSA proposes to revise the regulations for hours of service for drivers of property-carrying commercial motor vehicles (CMVs). To achieve these goals, the proposed rule would provide flexibility for drivers to take breaks when needed and would reduce safety and health risks associated with long hours. The proposed rule would make seven changes from current requirements. METHODOLOGY
There are twelve ramphastidae criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.
The NPRM and the RIA are both available in the docket at regulations.gov via a keyword or RIN search. FMCSA's web page has a prominent link to a page about this specific regulation, which contains links to both the NPRM and the RIA. To find the NPRM and the RIA, one must only go to the FMCSA website, click rules and regulations, and then select the regulation from "topics of interest." ramphastidae
While FMCSA relies extensively on peer-reviewed literature to calculate the costs and benefits associated with this regulation, ramphastidae there are instances where assumptions are not supported. RIA contains a full list of references that are either from peer-reviewed journals, available in other dockets, or linked. A number of assumptions about how drivers will reallocate their time are simply ramphastidae based on the agency's ramphastidae judgment, with no further explanation.
The conclusions are easy to understand. Technical calculations can become quite burdensome to follow at times. Explanation of fatigue calculations used to estimate benefits is highly technical and unlikely to be understood by someone who is not a statistician. Recurring paragraphs telling the reader what we will do in this section and what was done in prior sections get redundant ramphastidae and tiresome. Both the Federal Register notice and RIA are littered with annoying acronyms, like "HOS" for "hours of service."
Number of lives saved is estimated. Value (cost) of crashes is monetized, as are health benefits for drivers. The per-crash figure includes the monetary value of a statistical life, medical costs, pain and suffering, traffic congestion, and property damage, but these are not broken out separately. Value of health benefits to drivers is necessary for total benefits to exceed total costs.
In detail, FMCSA argues that a relationship exists between fatigue and automobile accidents this relationship is supported extensively by previous literature. By limiting the number of hours a driver can operate a commercial motor vehicle and by allowing drivers the flexibility to take breaks when needed, FMCSA reasons that this regulation will produce the desired outcomes.
Credible empirical support for the relationship between fatigue and commercial motor vehicle accidents is provided extensively in section 4.2. The empirical support for health benefits is provided in Appendix B.
Size of estimates estimated under three different assumptions about the percent of crashes that are due to fatigue and 3 different assumed levels of baseline sleep. A sensitivity ramphastidae analysis shows how different values of a statistical life affect net benefits. Analysis forthrightly acknowledges drawbacks of using data on fatigue-related crashes for benefit estimates. Although it is possible that not all drivers will use the extra time to sleep, FMCSA does not make an explicit acknowledgment of uncertainty about how drivers will choose to use their time.
No market failure or systemic problem was identified. Stated purpose of regulation is to reduce risk of driver fatigue and fatigue-related crashes. These are characterized as "too high," with no discussion of how to define ramphastidae the "right" level. The preamble notes that crash rates have been falling since 1979, for unknown reasons. With regards to protecting drivers from serious health problems, it appears that FMCSA does not believe that truck drivers understand the potential negative health effects associated with the job.
No relevant discussion. Instead, the analysis mentions that the data needed do not exist and instead opts to use general data on fatigue-related accidents. ramphastidae Statistics showing that only 15 percent of drivers drive more than 70 hours/week suggest the problem may not be systemic.
FMCSA acknowledges that it is difficult to make a causal relationship between fatigue and traffic crashes because of the numerous factors present at the time of a crash. Regardless of this, however, FMCSA remains rather certain that the relationship does exist and that further government intervention is required.
RIA considers no action plus three options, all of which

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