New TECHNICAL MEMORANDUM: HOURS-OF-SERVICE FLEXIBILITY · 2018. 8. 28. · Vice President of Inbound Transportation . Wal-mart Stores, Inc. Victoria King . Vice President Public Affairs

August 2018

Jeffrey Short Senior Research Associate

American Transportation Research Institute Atlanta, GA

TECHNICAL MEMORANDUM: HOURS-OF-SERVICE FLEXIBILITY

Photo Courtesy of Doug Turnbull, WSB Radio, Atlanta, GA

ATRI BOARD OF DIRECTORS

Judy McReynolds Chairman of the ATRI Board Chairman, President and CEO ArcBest Corporation Fort Smith, AR Andrew Boyle Co-President Boyle Transportation Billerica, MA Michael L. Ducker President and CEO FedEx Freight Memphis, TN Rich Freeland President and COO Cummins Inc. Columbus, IN Darren D. Hawkins CEO YRC Worldwide Overland Park, KS Dave Huneryager President and CEO Tennessee Trucking Association Nashville, TN Derek Leathers President and CEO Werner Enterprises Omaha, NE Robert E. Low President and CEO Prime Inc. Springfield, MO

Rich McArdle President UPS Freight Richmond, VA Benjamin J. McLean CEO Ruan Transportation Management Systems Des Moines, IA Dennis Nash Executive Chairman of the Board Kenan Advantage Group North Canton, OH Gregory L. Owen Head Coach and CEO Ability/ Tri-Modal Transportation Services Carson, CA James D. Reed President and CEO USA Truck Van Buren, AR Annette Sandberg President and CEO Transsafe Consulting, LLC Davenport, WA

Rebecca M. Brewster President and COO American Transportation Research Institute Atlanta, GA

Chris Spear President and CEO American Trucking Associations Arlington, VA

ATRI RESEARCH ADVISORY COMMITTEE

Karen Rasmussen, RAC Chairman Chief Executive Officer HELP Inc. Jon Blackham Policy and Government Affairs Canadian Trucking Alliance Amy Boerger Vice President, Sales Cummins, Inc. Bill Brown Manager of Fleet Telematics Southeastern Freight Lines Bob Costello Senior Vice President and Chief Economist American Trucking Associations Tom Cuthbertson Vice President, Regulatory Compliance Omnitracs, LLC Dennis Dellinger President Cargo Transporters Chip Duden Vice President, Strategic Business Analytics Werner Enterprises Paul J. Enos Chief Executive Officer Nevada Trucking Association Thomas Fansler President Trimble Transport Mobility Scott George Chief Executive Officer TCW, Inc.

Mike Golias Director for Research, Intermodal Freight Transportation Institute University of Memphis Victor Hart Director of Safety DOT Transportation, Inc. Sanford Hodes Ryder System, Inc. Senior Vice President and Deputy General Counsel Ken Howden Director, 21st Century Truck Partnership U.S. Department of Energy Kelly Killingsworth Vice President of Inbound Transportation Wal-mart Stores, Inc. Victoria King Vice President Public Affairs UPS Dustin Koehl Vice President, Sales and Marketing Total Transportation of Mississippi Caroline Mays Director, Freight and International Trade Section Texas DOT Lisa Mullings President and CEO National Association of Truck Stop Operators Tom Murtha Senior Planner Chicago Metropolitan Agency for Planning

Brenda Neville President Iowa Motor Truck Association Dean Newell Vice President, Safety Maverick, Inc. Steve Raetz Director of Research and Market Intelligence C.H. Robinson Worldwide, Inc. Wellington F. Roemer, III President and CEO Wellington F. Roemer Insurance, Inc. Lee Sarratt Director of Safety J.B. Hunt Mark Savage Deputy Chief Colorado State Patrol Andrea Sequin Director, Regulatory Services Schneider National, Inc. Carl Stebbins Corporate Director of Admissions and Marketing New England Tractor Trailer Training School Harold Sumerford, Jr. Chief Executive Officer J&M Tank Lines James E. Ward President and CEO D.M. Bowman Tom Weakley Director of Operations Owner-Operator Independent Drivers Association Foundation

Hours-of-Service Flexibility 2

TABLE OF CONTENTS

LIST OF ACRONYMS ............................................................................................................... 4

EXECUTIVE SUMMARY ........................................................................................................... 5

Report Objective ...................................................................................................... 5

Problem Statement .................................................................................................. 5

Research Approach ................................................................................................. 5

GPS Data Analysis Results ..................................................................................... 5

HOS Flexibility Demonstration Scenarios ................................................................ 7

Summary of Results and Conclusions ..................................................................... 7

INTRODUCTION ....................................................................................................................... 8

Problem Statement .................................................................................................. 8

Research Approach ................................................................................................. 9

BACKGROUND ........................................................................................................................10

Current Hours-of-Service Regulations ....................................................................10

HOS Flexibility ........................................................................................................11

Highway Congestion ...............................................................................................13

METHODOLOGY AND ANALYSIS ..........................................................................................15

Part I: GPS Data Analysis ...............................................................................................15

Time Loss and Cost of Congestion Analysis ...........................................................19

Part II: HOS Flexibility Demonstration Scenarios ............................................................23

Current Rules Scenario ..........................................................................................25

Flexible Rules Scenario ..........................................................................................27

SUMMARY OF RESULTS AND CONCLUSIONS ....................................................................30


LIST OF TABLES AND FIGURES

Figure ES1: Average Trip Times across 40-Mile Study Area ................................................ 6

Table ES2: Current vs. Flexible Single Day Statistics .......................................................... 7

Table 1: Hours-of-Service .......................................................................................................10

Table 2: Innovative Split Sleeper Berth Options ..................................................................11

Table 3: Responses to FMCSA’s June 2017 Federal Register Notice ................................12

Figure 1: Typical Average Speed Pattern at a Freight-Significant Bottleneck ...................13

Table 4: Top Ten Congested Locations – ATRI 2018 Bottleneck Report ............................14

Figure 2: Study Location .......................................................................................................16

Figure 3: Average Trip Times across 40-Mile Study Area ....................................................17

Figure 4: Average Trip Speeds across 40-Mile Study Area .................................................18

Table 5: Best Average Speeds and Travel Times ................................................................18

Table 6: Worst Average Speeds and Travel Times ..............................................................18

Table 7: Per Truck Trip Costs for the 40-Mile Trip ................................................................20

Table 8: Additional Cost of 40-Mile Trip across Study Area ................................................22

Figure 5: HOS Flexibility Demonstration Route ...................................................................24

Table 9: Current Rules Scenario ...........................................................................................26

Table 10: Flexible Rules Scenario ..........................................................................................28

Table 11: Current vs. Flexible Single Day Statistics ............................................................29


LIST OF ACRONYMS

ATA ATRI CMV EST FMCSA GIS GPS HOS MPH MTA RAC

American Trucking Associations American Transportation Research Institute Commercial Motor Vehicle Eastern Standard Time Federal Motor Carrier Safety Administration Geographic Information System Global Positioning System Hours-of-Service Miles-per-Hour Minnesota Trucking Association Research Advisory Committee


EXECUTIVE SUMMARY Report Objective In 2017 the American Transportation Research Institute’s (ATRI) Research Advisory Committee (RAC)1 selected as a top research priority a study to determine if flexibility in the hours-of-service (HOS) regulations, in the form of new split rest period options, could generate improved efficiencies for commercial motor vehicle (CMV) drivers by avoiding the nation’s worst urban bottlenecks. This research was, in part, a response to ongoing discussions by industry stakeholders including the Federal Motor Carrier Safety Administration (FMCSA) on how flexibility in sleep and rest time could benefit drivers. Problem Statement Truck drivers who must travel across urban interstates have limited options for avoiding traffic congestion, particularly during extended peak “rush-hour” periods. Under current HOS rules drivers are required to rest for at least 10 hours prior to starting a new 14-hour work day. With one exception, the 10 hours must be consecutive. As a result, drivers who take a break to avoid congestion may lose available work hours. There are however innovative HOS concepts that, if implemented, would enable drivers to avoid congestion by taking strategic periods of rest; a rest period of three or more hours that qualifies toward the daily 10-hour rest requirement could effectively help drivers avoid slow-moving peak travel periods. Research Approach This research uses empirical data to demonstrate how a 7/3, 6/4 or 5/5 split sleeper berth provision that pauses the 14-hour on-duty limit would be more effective than the current HOS regulations in helping drivers avoid congestion. GPS Data Analysis Results To illustrate the impact of urban congestion on freight, ATRI first selected a representative freight-significant 40-mile urban interstate study corridor across Atlanta, GA. Next, operational truck GPS data was utilized to identify a sample of 3,600 truck trips that traversed the study corridor. Average speeds and travel times by hour-of-day were calculated for each trip – which quantified significant congested periods that last well beyond 2 hours. Lost time and operational costs were calculated for each hour of the day; the peak period calculations were found to be more than double the time and cost of off-peak travel. 1 ATRI’s Research Advisory Committee (RAC) is comprised of industry stakeholders representing motor carriers, trucking industry suppliers, federal government agencies, labor and driver groups, law enforcement, and academia. The RAC is charged with annually recommending a research agenda for the Institute.


Not surprisingly, the results indicate that AM and PM peak travel times (when commuters have the greatest demand for urban interstate highways) had the lowest average speeds and highest average travel times across the 40-mile study area. The travel times displayed in Figure ES1 indicate a fastest travel time of 39.9 minutes to traverse the corridor (1:00 - 1:59 AM) and the slowest travel time of 1 hour and 33.4 minutes to traverse the corridor (when trips start between 4:00 - 4:59 PM). Thus, there is a range of 53.5 minutes between the best and worst travel times, indicating that the 40-mile trip could take nearly one hour longer to complete depending on the time of day travel commences.

Figure ES1: Average Trip Times across 40-Mile Study Area

An analysis was conducted to identify total lost time and the requisite cost of trips that begin during peak travel time periods using ATRI’s annual Analysis of the Operational Costs of Trucking, where the average cost per hour was $63.68.2 The lowest trip cost in this analysis was $42.32 for trips beginning between 1:00-1:59 AM and the highest average trip cost was $99.11 for trips with a start time of 4:00-4:59 PM. The difference in cost between a single 40-mile trip starting in the 1 AM time bin versus the 4 PM time bin is $56.79. The additional congestion costs for travel below a free-flow average speed of 55 MPH were calculated for the study corridor. To standardize these calculations, it is assumed that 1,000 trucks take this route each weekday and that the distribution of these trips across the day follow the distribution of trips observed in the GPS data sample. The cost-per-trip figure for each hour bin was multiplied by the 1,000 trips that were distributed across the day, with congestion adding costs of $15,496 in additional costs per 1,000 trips across the 40-mile corridor. Assuming there are 250 non-holiday weekdays in a year, the annual congestion cost for trucks 2 Hooper, A.; D. Murray, An Analysis of the Operational Costs of Trucking: A 2017 Update, American Transportation Research Institute. Arlington, VA. September 2017.

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

0.010.020.030.040.050.060.070.080.090.0

100.0

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Trip

Dis

trub

tion

Aver

age

Trav

el T

ime

(min

utes

)

Trips Start Hour of Day

Average Travel Time (minutes) and Trip Distribution

Trip Distribution Travel Time (minutes)


operating across this 40-mile route totals $3.8 million. Using the same 1,000 truck assumption, the drivers of these trucks spend an additional 240 hours of drive time on this route per day, equating to 60,185 additional hours of driving annually. HOS Flexibility Demonstration Scenarios The research team developed two scenarios of representative trips, both traveling 585 miles from North Carolina to Alabama. In the middle of the trip the driver must travel across the 40-mile congested study area. Driver A – the Current HOS Regulations Driver – operates through the congested location without stopping. Driver B – the Flexible HOS Regulations Driver, takes a four-hour rest period to avoid congestion. The differences between the Current HOS and Flexible HOS Scenarios are displayed in Table ES2. The driver in the Current Scenario drives an extra 45.5 minutes and uses 1 hour and 15.5 minutes more of the 14-hour window time limit.

Table ES2: Current vs. Flexible Single Day Statistics

Scenario Drive Time 14-Hour Maximum Current 10 hr 45.5 min 12 hr 45.5 min Flexible 10 hr 00 min 11 hr 30 min

Flexible HOS Savings 45.5 min saved 1 hour 15.5 min saved

Summary of Results and Conclusions

This report provides an assessment of how flexible HOS rules could be applied to enable a single representative driver the ability to avoid congestion in a single study area. There are hundreds, if not thousands, of severe chokepoints in the nation where these rules could be applied by HOS-regulated drivers. This analysis models two scenarios with a driver traveling across a heavily congested 40-mile urban corridor as part of a 585-mile trip using current and flexible HOS options. Utilizing the flexible option, traversing the 40 miles required 45.5 minutes less driving time because a 4-hour rest break allowed the driver to avoid a relatively small (40-mile) segment of urban interstate during peak travel times. If only 25 truck trips per day avoided the congested weekday time period presented on the study segment, truck drivers would drive 4,700 fewer hours annually to move the same goods the same distance.3 This equates to operational cost savings of more than $300,000 per year for the 25-truck sample at that single location. The analysis then uses the Atlanta scenario to extrapolate a conservative reduction of 2.3 million hours of driving annually using a flexible HOS regulation. This analysis does not consider the broader traffic congestion benefits derived from fewer truck trips operating in rush-hour traffic.

3 Assumes 45.5 minutes of driving time is saved on average per day by 25 drivers across 250 non-holiday weekdays.


INTRODUCTION

In 2017 the American Transportation Research Institute’s (ATRI) Research Advisory Committee (RAC)4 selected as a top research priority a study to determine if flexibility in the hours-of-service (HOS) regulations, in the form of new split rest period options, could help commercial motor vehicle (CMV) drivers avoid the nation’s worst urban bottlenecks. This was in part a response to ongoing discussions within the industry on how flexibility in sleep and rest time could benefit drivers. Speakers at a 2010 Federal Motor Carriers Safety Administration (FMCSA) listening session, for instance, indicated that drivers “would like some regulatory flexibility (i.e., an exemption from consolidated sleeper berth time) to be able to sleep when they get tired or as a countermeasure to traffic congestion.”5 In 2012, an FMCSA study on the safety impacts of split sleep offered evidence that “split sleep is preferable to consolidated daytime sleep.”6 This was followed with a late-2013 petition from the Minnesota Trucking Association (MTA) and the American Trucking Associations (ATA) for FMCSA to conduct a pilot program that would study split sleeper berth breaks.7 FMCSA began developing its pilot study on split sleeper berth options in 2015 and according to the study website, pre-testing of the study protocol has not yet commenced as of this publication.8

Problem Statement Truck drivers who must travel across urban interstates have limited options for avoiding congestion, particularly during extended peak “rush-hour” periods. Under current HOS rules drivers are required to rest for at least 10 hours prior to starting a new 14-hour work day. With one exception, the 10 hours must be consecutive. The exception, known as the sleeper berth provision, does allow narrow flexibility.9 Practical use of the current “8/2” sleeper berth provision to avoid congestion is limited, however, since rush-hour traffic often lasts well beyond the two-hour period. As a result, if a driver chooses under current HOS rules to avoid peak highway congestion periods by taking an extended rest break, that driver will typically lose available work hours. There are however innovative HOS concepts that, if implemented, would enable drivers to avoid congestion by taking periods of rest. For instance, a rest period of three or more hours that

4 ATRI’s Research Advisory Committee (RAC) is comprised of industry stakeholders representing motor carriers, trucking industry suppliers, federal government agencies, labor and driver groups, law enforcement, and academia. The RAC is charged with annually recommending a research agenda for the Institute. 5 Federal Motor Carrier Safety Administration (FMCSA), “Hours of Service of Drivers; Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time,” Published in the Federal Register 06/06/2017. Accessed 8/2/2018. https://www.federalregister.gov/documents/2017/06/06/2017-11642/hours-of-service-of-drivers-pilot-program-to-allow-commercial-drivers-to-split-sleeper-berth-time 6 Federal Motor Carrier Safety Administration (FMCSA), Investigation of the Effects of Split Sleep Schedules on Commercial Vehicle Driver Safety and Health. Report Number FMCSA-RRR-12-003. December 2012. 7 “MTA and ATA Request Sleeper Berth Pilot Project,” Accessed 8/5/2018. http://ripleytransportation.com/mta-and-ata-request-sleeper-berth-pilot-project/ 8 Federal Motor Carrier Safety Administration (FMCSA), “Flexible Sleeper Berth Pilot Program,” Accessed 08/27/18. https://www.fmcsa.dot.gov/research-and-analysis/research/flexible-sleeper-berth-pilot-program 9 Under this rule, drivers may take a consecutive 8-hour period (resting in the sleeper berth of the truck) and a separate 2-hour off-duty period to gain a new work day.

https://www.federalregister.gov/documents/2017/06/06/2017-11642/hours-of-service-of-drivers-pilot-program-to-allow-commercial-drivers-to-split-sleeper-berth-time

https://www.federalregister.gov/documents/2017/06/06/2017-11642/hours-of-service-of-drivers-pilot-program-to-allow-commercial-drivers-to-split-sleeper-berth-time

https://www.fmcsa.dot.gov/research-and-analysis/research/flexible-sleeper-berth-pilot-program


qualifies toward the daily 10-hour rest requirement could effectively help drivers avoid slow-moving peak travel periods. Without such an option, the current HOS rules will continue to encourage long-haul drivers to operate during peak periods of congestion. Research Approach Using empirical data as the primary input, the goal of this report is to demonstrate how a 7/3, 6/4 or 5/5 split sleeper berth provision that pauses the 14-hour on-duty limit would be more effective than the current HOS regulations in helping drivers avoid congestion. This is demonstrated first through a GPS Data Analysis which quantifies how the urban congestion problem relates to existing HOS rules. In the second analysis, scenarios are developed to demonstrate the application of HOS flexibility to avoid extensive congestion. Part I: GPS Data Analysis. To illustrate the impact of urban congestion on freight, ATRI first selected a representative freight-significant urban interstate study corridor. Next operational truck GPS data was utilized to identify a sample of 3,600 truck trips that traversed the study corridor. Average speeds and travel times by hour-of-day were calculated for each trip which quantified significant congested periods that last well beyond 2 hours. Lost time and operational costs were next calculated for each hour of the day; these figures during peak periods were found to be more than double the time and cost of off-peak travel. Part II: HOS Flexibility Demonstration Scenarios. Next, the research team developed two scenarios of representative trips traveling the study area, with the first trip operating under the current rules and the second trip operating under a flexible sleeper berth option. This final step quantitatively documents that drivers could spend less time driving, while achieving the same travel distance when employing innovative split sleeper berth options to avoid congested conditions.


BACKGROUND

Current Hours-of-Service Regulations FMCSA’s HOS regulations limit how long a driver may drive (and conduct non-driving work activities) during a work day and work week. The regulations also outline the amount of consecutive rest a driver must have before legally going on-duty. As shown in Table 1, drivers have a 14-hour window during each work day that can be used for driving (up to 11 hours), resting, or to conduct non-driving work. A new 14-hour window can be earned after 10 hours of qualifying off-duty time.10 Additionally, a new 14-hour on-duty window can be opened with two periods of off-duty time, where one period is at least 8 consecutive hours spent in the sleeper berth of a vehicle and another period is at least 2 consecutive hours off-duty.11 This rule is known as the sleeper berth provision. Through this provision the 14-hour on-duty window can be extended during the 8-hour period spent in the sleeper berth but not during the 2-hour period.

Table 1: Hours-of-Service

10 Federal Motor Carrier Safety Administration (FMCSA), “Summary of Hours of Service Regulations,” Accessed on 08/27/18. https://www.fmcsa.dot.gov/regulations/hours-service/summary-hours-service-regulations 11 It does not matter which period is taken first.

Hours-of-Service Rules for Property Carrying Drivers11-Hour Driving LimitMay drive a maximum of 11 hours after 10 consecutive hours off duty.14-Hour LimitMay not drive beyond the 14th consecutive hour after coming on duty, following 10 consecutive hours off duty. Off-duty time does not extend the 14-hour period.Rest BreaksMay drive only if 8 hours or less have passed since end of driver’s last off-duty or sleeper berth period of at least 30 minutes. Does not apply to drivers using either of the short-haul exceptions in 395.1(e). [49 CFR 397.5 mandatory “in attendance” time may be included in break if no other duties performed]60/70-Hour LimitMay not drive after 60/70 hours on duty in 7/8 consecutive days. A driver may restart a 7/8 consecutive day period after taking 34 or more consecutive hours off duty. Sleeper Berth ProvisionDrivers using the sleeper berth provision must take at least 8 consecutive hours in the sleeper berth, plus a separate 2 consecutive hours either in the sleeper berth, off duty, or any combination of the two.

https://www.fmcsa.dot.gov/regulations/hours-service/summary-hours-service-regulations


HOS Flexibility While the 8/2 split sleeper berth provision does offer some flexibility, this report will consider additional regimens to the sleeper berth provision where rest is split into 7/3, 6/4 and 5/5 hour time periods, and where the shorter break period pauses the 14-hour on-duty window, with both periods accumulating for the required total rest time of 10 hours per day. It is believed that these options, listed in Table 2, would allow drivers to avoid some of the nation’s worst congestion while at the same time allowing CMV operators to drive for less time to achieve the same miles and related compensation.

Table 2: Innovative Split Sleeper Berth Options

Option First Rest Period

Second Rest Period Total Rest

A 3 hours 7 hours 10 hours B 4 hours 6 hours 10 hours C 5 hours 5 hours 10 hours

As described earlier, FMCSA is currently studying split sleep and how it could be used to improve rest and alertness. FMCSA reports that a key impetus for the study is the fact that “many drivers indicated that they would like some regulatory flexibility to be able to sleep when they become tired or when traffic is congested (i.e., exemption from the requirement for consolidated sleeper berth time).”12 Examples of driver feedback on additional HOS flexibility are found in public comments submitted to the Federal Register, in particular FMCSA’s June 2017 request for comment notice titled “Hours of Service; Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time.”13,14 Several hundred public comments were submitted, with many highlighting the need for flexibility in order to adapt to the delays that professional drivers encounter on a daily basis and to allow drivers to rest when they were tired. In one comment, for example, a respondent stated: “The trucking industry is full of variables every day from time spent at shippers and receivers to time spent trying to get thru gridlocked cities like [Atlanta] during rush hour. When it takes a driver 4 hours to get thru major cities they are not getting [paid] for that time.”15 Many others echoed this sentiment, along with the safety benefits of having flexible sleep and rest options (Table 3).

12 Federal Motor Carrier Safety Administration (FMCSA), “Flexible Sleeper Berth Pilot Program,” Accessed 08/27/18. https://www.fmcsa.dot.gov/research-and-analysis/research/flexible-sleeper-berth-pilot-program 13 Federal Motor Carrier Safety Administration (FMCSA), “Hours of Service; Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time,” Docket ID: FMCSA-2016-0260, Accessed 08/16/18. https://www.regulations.gov/docket?D=FMCSA-2016-0260 14 Federal Motor Carrier Safety Administration (FMCSA), “Hours of Service of Drivers; Pilot Program To Allow Commercial Drivers To Split Sleeper Berth Time,” Federal Register Notice Vol. 82, No. 107, Tuesday, June 6, 2017, Accessed on 08/27/18. https://www.gpo.gov/fdsys/pkg/FR-2017-06-06/pdf/2017-11642.pdf 15 Federal Motor Carrier Safety Administration (FMCSA), “Hours of Service; Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time,” Docket ID: FMCSA-2016-0260, Accessed 08/16/18. https://www.regulations.gov/docket?D=FMCSA-2016-0260

https://www.fmcsa.dot.gov/research-and-analysis/research/flexible-sleeper-berth-pilot-program

https://www.regulations.gov/docket?D=FMCSA-2016-0260

https://www.gpo.gov/fdsys/pkg/FR-2017-06-06/pdf/2017-11642.pdf

https://www.regulations.gov/docket?D=FMCSA-2016-0260


Table 3: Responses to FMCSA’s June 2017 Federal Register Notice

Comment ID Comment

FMCSA-2016-0260-0148

Drivers need more flexibility, the more combinations of split times the better. You never know from day to day what delays you will run into for a vast variety of reasons.

FMCSA-2016-0260-0188

The split sleeper birth time should be reinstated. It allows drivers to avoid traffic congestion [without] wasting valuable driving time.

FMCSA-2016-0260-0258

Being able to split sleeper berth time I feel would make things safer. Drivers would be able to park and rest during rush hour traffic reducing some congestion then be able to continue their trip. There wouldn't be so many drivers rushing around because they are worried about the 14 hour clock ... Being able to split time and stop the clock is a common sense safety option.

FMCSA-2016-0260-0129

I don't have any issues with the 14 hour workday. I do take issue with the fact that I am forced to drive during rush hour traffic, when I could be resting and out of the way of commuting traffic.

FMCSA-2016-0260-0051

Allowing drivers to rest for the amount of time they feel is necessary can only make them safer. Some days a 3,4-or 5 hour break is exactly what is needed. This can also benefit all others on the road as the driver could take a break during rush hour and not be penalized later when finishing 10 hr break. If FMCSA wants safer drivers behind the wheel...let them rest rest [sic] when needed.

FMCSA-2016-0260-0231

I support FMCSA's efforts to study the impact of providing additional flexibility to the current sleeper berth provision of the Hours of Service rules. This program will help prove the theory that drivers need more flexibility in their day. … By giving a driver the flexibility that is needed, there will be less congestion on our cities highways at peak traffic times.

FMCSA-2016-0260-0284

Being able to get some rest when, I feel, I need it would greatly increase my productivity and the safety of the public. Playing "beat the clock" when I have been held up, in traffic or at the dock, is not safe for anyone. With a change to the rules, I could count the 6 hours I spent sleeping in the dock waiting to be unloaded, toward my 10 hr break, and not have it be wasted time, because I'm forced to leave the shipper/receiver when they do not allow us to stay to finish our mandatory break of 8 hrs.


Highway Congestion Congested travel occurs when demand for highways by cars, trucks and other vehicles is greater than roadway capacity. The result is often stop-and-go traffic, and average speeds well below the posted speed limit. Congestion on U.S. highways adds an additional $63.4 billion annually to the trucking industry’s operational costs.16 The most congested time periods typically occur during “rush-hour” peak periods – the weekday morning and afternoon hours when automobile drivers use highways to get to and from work in their personal vehicles. Figure 1 shows the decrease in average speeds during the AM and PM rush hours at one of the top 100 freight-significant bottlenecks monitored by ATRI.17 This example is typical of an urban bottleneck – where significant delays extend well beyond two hours and can last beyond five hours.

Figure 1: Typical Average Speed Pattern at a Freight-Significant Bottleneck

16 Torrey, W. Ford. Estimating the Cost of Congestion to the Trucking Industry: Standardized Methodology for Congestion Monitoring and Monetization. Transportation Research Record: Journal of the Transportation Research Board, No. 2646, Transportation Research Board of the National Academies, Washington D.C., 2017. DOI 10.3141/2646-07. 17 American Transportation Research Institute (ATRI). “2018 ATRI Top Truck Bottleneck List.” As seen on 8/1/18 at http://atri-online.org/2018/01/25/2018-top-truck-bottleneck-list/

55 55 55 55 55 54.6

33.9

15.8 14.4

23.9

41.3

47.3

41.6

29.9

22.817.7 15.8 16.9

19.7

26.3

39.8

49.451.7

54.4

12A

M-1

AM

1AM

-2A

M

2AM

-3A

M

3AM

-4A

M

4AM

-5A

M

5AM

-6A

M

6AM

-7A

M

7AM

-8A

M

8AM

-9A

M

9AM

-10A

M

10A

M-1

1AM

11A

M-1

2PM

12P

M-1

PM

1PM

-2P

M

2PM

-3P

M

3PM

-4P

M

4PM

-5P

M

5PM

-6P

M

6PM

-7P

M

7PM

-8P

M

8PM

-9P

M

9PM

-10P

M

10P

M-1

1PM

11P

M-1

2AMA

vg S

peed

(MPH

)

Time of Day

Average Speed by Time of DayChicago: I-90 at I-94 (North)

http://atri-online.org/2018/01/25/2018-top-truck-bottleneck-list/


The extreme impacts of peak travel periods are further illustrated in the nation’s top ten congested locations from ATRI’s 2018 Bottleneck Report (Table 4), which lists the fastest and slowest hourly average speeds at each location. The difference in travel time across a hypothetical 10 miles is also listed, showing the amount of time that can be lost due to congestion. While truck drivers are generally aware of the best and worst times to drive through these bottlenecks to avoid congestion, the HOS rules along with customer pick-up and delivery scheduling may preclude them from avoiding these areas at the worst times.

Table 4: Top Ten Congested Locations – ATRI 2018 Bottleneck Report

Rank Location Best

Average Speed (mph)

Worst Average Speed (mph)

Additional Time to Drive 10 Miles

(minutes of additional drive time at best vs

worst average speed) 1 Atlanta, GA: I-285 at I-85 (North) 58.5 16.7 25.74 2 Fort Lee, NJ: I-95 at SR 4 49.2 20.7 16.86 3 Chicago, IL: I-290 at I-90/I-94 48.7 14.2 29.93 4 Atlanta, GA: I-75 at I-285 (North) 59.1 21.2 18.15 5 Los Angeles, CA: SR 60 at SR 57 55.4 28.9 9.92 6 Boston, MA: I-95 at I-90 52.2 26.0 11.58 7 Baltimore, MD: I-695 at I-70 59.5 32.5 8.38 8 Queens, NY: I-495 48.8 15.2 27.18 9 Cincinnati, OH: I-71 at I-75 53.2 28.2 10.00

10 Louisville, KY: I-65 at I-64/I-71 51.5 27.5 10.17 As demonstrated in Table 4, if a driver can move freight from point A to point B along an urban highway at an average speed of 58.5 MPH rather than 16.7 MPH, he or she will spend less time behind the wheel to travel the same distance. For a long-haul driver, however, this cannot always be timed perfectly given the impacts of customer detention, traffic incidents and weather, and the inflexibility of the current HOS rules.


METHODOLOGY AND ANALYSIS Part I: GPS Data Analysis The primary dataset used for estimating the potential benefits of splitting off-duty periods was ATRI’s anonymized truck GPS dataset. This dataset is comprised of a continuous stream of truck position data that is reported from more than 800,000 trucks. For each individual truck, a latitude/longitude, date and time stamp, speed and other information is recorded continuously. Position reads (pings) within the dataset are extremely frequent; anywhere from every 30 seconds to every several minutes. The goal of the GPS data analysis was to establish travel times for truck trips across a representative urban corridor during different periods of a typical day. The variation in travel time during peak and off-peak periods could then be used in a subsequent analysis to identify periods where HOS flexibility could be applied to achieve travel time and cost savings. The first step in the GPS data analysis was to select a study corridor that exemplified a typical urban bottleneck problem and would therefore be an appropriate location to apply HOS flexibility. The ideal study corridor would exhibit the following characteristics:

1. The corridor must experience both free-flow average speeds and significantly congested average speeds during a typical weekday.

2. The corridor must be freight-significant.

3. The corridor must have limited alternative routes.

Using ATRI’s 2018 Top 100 Bottleneck List18 as a guide, an approximately 40-mile route from the northeast Atlanta region along I-85 to points west of Atlanta along I-20 that met these criteria was selected. The corridor, illustrated in Figure 2, includes travel through bottlenecks ranking 1, 4 and 17 on the 2018 Top 100 Truck Bottleneck List.19

18 American Transportation Research Institute (ATRI). “2018 ATRI Top Truck Bottleneck List.” As seen on 8/1/18 at http://atri-online.org/2018/01/25/2018-top-truck-bottleneck-list/ 19 Locations are as follows: #1 Atlanta, GA: I-285 at I-85 (North); #4 Atlanta, GA: I-75 at I-285 (North); #17 Atlanta, GA: I-20 at I-285 (West)

http://atri-online.org/2018/01/25/2018-top-truck-bottleneck-list/


Figure 2: Study Location

Next, travel times were established using truck trips that traversed the entire corridor. Empirical truck GPS data along the route was first selected for a 20-day study period during October 2017, which included weekdays only.20 Using GIS and statistical computing tools, truck trips that traversed the entire corridor were identified within the study period. As part of the trip identification procedure, filters were used to remove trips that left the route or did not traverse the full route, ensuring that only uninterrupted, complete trips across the approximately 40-mile study corridor were included. Statistics for average speed, travel time and number of trips were then compiled into hourly bins based on trip start time. Filters were next applied to remove outliers. In particular, trips greater than 2 hours (e.g. those that might have resulted from significant traffic incidents) were removed. Additionally, trips with a distance of more than 43.0 miles and less than 37.0 miles were filtered from the final study dataset.21 To test the effectiveness of the distance filters, average distance was calculated for each 1-hour bin. The average distance was 39.84 miles with a maximum

20 The dates were Monday through Friday: October 2-6, 2017; October 9-13, 2017; October 16-20, 2017; October 23-27, 2017. 21 Truck GPS position reads are recorded on time intervals (e.g. every 1 to 5 minutes) and not at mile markers. Thus for this study they could not be collected exactly at the 40 mile mark, so the 37.0 to 43.0 mile range was used.


average distance of 40.06 miles and a minimum average distance of 39.41 miles, a range of only 0.65 miles. A total of 3,690 valid trips were identified and each trip was assigned a one-hour time bin based on the time of the trip start. After the binning procedure, the trips were subsequently utilized to establish the impact of peak traffic volumes on travel times within the study area. As expected, the results indicate that AM and PM peak travel times (when commuters have the greatest demand for urban interstate highways) had the lowest average speeds and highest average travel times across the 40-mile study area. The travel times displayed in Figure 3 indicate a best travel time of 39.9 minutes to traverse the corridor (1:00 - 1:59 AM) and a worst travel time of 1 hour and 33.4 minutes to traverse the corridor (when trips start between 4:00 - 4:59 PM). Thus, there is a range of 53.5 minutes between the best and worst travel times, indicating that the trip could take nearly one hour longer to complete depending on the time of day travel commences. For additional context, Figure 4 displays these same data in a miles-per-hour (MPH) format.

Figure 3: Average Trip Times across 40-Mile Study Area

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

90.0

100.0

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23Tr

ip D

istr

ubtio

n

Aver

age

Trav

el T

ime

(min

utes

)


Average Travel Time (minutes) and Trip Distribution

Trip Distribution Travel Time (minutes)


Figure 4: Average Trip Speeds across 40-Mile Study Area

To further illustrate how impactful the starting time is for each trip through this urban area, Tables 5 and 6 contain the best and worst times to start a trip across the 40-mile corridor based on average speed and travel time.

Table 5: Best Average Speeds and Travel Times

Start Time Average Speed (MPH)

Travel Time (minutes)

1:00-1:59 AM 60.4 39.9 2:00-2:59 AM 59.8 41.0 5:00-5:59 AM 59.7 40.8 11:00-11:59 PM 59.5 40.9 4:00-4:59 AM 59.4 41.1

Table 6: Worst Average Speeds and Travel Times

Start Time Average Speed (MPH)

Travel Time (minutes)

4:00-4:59 PM 25.8 93.4 5:00-5:59 PM 27.4 89.7 7:00-7:59 AM 28.7 84.8 3:00-3:59 PM 31.8 78.9 8:00-8:59 AM 32.3 76.4

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

0.00

10.00

20.00

30.00

40.00

50.00

60.00

70.00

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Trip

Dis

trib

utio

n

Aver

age

Spee

d (m

ph)


Average Speed (mph) and Trip Distribution

Trip Distribution Average Speed (mph)


Intuitively, the trip-starting periods with the longest travel times and lowest speeds are least attractive to a driver. As mentioned earlier, however, the current HOS rules do not empower drivers to avoid lengthy congested time periods. This is because on-duty time cannot be stopped, and rest time greater than 2 hours and less than 8 hours does not count toward daily rest requirements under the current sleeper berth rules. Time Loss and Cost of Congestion Analysis Next an analysis was conducted to identify total lost time and the cost of trips that begin during peak travel time periods. While average trip times to traverse the same 40-mile interstate corridor were between 39 minutes and 1 hour 33 minutes, depending on trip start time, the average trip time (among the 24 hourly bins) was 57 minutes – or approximately 46 MPH across the entire study corridor. This is not an ideal speed on a corridor that has legal speed limits as high as 65 MPH. The national average cost-per-hour to operate a truck based on real-world motor carrier data is found in ATRI’s annual Analysis of the Operational Costs of Trucking, where the average cost per hour was $63.68.22 This cost represents both vehicle-based costs (e.g. fuel) and driver-based costs (e.g. driver wages and benefits). Using the operational cost figure, Table 7 shows the average cost per trip during each of the weekday hour bins. The lowest cost was $42.32 for trips beginning between 1:00-1:59 AM and the highest average trip cost was $99.11 for trips with a start time of 4:00-4:59 PM. The difference in cost between a single 40-mile trip starting in the 1 AM time bin versus the 4 PM time bin is $56.79.

22 Hooper, A.; D. Murray, An Analysis of the Operational Costs of Trucking: A 2017 Update, American Transportation Research Institute. Arlington, VA. September 2017.


Table 7: Per Truck Trip Costs for the 40-Mile Trip

Trip Start Time Average

Corridor Travel Time (minutes)

Average Speed Average Trip Cost per Truck

12:00-12:59 AM 42.0 59.0 $ 44.58 1:00-1:59 AM 39.9 60.4 $ 42.32 2:00-2:59 AM 41.0 59.8 $ 43.54 3:00-3:59 AM 42.5 59.4 $ 45.06 4:00-4:59 AM 41.1 59.4 $ 43.64 5:00-5:59 AM 40.8 59.7 $ 43.26 6:00-6:59 AM 65.2 39.1 $ 69.24 7:00-7:59 AM 84.8 28.7 $ 90.02 8:00-8:59 AM 76.4 32.3 $ 81.05 9:00-9:59 AM 63.8 39.3 $ 67.66 10:00-10:59 AM 55.3 45.1 $ 58.73 11:00-11:59 AM 51.0 48.5 $ 54.11 12:00-12:59 PM 49.5 50.4 $ 52.51 1:00-1:59 PM 54.3 46.8 $ 57.65 2:00-2:59 PM 61.1 41.0 $ 64.88 3:00-3:59 PM 78.9 31.8 $ 83.69 4:00-4:59 PM 93.4 25.8 $ 99.11 5:00-5:59 PM 89.7 27.4 $ 95.18 6:00-6:59 PM 66.2 37.9 $ 70.29 7:00-7:59 PM 50.8 49.2 $ 53.97 8:00-8:59 PM 47.3 52.4 $ 50.21 9:00-9:59 PM 51.9 49.9 $ 55.03 10:00-10:59 PM 47.7 54.2 $ 50.57 11:00-11:59 PM 40.9 59.5 $ 43.45


The congestion costs for travel below a free-flow average speed of 55 MPH was next calculated for travel across the study corridor (Table 8). The cost-per-trip figure for each hour bin was multiplied by the 1,000 trips that were distributed across the day based on the number of trips observed with the GPS-based trip sample.23 The total additional cost per 1,000 trips across the 40-mile corridor due to congestion is $15,496. If it is assumed that 1,000 trucks take this route per weekday and there are 250 non-holiday weekdays in a year, then the annual congestion cost for trucks operating across this 40-mile route is an additional $3.8 million. Drivers also spend more time driving during peak periods than they would at free flow speed. Using the same number of impacted trips as the cost figures, an extra 240 hours of driving time occurs on this route per day, which is an additional 60,185 hours annually. In summary, for this specific route and utilizing the aforementioned assumptions, $3.8 million in operational costs is lost and drivers face an addition 60,185 hours annually in driving time just to cross this one 40-mile section of highway.

23 Some single direction average annual daily truck traffic (AADTT) readings along this route reach greater 10,000 trucks per day, for more information see: Georgia Department of Transportation (GDOT), Accessed 08/27/18. http://trafficserver.transmetric.com/gdot-prod/tcdb.jsp?siteid=121-5542

http://trafficserver.transmetric.com/gdot-prod/tcdb.jsp?siteid=121-5542


Table 8: Additional Cost of 40-Mile Trip across Study Area

Trip Start Time Additional Cost Per Trip

Additional Driving Time

Per Trip (minutes)

Percent of Daily Trips within

Hour Bin

Additional Driving Time

Per 1,000 Trips (hours)

Additional Cost Per 1,000 Trips

12:00-12:59 AM $ - 0.0 2.60% 0.0 $ - 1:00-1:59 AM $ - 0.0 2.68% 0.0 $ - 2:00-2:59 AM $ - 0.0 3.93% 0.0 $ - 3:00-3:59 AM $ - 0.0 3.98% 0.0 $ - 4:00-4:59 AM $ - 0.0 4.28% 0.0 $ - 5:00-5:59 AM $ - 0.0 3.55% 0.0 $ - 6:00-6:59 AM $ 23.15 21.6 1.68% 6.0 $ 388.90 7:00-7:59 AM $ 43.92 41.2 1.54% 10.6 $ 678.50 8:00-8:59 AM $ 34.95 32.7 2.71% 14.8 $ 947.26 9:00-9:59 AM $ 21.57 20.1 3.71% 12.4 $ 800.81 10:00-10:59 AM $ 12.64 11.7 5.72% 11.2 $ 722.83 11:00-11:59 AM $ 8.01 7.3 5.99% 7.3 $ 479.99 12:00-12:59 PM $ 6.41 5.8 6.91% 6.7 $ 443.06 1:00-1:59 PM $ 11.55 10.7 7.02% 12.5 $ 810.82 2:00-2:59 PM $ 18.78 17.5 7.24% 21.1 $ 1,359.09 3:00-3:59 PM $ 37.60 35.2 6.10% 35.8 $ 2,292.51 4:00-4:59 PM $ 53.02 49.7 5.04% 41.8 $ 2,672.36 5:00-5:59 PM $ 49.09 46.0 3.90% 29.9 $ 1,915.63 6:00-6:59 PM $ 24.20 22.6 4.61% 17.3 $ 1,114.77 7:00-7:59 PM $ 7.87 7.2 4.72% 5.7 $ 371.27 8:00-8:59 PM $ 4.12 3.7 3.39% 2.1 $ 139.59 9:00-9:59 PM $ 8.94 8.2 2.49% 3.4 $ 222.91 10:00-10:59 PM $ 4.48 4.0 3.04% 2.0 $ 135.97 1:00-11:59 PM $ - 0.0 3.17% 0.0 $ -


Part II: HOS Flexibility Demonstration Scenarios As was demonstrated through the Part I: GPS Data Analysis, the congestion costs along the study route are substantial. Infrastructure investment is one strategy for mitigating congestion, but an alternate approach with much lower costs is to provide drivers with the HOS flexibility needed to avoid the worst congestion. In this section, Part II: HOS Flexibility Demonstration Scenarios, a split-sleep option is utilized to avoid rush hour travel in the congested area that was described in the previous section. Using the congestion measures from the earlier GPS Data Analysis, the movement of two truck trip scenarios through the study area is modeled to demonstrate the application of an innovative sleeper berth concept. The first truck trip scenario operates under current HOS rules and is described below in the Current Rules Scenario. The second trip scenario operates under flexible sleeper berth rules (utilizing a 6/4 split with a pause in the 14-hour on-duty rule), and is described in the Flexible Rules Scenario. Assumptions. There are several conservative assumptions built into this model so that the two trips are comparable, and to ensure that data related to the key research question, “can drivers avoid severe congestion within the 40-mile study area utilizing flexible HOS options?” is isolated and measured. Both scenarios use the truck-trip route illustrated in the Figure 5 map, which includes travel through the study area. The operational requirements of this trip are set by the needs of the customer to move goods from the origin to the destination. The departure times are set based on shipper schedule requirements for when the truck can be loaded and readied for departure, and cannot be delayed due to the 14-hour daily on-duty window starting at 9:00 AM when the driver first goes on-duty. Likewise, the delivery at the destination cannot be made until the destination facility is open the next morning. In both scenarios an irregular route long-haul driver working for a for-hire carrier leaves Burlington, NC at 10:30 AM on Day 1. Due to the aforementioned operational requirements the driver must then stage the vehicle approximately 585 miles away in western Alabama in advance of a morning delivery. The study area corridor is utilized as part of the trip since there are no viable alternate routes. In the scenarios it is assumed that average speed outside of the study area to the east averages 58.4 MPH and west of the study area averages 60.0 MPH. These average moving speeds are sourced from a county-to-county truck trip table produced by ATRI using ATRI’s empirical truck GPS data.24 Finally, the time required to find a truck parking space for either the 30-minute rest period, the 10-hour rest period, or the split sleeper time is assumed to be included in the average travel speeds.

24 In ATRI’s county-to-county trip matrix, trips starting in all U.S. counties are paired with trips ends in other counties. Among the key performance measures assigned to each trip is moving time between counties. These measures are aggregated to develop average moving times between counties.


Figure 5: HOS Flexibility Demonstration Route


Current Rules Scenario The hourly trip activities of the first “Current Rules Scenario” are detailed in Table 9, and represent operations that are in compliance with the current HOS regulations. In this scenario the driver enters on-duty status at 9 AM and conducts pre-trip/load activities for 1.5 hours, leaving Burlington, NC at 10:30 AM. The driver averages 58.4 MPH for the first 3.5 hours of drive time, and finds a location to take the required 30-minute rest break after 5 hours on-duty. The driver continues the trip after the 30-minute rest break, entering the congested 40-mile study area at 4:30 PM when the average speed is 25.8 MPH and the additional marginal operating cost of travel (beyond free-flow speed costs) through the study area due to traffic delay is approximately $53.00. The driver then spends approximately 1 hour, 30 minutes to travel across the 40-mile corridor averaging 25.8 MPH. The first day of travel comes to an end at 9:45 PM with a pre-planned stop at a rest area near Boligee, AL. The driver enters a 10-hour rest period with 1 hour, 14.5 minutes of remaining on-duty time and 14.5 minutes of available drive time. Any unexpected delay would likely have prevented the driver from arriving at the pre-planned rest area. The following day (Day 2) the driver must start at 9:00 AM (EST) to reach the delivery appointment on time.


Table 9: Current Rules Scenario


Flexible Rules Scenario

In this next scenario, the Flexible Rules Scenario, costs and driving time for the same trip are decreased and available rest time is increased through the use of a 4/6 split sleeper berth (Table 10). The same assumptions that applied in the Current Rules Scenario were applied to this scenario, including the same origin, destination, and initial departure time. As in the previous scenario, the driver departs at 10:30 AM. As the driver nears the congested study area, and as rush hour approaches, the driver stops for a 4-hour rest period. This is after driving for 5 hours and being on-duty for 6.5 hours. This stop allows the driver to avoid congestion and also covers the required 30-minute rest break. As a result of the 4-hour rest period the driver is specifically able to avoid the congested travel period of 4:00 PM to 7:59 PM when average speeds can be as low as 25.8 MPH. At 7:30 PM driving resumes after 4 consecutive hours of rest, and the driver enters the study corridor at 8:00 PM when the average speed to cross the corridor is 52.4 MPH. After traveling through the study area the driver averages 60 MPH. After 10 hours of total driving time Day 1 comes to a conclusion with the planned stop near Boligee, MS at 12:30 AM (EST). The driver takes a second rest period of 6 hours, accumulating a total of 10 hours of rest time by 6:30 AM (EST).


Table 10: Flexible Rules Scenario

Day Time Bin (EST) Activity 14-Hour On-Duty

Total Hours Driving

Total Rest

Hours

Average Speed

Cumulative Trip

Distance

Day 1 9:00-9:29 AM Trip Preparation 0.5

9:30-9:59 AM Trip Preparation 1.0

10:00-10:29 AM Trip Preparation 1.510:30-10:59 AM Driving 2.0 0.5 58.4 2911:00-11:29 AM Driving 2.5 1.0 58.4 5811:30-11:59 AM Driving 3.0 1.5 58.4 8812:00-12:29 PM Driving 3.5 2.0 58.4 11712:30-12:59 PM Driving 4.0 2.5 58.4 146

1:00-1:29 PM Driving 4.5 3.0 58.4 1751:30-1:59 PM Driving 5.0 3.5 58.4 2042:00-2:29 PM Driving 5.5 4.0 58.4 2342:30-2:59 PM Driving 6.0 4.5 58.4 2633:00-3:29 PM Driving 6.5 5.0 58.4 2923:30-3:59 PM Rest 0.54:00-4:29 PM Rest 1.04:30-4:59 PM Rest 1.55:00-5:29 PM Rest 2.05:30-5:59 PM Rest 2.56:00-6:29 PM Rest 3.06:30-6:59 PM Rest 3.57:00-7:29 PM Rest 4.07:30-7:59 PM Driving 7.0 5.5 58.4 3218:00-8:29 PM Driving 7.5 6.0 52.4 3478:30-8:59 PM Driving 8.0 6.5 56.0 3759:00-9:29 PM Driving 8.5 7.0 60.0 4059:30-9:59 PM Driving 9.0 7.5 60.0 435

10:00-10:29 PM Driving 9.5 8.0 60.0 46510:30-10:59 PM Driving 10.0 8.5 60.0 49511:00-11:29 PM Driving 10.5 9.0 60.0 52511:30-11:59 PM Driving 11.0 9.5 60.0 55512:00-12:29 AM Driving 11.5 10.0 60.0 58512:30-12:59 AM Rest 4.5

1:00-1:29 AM Rest 5.01:30-1:59 AM Rest 5.52:00-2:29 AM Rest 6.02:30-2:59 AM Rest 6.53:00-3:29 AM Rest 7.03:30-3:59 AM Rest 7.54:00-4:29 AM Rest 8.04:30-4:59 AM Rest 8.55:00-5:29 AM Rest 9.05:30-5:59 AM Rest 9.56:00-6:29 AM Rest 10.06:30-6:59 AM Extra Rest 10.57:00-7:29 AM Extra Rest 11.07:30-7:59 AM Extra Rest 11.58:00-8:29 AM Extra Rest 12.08:30-8:59 AM Extra Rest 12.5

Day 2 9:00-9:29 AM Driving/Delivery 0.5 0.25 30.0 7.5


The differences between the Current HOS and Flexible HOS Scenarios are displayed in Table 11. The driver in the Current Scenario drives an extra 45.5 minutes and uses 1 hour and 15.5 minutes more of the 14-hour on-duty window time limit.

Table 11: Current vs. Flexible Single Day Statistics

Scenario Drive Time 14-Hour On-Duty Window

Current 10 hr 45.5 min 12 hr 45.5 min Flexible 10 hr 00 min 11 hr 30 min

Flexible HOS Savings 45.5 min saved 1 hour 15.5 min saved For the Flexible scenario, the application of the 7/3 and the 5/5 split rest break both have better outcomes than those of the Current scenario. Both the 7/3 and 5/5 ensure that average travel speeds through the study area are at least 49 MPH (instead of the 25.8 MPH average in the Current scenario) and allow for completion of travel through the study area in less than an hour. It should be noted also that the 2-hour break which currently does exist would at best allow for average speeds of approximately 37 MPH within the study area in this scenario.


SUMMARY OF RESULTS AND CONCLUSIONS Trucking is not a one-size-fits-all industry. Truckers in the U.S. begin a day of work in thousands of different cities and towns, and drive to myriad destinations as they crisscross the nation. No two trips are the same; even with identical origins and destinations, congestion on most trips varies due to time of departure, ultimately resulting in a variety of travel times. The opportunity for a driver to adapt to changing conditions and congestion levels throughout a day is critical, and could be greatly enhanced with the addition of flexible sleeper berth rules to the current HOS regulations. In this report the research team provides an assessment of how flexible HOS rules could be applied to enable a single representative driver the ability to avoid congestion in a single study area. There are hundreds, if not thousands, of severe chokepoints in the nation where these rules could be applied by HOS-regulated drivers. The time savings, cost savings, and decreased drive time that could result from implementation of a 7/3, 6/4 or 5/5 split sleeper berth rule, while unknown, are likely quite large. On a national scale, HOS flexibility has the potential to decrease the number of hours it takes to complete the 273.9 billion miles driven by combination trucks annually in the U.S.25 While the total miles driven in the U.S. is a static figure – the marketplace requires this scale of goods movement – the overall driving time needed to deliver these goods can decrease if congestion can be avoided. This analysis models two scenarios with a driver traveling across a heavily congested 40-mile urban corridor as part of a 585-mile trip using current and flexible HOS options. Utilizing the flexible option, traversing the 40 miles required 45.5 minutes less driving time because a 4-hour rest break allowed the driver to avoid a relatively small (40-mile) segment of urban interstate during peak travel times. If only 25 truck trips per day avoided the congested weekday time period presented on the study segment, truck drivers would drive 4,700 fewer hours annually to move the same goods the same distance.26 This equates to operational cost savings of more than $300,000 per year for the 25-truck sample at that single location. The Atlanta scenario represents only one congested route in a single city. The Atlanta region has several dozen congested locations which impact many thousands of truck trips each day. Likewise, similar rush hour congestion is present in most major U.S. cities; some cities such as Chicago and New York, have far greater impacts. Recognizing that these congestion occurrences happen every weekday across the country, it is reasonable to assume a very conservative estimate of 500 similar routes in the U.S. where congestion could be avoided using flexible HOS options. Extrapolating from the Atlanta scenario, a reasonable national average for this type of route, assuming that only 25 truck trips avoid the 500 locations, it can be concluded that more than 2.3 million hours of driving could be saved using the flexible HOS options, with an annual direct savings in truck operating costs of more than $150,000,000. This calculation does not include societal benefits associated with decreases in truck-related 25 American Trucking Associations, American Trucking Trends 2017, Arlington, VA, 2017. 26 Assumes 45.5 minutes of driving time is saved on average per day by 25 drivers across 250 non-holiday weekdays.


congestion and more efficient supply chains. There is a clear benefit in driving fewer hours to move the same distance – drivers spend less time operating in less-than-ideal conditions while at the same time decreasing industry operating costs.

Documents

New TECHNICAL MEMORANDUM: HOURS-OF-SERVICE FLEXIBILITY · 2018. 8. 28. · Vice President of Inbound Transportation . Wal-mart Stores, Inc. Victoria King . Vice President Public Affairs