Jobs for Teams

April 2016

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Industry News Continued www.jobsfor teams.com JOBS for TEAMS | 42 (required of any rule of economic sig- nifi cance) accompanying the ELD rule itself shows some very large fi gures on both the annualized costs and benefi ts sides. The single largest benefi t — well above the annual $572.2 million worth in crash reductions the agency estimates for the rule's safety-related benefi ts — is in driver time saved using ELDs. The agency estimated a whopping $1.88 billion worth of time saved by drivers who would no longer have to fi ll out and submit paper log- books to carriers. Here's how the entire $2.44 billion of clerical/paperwork-related savings break down on the whole: In comments on the rule, the California Construction Trucking Association (since renamed the Western States Trucking Association) questioned such benefi ts, particularly as related to driver's time, as not refl ecting the reality today of mileage and/or percentage pay, where time saved is only indirectly related to dol- lars. CCTA/WSTA "believed that while some calculated time savings may be present — especially on the fl eet management side of the equation — assigning a dollar value to the time drivers spend completing paperwork is an example of government ma- nipulating data to justify a regulation," FMCSA noted in text accompanying the rule. OOIDA has made this argument as well. A briefi ng document that accompanied a September 2013 meeting between White House Offi ce of Management and Budget staff and OOIDA representatives noted that "truckers are generally paid by-the- mile, so there is no appreciable sav- ings from not requiring the trucker to fi ll out the paper log." Furthermore, the briefi ng docu- ment continued, "With 50 percent of the industry being one-truck opera- tions, the vast majority of carriers do not have clerical staff." Estimates of back-offi ce benefi t, by the latter argument, wouldn't apply in the same way to independents' operations as those of larger carri- ers. The rule appears to do little if anything to control for such dif- ferences in its cost-benefi t, though FMCSA counters the charges related specifi cally to time savings as noting that it's standard operating procedure for rules such as this: "FMCSA as- sumes that a driver's time is valuable whether or not that driver receives an hourly wage for their time. In the rule, we value the time when the driver should be on duty at an hourly wage rate for his or her time, exclud- ing benefi ts. This is common practice in Federal cost benefi t analyses." My question today is directed par- ticularly at those who've transitioned to e-logs with their leasing carrier. What's the reality on actual time saved week to week, year to year, with e- logs? Is the annual time you save from not having to fi ll out a paper log, and

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