PRA-2126-0054 SS CMV Marking Requirements (10.12.18)

Department of Transportation

Office of the Chief Information Officer

SUPPORTING STATEMENT

Commercial Motor Vehicle Marking Requirements

INTRODUCTION

This is to request the Office of Management and Budget (OMB) to renew the current approval of the OMB Control Number 2126-0054, “Commercial Motor Vehicle Marking Requirements,” information collection request (ICR), which is currently due to expire on August 31, 2018, and extend it for three years.

FMCSA promulgated a final rule titled, “Lease and Interchange of Vehicles; Motor Carriers of Passengers,” (80 FR 30164) dated May 27, 2015, (Attachment A). The 2015 final rule modified how leased and interchanged passenger-carrying vehicles operated by for-hire and private motor carriers of passengers must be marked. These marking regulations require vehicles and intermodal equipment to display certain information about motor carriers or intermodal equipment providers (IEPs) engaging in interstate transportation. The current ICR estimated a higher burden in the first year of the rule, which has now passed.

Part A. Justification

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

The USDOT number is used to identify all motor carriers in FMCSA's registration and information systems. It is also used by States as the key identifier in the Performance and Registration Information Systems Management (PRISM) system, a cooperative Federal/State program that makes motor carrier safety a requirement for obtaining and maintaining commercial motor vehicle registration and privileges.

As noted in the 2015 final rule, FMCSA has authority to require motor carriers to conduct recordkeeping, reporting, and disclosure of information (see 49 U.S.C. 31133(a)(8) and 31133(a)(10)) (Attachment B).

49 U.S.C. 31133. General powers of the Secretary of Transportation

(a) GENERAL.—In carrying out this subchapter and regulations prescribed under section 31102 of this title, the Secretary of Transportation may—

* * *

(8) prescribe recordkeeping and reporting requirements;

* * *; and

(10) perform other acts the Secretary considers appropriate.

Vehicle marking requirements are intended to ensure that FMCSA, the National Transportation Safety Board (NTSB), and State safety officials are able to identify motor carriers and correctly assign responsibility for regulatory violations during inspections, investigations, compliance reviews, and crash studies. These marking requirements will also provide the public with beneficial information that could also assist in identifying carriers for the purposes of commerce, complaints or emergency notification. (80 FR 30164, 30166).

The burden for the CMV marking requirement was initially documented in the final rule entitled, “Federal Motor Carrier Safety Regulations: General Commercial Motor Vehicle Marking,” (65 FR 35287), June 2, 2000 (Attachment C).

FMCSA discovered that the annual burden for the CMV marking requirement needed to be updated during the development of the notice of proposed rulemaking (NPRM) entitled, “Lease and Interchange of Vehicles; Motor Carriers of Passengers,” (78 FR 57822), September 20, 2013 (Attachment D). The Agency's regulation governing the marking of CMVs is referenced at 49 CFR 390.21.

This information collection supports the DOT strategic goals of safety and organizational excellence.

2. HOW, BY WHOM, AND FOR WHAT PURPOSE IS THE INFORMATION USED

The marking requirements apply to motor carriers and intermodal equipment providers (IEPs) engaging in interstate transportation. The Agency provides performance-based requirements for the marking but does not require a specific method of marking as long as the method complies with FMCSA’s regulations. These requirements ensure that FMCSA, NTSB and the States are able to identify motor carriers and correctly assign responsibility for regulatory violations during inspections, investigations, compliance reviews, and crash studies. These requirements will also provide the public with beneficial information that could also assist in identifying carriers for the purposes of commerce, complaints or emergency notification.

3. EXTENT OF AUTOMATED INFORMATION COLLECTION

Some IEPs mark their equipment electronically in a database rather than on the vehicle itself. It calls for a limited amount of information to identify the registrant and the equipment in question.

4. EFFORTS TO IDENTIFY DUPLICATION

There are no other Federal agencies that require commercial motor vehicle marking.

5. EFFORTS TO MINIMIZE THE BURDEN ON SMALL BUSINESSES

If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. Based on Small Business Administration size standards, FMCSA has determined that motor carriers of property with 148 power units or fewer, and passenger carriers with 93 power units or fewer, are small businesses.¹   The marking requirements impose minimal burden on small businesses. Considerable flexibility is afforded in meeting those requirements. Marking may be painted on the vehicles, applied with stencils, decals, or affixed by any other means, including paper and electronic marking (in the case of IEPs), provided the method(s) meets the requirements. The cost of marking includes the cost of materials, labor, and the opportunity cost of the vehicles' time out of service (negligible).

6. IMPACT OF LESS FREQUENT COLLECTION OF INFORMATION
   
   

The appropriate marking of vehicles, owned, leased or rented, assists FMCSA in identifying motor carriers and monitoring the safety performance and crash involvement, thereby helping the Agency identify unsafe, high risk motor carriers. This ICR also greatly assists FMCSA and its State partners in meeting the standard burden of proof for enforcement actions against non-compliant carriers, as well as assists State partners during accident investigations in determining the responsible motor carrier involved in a CMV crash. The regulations include a marking requirement, which depending on the need and method could be permanent or temporary. Only enough information is collected to maintain tracking of intermodal equipment.

7. SPECIAL CIRCUMSTANCES

There are no special circumstances associated with this ICR.

8. COMPLIANCE WITH 5 CFR 1320.8
   
   

On April 24, 2018 (83 FR 17885) (See Attachment E), FMCSA published a notice in the Federal Register with a 60-day public comment period to announce this proposed information collection request. The agency received two comments, though only one spoke to markings.

On September 20, 2013 (78 FR 57822) (See Attachment D), FMCSA published an NPRM in the Federal Register requesting public comments on a variety of proposals, including changes to the marking requirements for buses and motorcoaches being rented or leased. Several passenger carriers and carrier organizations submitted comments objecting to the burdens associated with the proposal, though none singled out marking as the primary concern.

9. PAYMENTS OR GIFTS TO RESPONDENTS
   
   

No payments or gifts are provided.

10. ASSURANCE OF CONFIDENTIALITY

There are no confidential reporting requirements associated with this information collection. The requirement is limited to marking vehicles operated in interstate commerce with an FMCSA-furnished USDOT registration number.

11. JUSTIFICATION FOR COLLECTION OF SENSITIVE INFORMATION
    
    

The information requested and collected is not of a sensitive nature.

12. ESTIMATE OF BURDEN HOURS FOR INFORMATION REQUESTED

The estimate of burden hours depends on four factors: the type of entity, size of entity, type of vehicle ownership (owned vs. leased), and the type of marking.

Component 1: Freight-carrying commercial motor carriers (i.e., trucking companies)

• Small carriers are assumed to use individual stencil kits.

• Medium carriers are assumed to use larger stencil kits.

• Large carriers are assumed to use individually developed decals.

The estimated average time for affixing a DOT number is 12 minutes (assuming an average of 7 digits), and the estimated average time for affixing a carrier name is 14 minutes (assuming an average of 21 alphanumeric characters); these estimates incorporate a number of factors that vary, including marking via stencils versus decals, amount of cleaning required, weather, and whether a new or existing vehicle is being marked. These estimates are based on responses to the Federal Highway Administration (FHWA, the predecessor organization to the FMCSA) interviews with metropolitan Washington, D.C. signage companies and Agency employees formerly employed by the motor carrier industry, which were undertaken during the original rulemaking process. This rule was published June 3, 2000.⁽¹⁾ The combined total is 26 minutes (0.433 hours).

FMCSA’s Motor Carrier Management Information System (MCMIS) and Safety Measurement System (SMS) database indicates that there are 535,309 active interstate freight carriers and intrastate hazardous materials carriers operating approximately 4,230,195 power units, as of a September 29, 2017, snapshot. To estimate Component 1’s burden on a consistent basis relative to Components 2 and 3, these carrier and (correspondingly) power unit counts are projected forward to the years 2018, 2019, and 2020, and averaged across those three years to account for an estimated annual compound growth rate of 0.275%.⁽²⁾ Table 1 shows annual carrier growth rates projected through 2020. The average carrier population from 2018 to 2020 is 538,258. The average power unit count is 4,253,504.

Table 1. Freight Industry Growth

	2017	2018	2019	2020	3-Year Average
Carriers	535,309	536,781	538,257	539,737	538,258
Power Units	4,230,195	4,241,828	4,253,493	4,265,190	4,253,504

The U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) published a report in 1994 which suggests that the average operational life of a heavy-duty commercial motor vehicle was 14.7 years.⁽³⁾ Therefore, the Agency assumes that one new freight-carrying CMV is acquired every 14.7 years.

In addition, because of the absence of more reliable data on the sale and resale of used freight-carrying CMVs, for purposes of this analysis and to simplify calculations, the Agency assumes that the average turnover of freight-carrying vehicles is not more frequent than once every 3 years. The implication of this assumption is that on an annual basis, one-third of freight-carrying CMVs, less newly-acquired CMVs, are resold in a secondary market and undergo re-identification.

Finally, the Final Regulatory Evaluation for the FMCSA’s Inspection, Repair, and Maintenance Requirements for Intermodal Equipment Providers suggests that the average life of a weatherproof vinyl label (as attached to an IEP) is 3 years.⁽⁴⁾ Without more authoritative information on the lifetimes of both freight-carrying motor vehicles and other types of labeling (e.g., paper), the Agency uses this as an estimate of all freight-carrying CMVs and all types of labels (realizing that some labels will likely last less than 3 years [e.g., paper] and some will likely last more than 3 years). Therefore, FMCSA assumes that on an annual basis one-third of freight-carrying CMVs that are retained by the owner must undergo relabeling (due to the label reaching the end of its useful life).

With these assumptions in mind, the Agency estimates the following:

• The average annual number of newly-acquired freight-carrying CMVs is 289,354 (4,253,504 power units ÷ 14.7 years average operational life).

• The average annual number of resold freight-carrying CMVs, which require re-identification, is estimated to be 1,321,383 ([4,253,504 power units – 289,354 newly acquired power units] ÷ 3 years average turnover rate).

• The average annual number of freight-carrying CMVs retained by the owner and undergo relabeling due to the label reaching the end of its useful life is 880,922 ([4,253,504 power units – 289,354 newly acquired power units – 1,321,383 resold and relabeled power units] ÷ 3 years average label useful life).

This results in an estimated 2,491,659 freight-carrying CMVs (289,354 + 1,321,383 + 880,922) impacted by marking requirements annually, which will generate 2,491,659 responses annually.

The Agency estimates it takes approximately 0.2 hours to affix a DOT number and approximately 0.233 hours to affix a carrier name, which results in a total annual burden of 1,078,888 hours (2,491,659 responses × 0.433 hours per response).

The estimated total number of annual respondents (i.e., impacted freight-carrying motor carriers) is 315,306 (2,491,659 impacted vehicles ÷ 4,253,504 total vehicles × 538,258 total freight carriers).

To estimate the burden hour cost for Component 1, the Agency assumes that respondent occupations undertaking the marking task correspond to Bus and Truck Mechanics and Diesel Engine Specialists. The mean hourly wage of Bus and Truck Mechanics and Diesel Engine Specialists of the General Freight Trucking industry (North American Industry Classification System [NAICS] code NAICS 484100) is $20.51.⁽⁵⁾

To arrive at a loaded wage, the Agency first estimated a load factor of 1.421 by dividing the total cost of compensation for private industry workers of the trade, transportation, and utilities industry ($27.44) by the average cost of hourly wages and salaries ($19.31) as reported by the Bureau of Labor Statistics in its Employer Costs for Employee Compensation for March 2017.⁽⁶⁾ Multiplying mean hourly wage by the load factor results in a loaded hourly wage of $29.14. Therefore, the estimated annual total burden hour cost for Component 1 is $31,438,796 ($29.14 × 1,078,888 hours).

Component 1 Summary

Estimated Total Annual Burden: 1,078,888 hours.

Estimated Annual Number of Respondents: 315,306.

Estimated Annual Number of Responses: 2,491,659.

Estimated Annual Burden Hour Cost: $31,438,796.

Component 2: Passenger-carrying commercial motor carriers

• Owned passenger-carrying vehicles are assumed to use decals or stencils for permanent signage.

• Lease and rented passenger-carrying vehicles are assumed to use paper signage, and incur a negligible burden.

The passenger carrier population impacted by the marking requirements consists of motor carriers transporting passengers in interstate commerce in CMVs, as defined by 49 CFR 390.5 that either: (1) have a gross vehicle weight rating or gross vehicle weight of at least 10,001 pounds, whichever is greater; (2) are designed or used to transport more than 8 passengers (including the driver) for-hire; or (3) are designed or used to transport more than 15 passengers (including the driver) and are not used to transport passengers for-hire.

According to MCMIS and SMS data as of September 29, 2017, 15,756 carriers are in active operations (note that this value is comprised of 12,891 distinct carriers; carriers operating in multiple categories covered by the final rule are counted as multiple carriers in such cases). Of the 15,756 carriers, 9,627 are for-hire carriers and 6,129 are privately owned, not for compensation business or non-business carriers.

The analysis in support of the final rule estimates that 90 percent of private (not for compensation) carriers are not impacted by the final rule (as most private passenger carriers do not lease vehicles to a significant degree). Therefore, 10,240 passenger carriers are subject to the rule (9,627 authorized for-hire carriers and 0.1 × 6,129 private, not-for-compensation business or non-business carriers) according to MCMIS and SMS data as of September 29, 2017.

As in Component 1, the Agency applied the 0.275% annual compound growth rate, resulting in an annualized affected carrier count of 10,296. According to 2017 MCMIS and SMS data, the average carrier in this group operates 20 power units. Assuming this ratio remains steady, it is estimated that these 10,296 carriers will operate approximately 205,920 power units (10,296 × 20).

FMCSA assumes:

• Approximately 185,328 (or 90 percent of the 205,920) power units are owned and assumed to use decals or stencils for permanent signage.

• The remaining 20,592 (or 10 percent of the 205,920) power units are term-leased.

Average annual rates of the resale of used passenger-carrying power units could not be readily located. To arrive at an estimate, the Agency makes equivalent assumptions about the proportion of newly acquired and re-identified passenger-carrying power units as was made for freight-carrying CMVs (i.e., every year nearly 1/15 of current fleet are newly acquired, 1/3 of current fleet are resold and re-identified, and 1/3 of the remaining are re-identified due to label replacement).

With these assumptions in mind, the Agency estimates the following:

• The average annual number of newly-acquired owned passenger-carrying power units is 12,607 per year (185,328 owned passenger-carrying power units ÷ 14.7 years average operational life).

• The average annual number of resold and re-identified passenger-carrying power units is 57,574 ([185,328 power units – 12,607 newly acquired power units] ÷ 3 years average turnover rate).

• The average annual number of passenger-carrying power units retained by the owner and undergo relabeling due to the label reaching the end of its useful life is 38,382 ([185,328 power units – 12,607 newly acquired power units – 57,574 resold and relabeled power units] ÷ 3 years average label useful life).

This results in an estimated 108,563 owned passenger-carrying power units (12,607 + 57,574 + 38,382) impacted by marking requirements annually, which will generate 108,563 responses annually.

Similarly, the estimated number of newly acquired leased passenger-carrying power units is approximately 1,401 per year (20,592 leased passenger-carrying power units ÷ 14.7 years average power unit operational life); the estimated number of resold and re-identified leased passenger-carrying power units is estimated to be 6,397 per year ([20,592 leased passenger-carrying power units – 1,401 newly acquired leased power units] ÷ 3 years average re-identification rate); and the estimated number of leased passenger-carrying power that undergo relabeling due to the label reaching the end of its useful life is 38,382 ([20,592 leased passenger-carrying power units – 1,401 newly acquired leased power units – 6,397 resold and re-identified leased passenger-carrying power units] ÷ 3 years average re-identification rate) is 4,265. This results in an estimated 12,063 leased passenger-carrying power units impacted by marking requirements and will generate 12,063 responses annually.

Marking of owned vehicles (which use decals or stencils, see above) takes 26 minutes (0.433 hours), consistent with other previous estimates calculated herein. Marking of leased vehicles (which use paper signs, see above) takes a negligible amount of time (i.e., assumed 0 minutes).

The estimated annual number of burden hours attributed to Component 2 is 47,008 hours (0.433 hours × 108,563 owned power units marked with decals or stenciled marking] + [0 minutes per hour × 12,063 leased power units marked with paper signage]). The estimated total number of annual respondents (i.e., passenger-carrying motor carriers) is 6,031 ([108,563 impacted owned vehicles + 12,063 impacted leased vehicles) ÷ 205,920 total vehicles] × 10,240 passenger-carrying carriers).

To estimate the burden hour cost for Component 2, the Agency assumes that respondent occupations undertaking the marking task correspond to Bus and Truck Mechanics and Diesel Engine Specialists. The mean hourly wage of Bus and Truck Mechanics and Diesel Engine Specialists of the Interurban and Rural Bus Transportation industry (NAICS code 485200) is $24.06.⁽⁷⁾ Applying the estimated a load factor of 1.421 results in a loaded hourly wage of $34.19. Therefore, the annual estimated burden hour cost for Component 2 is $1,607,204 ($34.19 × 47,008 hours).

Estimated Total Annual Burden: 47,008 hours.

Estimated Annual Number of Respondents: 6,031.

Estimated Annual Number of Responses: 120,626.

Estimated Annual Burden Hour Cost: $1,607,204.

Component 3: Intermodal equipment providers (IEPs)

• The majority of IEPs, about 90 percent, mark their equipment electronically into the Intermodal Association of North America (IANA) database.

• The remaining 10 percent are assumed to use decals or stencils.

The MCMIS database indicates that there are 105 registered IEPs comprising 555,000 (rounded to the nearest thousand) intermodal trailers, chassis and equipment owned or leased as of a January 23, 2015 snapshot.⁽⁸⁾ The number of IEPs has been variable in recent years with no clear trend while the number of intermodal trailers, chassis and equipment has remained steady. Due to the lack of a clear upward trend in the number of IEPs in recent years and the static number of IEP-owned or leased equipment, the Agency assumes these values will remain representative of the IEP industry.

The burden hours associated with the marking requirements will only include those incurred by the 10 percent of the impacted IEP population that does not elect to input their equipment information into the IANA database. The total number of IEPs (or respondents) impacted by the marking rules is approximately 11 (105 registered IEPs × 0.1). The estimated count of intermodal trailers/chassis/equipment not marked electronically is assumed to be 10 percent of 555,000, or approximately 55,500.

As noted previously, the Final Regulatory Evaluation for the FMCSA’s Inspection, Repair, and Maintenance Requirements for Intermodal Equipment Providers suggests that the average life of a weatherproof vinyl label (as attached to an IEP) is 3 years.⁽⁹⁾ It also suggests that the operational life of an intermodal chassis is 14.7 years (and thus nearly 1/15 of the intermodal chassis pool turns over each year).¹⁰ Similar to the calculations performed in Component 1, the Agency estimates the count of newly acquired intermodal trailers/chassis/equipment is 3,776 per year (55,500 decal-marked intermodal equipment ÷ 14.7 years average intermodal chassis life); and the number of existing intermodal trailers/chassis/equipment requiring re-identification is estimated to be 17,241 per year ([55,500 decal-marked intermodal equipment – 3,776 newly acquired units] ÷ 3 years average weatherproof vinyl label life).

Thus, the total estimate of intermodal trailers/chassis/equipment impacted by the marking requirements is 21,017 annually (3,776 + 17,241). The estimated total number of annual burden hours attributed to marking by this segment is 9,100 (0.433 hours × 21,017 intermodal chassis, trailers, and equipment owned or leased by IEPs not input into the IANA database per year, rounded). The total number of IEPs (or respondents) impacted by the marking rules is approximately 11.

To estimate the burden hour cost for Component 3, the Agency assumes that respondent occupations undertaking this marking task correspond to Bus and Truck Mechanics and Diesel Engine Specialists. The mean hourly wage of Bus and Truck Mechanics and Diesel Engine Specialists of the General Freight Trucking industry (NAICS 484100) is $20.51.⁽¹¹⁾ Applying the estimated a load factor of 1.421 results in a loaded hourly wage of $29.14. Therefore, the annual estimated burden hour cost for Component 3 is $265,174 ($29.14 × 9,100 hours).

Estimated Total Annual Burden: 9,100 hours.

Estimated Annual Number of Respondents: 11.

Estimated Annual Number of Responses: 21,017.

Estimated Annual Burden Hour Cost: $265,174.

Summary

The totals number of respondents (number of carriers and IEPs with impacted CMVs and intermodal equipment), responses (number of impacted CMVs and intermodal equipment), and annual hour burden all three components of this ICR are presented below in Table 2.

Table 2. Summary of Average Annual Respondents, Responses, and Burden by Component

Component	Number of Respondents	Number of Responses	Burden Hours
Component 1: Freight Carriers	315,306	2,491,659	1,078,888
Component 2: Passenger Carriers	6,031	120,626	47,008
Component 3: IEPs	11	21,017	9,100
Total	321,348	2,633,302	1,134,996

Estimated Average Annual Burden Hours: 1,134,996.

Estimated Average Annual Respondents: 321,348.

Estimated Average Annual Responses: 2,633,302.

13. ESTIMATE OF TOTAL ANNUAL COSTS TO RESPONDENTS

The estimated total annual costs to respondents vary by entity, as explained above. The total annual cost per respondent depends on the material cost per vehicle. The marking requirements call for the display of the carrier’s name and USDOT number. The marking must be displayed on both sides of the vehicle (equipment).

Due to the diversity of carriers and the dynamics of renting and leasing of vehicles and equipment, the estimate of cost is based on an annual growth rate of 0.275 percent. The CMV count is of owned, leased and rented vehicles combined. The annual cost per carrier is estimated based on the average size of carrier, as explained below.

1. Freight-carrying commercial motor carriers.

The vast majority of these carriers currently use stencils or decals for marking, as these are the cheapest methods. The paper option is not conducive to this type of carrier. The distribution of freight carriers by size is presented below in Table 3. The majority (85 percent) of those carriers is in the smallest category (1–6 CMVs).

Table 3. 2017 Distribution of Freight Carriers by Size*

Carrier Size	Carriers	Carriers percent	CMVs	CMVs percent
1 to 6	455,082	85.0%	875,881	20.7%
7 to 19	53,741	10.0%	584,629	13.8%
20 to 100	22,511	4.2%	885,343	20.9%
101+	3,975	0.7%	1,884,342	44.5%
Total	535,309	100%	4,230,195	100%

*Totals may not add due to rounding.

The Agency applies the percentage distributions from Table 3 to the estimated average total numbers of impacted freight carriers, 315,306, and CMVs, 2,491,659, to estimate the distribution of impacts by carrier size (see Table 4).

Table 4. Estimated Annualized Distribution of Freight Carriers by Size*

Carrier Size	Carrier Percent	Impacted Carriers	CMVs Percent	Impacted CMVs
1 to 6	85.0%	268,051	20.7%	515,909
7 to 19	10.0%	31,654	13.8%	344,357
20 to 100	4.2%	13,259	20.9%	521,483
101+	0.7%	2,341	44.5%	1,109,910
Total	100%	315,306	100%	2,491,659

*Totals may not add due to rounding.

The estimated marking costs, consisting of material costs, are depicted below in Table 5. Current research shows prices ranging from $6 to $1,000, depending on the type, quality, quantity, and durability of the option, as well as whether marking is achieved through a do-it-yourself tool or one that is custom-made.

Table 5. Average Material Cost per CMV

Carrier Size	Material Cost per Vehicle		Total Material Cost per Impacted CMV
	Affixing Carrier DOT #	Affixing Carrier Name
1 to 6	$11.10	$16.70	$27.80
7 to 19	$8.30	$12.50	$20.80
20 to 100	$5.50	$8.30	$13.80
101+	$2.80	$4.10	$6.90

The estimated marking cost per carrier (summarized in Table 6) will vary according to the fleet size per carrier.

Table 6. Average Material Cost per Carrier*

Carrier Size	Average Fleet Size	Material Cost per Vehicle	Average Cost per Carrier
1 to 6	2	$27.80	$56
7 to 19	11	$20.80	$229
20 to 100	39	$13.80	$538
101+	474	$6.90	$3,271

*Totals may not add due to rounding.

The total cost for all freight-carrying motor carriers is estimated by applying the material cost per vehicle to the number of CMVs corresponding to its size category. For example, the 1–6 carrier size category incurs a cost of $9,746,854 (350,606 CMVs × $27.80 per vehicle). The total cost for all categories of freight-carrying motor carriers is $24,709,678 per year. Table 8 presents this information.

Table 7. Total Material Cost to Freight Carriers*

Carrier Size	Total Number of CMVs	Material Cost per Vehicle	Total Cost
1 to 6	515,909	$27.80	$14,342,270
7 to 19	344,357	$20.80	$7,162,626
20 to 100	521,483	$13.80	$7,196,465
101+	1,109,910	$6.90	$7,658,379
Total	2,491,659	-	$36,359,740

*Totals may not add due to rounding.

2. Passenger-carrying commercial motor carriers.

The majority of interstate passenger carriers are small entities with an average fleet of 20 CMVs. As stated above, the majority (90 percent) of CMVs of passenger carriers are owned by their operators. Those CMVs are assumed to be permanently marked. The estimated cost per vehicle of such marking is $27.80 ($11.10 to affix carrier DOT # + $16.70 to affix carrier name).

There are an estimated 120,626 passenger-carrying CMVs that require marking with decals or stencil annually; therefore, the total cost for all passenger carriers impacted by this component of the marking rule is $3,353,403 per year (120,626 CMVs × $27.80 per vehicle) as shown in Table 8.

Table 8. Estimated Passenger-carrying CMV Marking Cost*

Material Cost per Vehicle		Total Cost per Vehicle	Total Affected Vehicles	Total Cost
Affixing Carrier DOT #	Affixing Carrier Name
$11.10	$16.70	$27.80	120,626	$3,353,403

*Totals may not add due to rounding.

There is an additional $0.04 marking cost for short-term leases as detailed in the final rule “Lease and Interchange of Vehicles; Motor Carriers of Passengers.” There are an estimated 12,063 passenger-carrying CMVs that require short-term lease marking; therefore, the total cost for all passenger carriers impacted by this component of the marking rule is $617,626 per year (12,063 CMVs × $0.04 × 64 leases per year × 20 CMVs per fleet).

Summary of passenger-carrying commercial motor carriers’ marking costs:

Passenger-carrying commercial motor carrier marking costs, on an annual basis for the 120,626 impacted CMVs, are projected to total $3,971,029 ($3,353,403 + $617,626). This equates to a per-CMV average of $32.92 ($3,971,029 ÷ 120,626), or an average of $658 per impacted carrier.

3. Intermodal equipment providers.

As stated above, the overwhelming majority (90 percent) of IEPs voluntarily mark their vehicles and equipment electronically into the Intermodal Association of North America (IANA) database. Actual physical marking is assumed of the remaining 10 percent of those entities. The total number of equipment owned, leased or rented by that segment of IEPs and that would require marking was estimated at 21,017. The cost per entity depends on the quantity and combination of equipment which varies considerably. For simplicity, the Agency applies the average number of units per fleet for all IEPs, i.e., 1,911 per year (21,017 impacted units ÷ 11 IEPs). Regarding the cost of marking per unit, the Agency applies the total cost (DOT# and name material costs) to freight carriers with 1,000+ units. That cost estimate is $3.50 per unit.

Table 9 presents the average marking cost per IEP, which is $6,689 ($3.50 × 1,911 units per IEP). The total material cost for all IEPs impacted by the marking rule is $73,560 ($3.50 per unit × 21,017 units).

Table 9. Estimated Marking Cost per IEP*

Material Cost per Vehicle		Total Cost per Unit	Average Annual Impacted Units per IEP	Annual Average Cost per IEP
Affixing Carrier DOT #	Affixing Carrier Name
$1.40	$2.10	$3.50	1,911	$6,689

*Totals may not add due to rounding.

Summary

Table 10 presents the average material cost incurred per carrier or IEP and the total material cost for all carriers and IEPs.

Table 10. Total Annual Costs to Respondents

Respondent Type	Average Cost per Carrier or IEP	Total Cost
Freight Carrier	$115	$36,359,740
Passenger Carrier	$658	$3,971,029
IEP	$6,689	$73,560
Total	-	$40,404,329

13. ESTIMATE OF COST TO THE FEDERAL GOVERNMENT

None. The cost of educating the motor carriers and lessees of the marking requirements and the enforcement of those requirements at the roadside during crash and compliance investigations would be covered by existing personnel without further impact to the government.

13. EXPLANATION OF PROGRAM CHANGES OR ADJUSTMENTS

This program adjustment increase in 283,996 estimated annual burden hours (1,134,996 proposed revised estimated annual burden hours – 851,000 approved estimated annual burden hours) is due to adjustments in respondent and response estimates and to a correction in methodology for Component 1 and Component 2. The currently approved burden estimates did not account for the one-third of power units that are retained by the owner and undergo relabeling due to the label reaching the end of its useful life. This ICR corrects that error.

13. PUBLICATION OF RESULTS OF DATA COLLECTION
    
    

The results of this ICR will not be published.

13. APPROVAL FOR NOT DISPLAYING THE EXPIRATION DATE OF OMB APPROVAL

Not applicable.

13. EXCEPTIONS TO CERTIFICATION STATEMENT
    
    

None.

Department of Transportation

Office of the Chief Information Officer

REFERENCE LIST

Commercial Motor Vehicle Marking Requirements

1. Lease and Interchange of Vehicles; Motor Carriers of Passengers (80 FR 30164) dated May 27, 2015, (Attachment A) Page 1

2. General powers of the Secretary of Transportation, 49 U.S.C. 31133(a)(8) and 31133(a)(10) (Attachment B) Page 1

3. Federal Motor Carrier Safety Regulations: General Commercial Motor Vehicle Marking, (65 FR 35287), June 2, 2000 (Attachment C) Page 2

4. FMCSA Carrier Safety Fitness Determination Notice of Proposed Rulemaking. See 81 FR 3596, Thursday, January 21, 2016, https://www.gpo.gov/fdsys/pkg/FR-2016-01-21/pdf/2015-33153.pdf Page 2

5. Lease and Interchange of Vehicles; Motor Carriers of Passengers, (78 FR 57822), September 20, 2013 (Attachment D) Page 2

6. Agency Information Collection Activities; Renewal of an Approved Information Collection: Commercial Motor Vehicle Marking Requirements, (83 FR 17885) (Attachment E) Page 3

7. Bureau of Labor Statistics, Employment by industry, occupation, and percent distribution, 2016 and projected 2026, 484100 General freight trucking, www.bls.gov/emp/ep_table_109.htm Page 4

8. DOT HS 808 080, Final Report: A Study of Commercial Motor Vehicle Electronics-Based Rear and Side Object Detection Systems, January 1994, www.nhtsa.gov Page 5

9. Inspection, Repair, and Maintenance; Driver-Vehicle Inspection Report for Intermodal Equipment, www.regulations.gov/#!docketDetail;D=FMCSA-2011-0046 Page 5

10. Bureau of Labor Statistics. Occupational Employment Statistics, May 2016 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 484000 - Truck Transportation, www.bls.gov/oes/current/naics4_484100.htm#49-0000 Page 6

11. Bureau of Labor Statistics. “Table 10. Employer costs per hour worked for employee compensation and costs as a percentage of total compensation: private industry workers, by industry group, March 2017.” https://www.bls.gov/news.release/ecec.t10.htm Page 6

12. Bureau of Labor Statistics. Occupational Employment Statistics, May 2016 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 485200 - Interurban and Rural Bus Transportation, www.bls.gov/oes/current/naics4_485200.htm Page 8

13. Bureau of Labor Statistics. “Table 10. Employer costs per hour worked for employee compensation and costs as a percentage of total compensation: private industry workers, by industry group, March 2017.” https://www.bls.gov/news.release/ecec.t10.htm Page 8

14. Bureau of Labor Statistics. Occupational Employment Statistics, May 2016 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 484000 - Truck Transportation, www.bls.gov/oes/current/naics4_484100.htm#49-0000 Page 10

15. Bureau of Labor Statistics. “Table 10. Employer costs per hour worked for employee compensation and costs as a percentage of total compensation: private industry workers, by industry group, March 2017.” https://www.bls.gov/news.release/ecec.t10.htm Page 10

1 FMCSA Carrier Safety Fitness Determination Notice of Proposed Rulemaking. See 81 FR 3596, Thursday, January 21, 2016, available at https://www.gpo.gov/fdsys/pkg/FR-2016-01-21/pdf/2015-33153.pdf .

1⁽⁾ 65 FR 35287 (June 2, 2000).

2⁽⁾ Bureau of Labor Statistics, “Employment by industry, occupation, and percent distribution, 2016 and projected 2026, 484100 General freight trucking. Available at www.bls.gov/emp/ep_table_109.htm. Accessed December 1, 2017.

3⁽⁾ DOT HS 808 080, Final Report: A Study of Commercial Motor Vehicle Electronics-Based Rear and Side Object Detection Systems, January 1994. Available at www.nhtsa.gov. Accessed March 14, 2013.

4⁽⁾ Available at www.regulations.gov/#!docketDetail;D=FMCSA-2011-0046. Accessed on January 16, 2018.

5⁽⁾ Bureau of Labor Statistics. Occupational Employment Statistics, May 2016 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 484000 - Truck Transportation. Available at www.bls.gov/oes/current/naics4_484100.htm#49-0000. Accessed December 1, 2017.

6⁽⁾ Bureau of Labor Statistics. “Table 10. Employer costs per hour worked for employee compensation and costs as a percentage of total compensation: private industry workers, by industry group, March 2017.” Available at https://www.bls.gov/news.release/ecec.t10.htm. Accessed December 1, 2017.

7⁽⁾ Bureau of Labor Statistics. Occupational Employment Statistics, May 2016 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 485200 - Interurban and Rural Bus Transportation. Available at www.bls.gov/oes/current/naics4_485200.htm. Accessed December 4, 2017.

8⁽⁾ More recent data is not available as FMCSA no longer collects this information.

9⁽⁾ See footnote 5.

10⁽⁾ Ibid.

11⁽⁾ Bureau of Labor Statistics. Occupational Employment Statistics, May 2016 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 484000 - Truck Transportation. Available at www.bls.gov/oes/current/naics4_484100.htm#49-0000. Accessed December 1, 2017.

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