In Part 1 of The Past and Future of Truck Inspections, we saw how trucking and commercial vehicle law enforcement grappled with the need to address highway safety while preserving the efficiency of motor carrier operations. The focus forty years ago, in the Crescent Project, was the wasted time and effort, for both parties, of funneling all trucks through weigh stations.
In Part 2, we began looking at the differences between the weigh stations bypass program, which began in the Crescent Project as HELP and evolved to today’s PrePass, and the proposed UID/Level VIII inspection system. What are the differences between the Crescent Project weigh station bypass agreement and the proposed UID/ Level VIII inspection system? The differences center on privacy, cost and safety. In Part 2 we examined privacy. Here in part 3, we will look at cost and safety, and then offer a PrePass path forward.
Cost
What did HELP, the Crescent Project weigh station bypass program, cost the jurisdictions adopting it? Nothing.
To be clear, there is always the disruption of existing weigh station operations and the work performed on adjacent roads installing WIM scales, readers, and directional signage, plus the training of weigh station personnel. But all of that, plus the computer programs supporting the program, were first paid for by HELP and now are underwritten by PrePass. PrePass alone has invested $900 million in the program, free of charge to the states and their taxpayers.
For motor carriers, the monthly PrePass subscription is more than compensated by the $ 8.68 savings every time one of a participant’s trucks bypass a weigh station, according to FMSCA data. Those savings also incentivize trucking companies to maintain a qualifying safety record.
The cost of UIDs and Level VIII inspections? Unknown.
A UID will be more expensive than a weigh station bypass transponder or app, simply because a UID, one supporting Level VIII inspections, must transmit so much more data from many more vehicle component sources. Compatibility with truck and truck componentry year, make and model could be a challenge. But a cost figure has not been determined. And the question remains whether UIDs would be required on all trucks or only on newly manufactured trucks, and whether, as has been proposed, UIDs would also be installed on trailers and semitrailers.
Similarly, a UID/Level VIII inspection program would require the development and installation of new communication systems between roadside and trucks on the road. Those transmissions would need to be highly encrypted, adding to development cost. New directional signage would be needed.
Would the proposed UID/Level VIII inspection system simply build off the existing PrePass weigh station bypass infrastructure? The FMCSA ANPRM on UIDs makes no mention of existing bypass programs and their future.
Bottom line, though, the PrePass weigh station bypass system and infrastructure are all privately funded and privately owned. That private funding made sense to the trucking industry in the Crescent Project because qualifying motor carriers saw a time and money return on their company’s investment in safety. That private funding made sense to the government personnel in the Crescent Project because improvements in weigh station functioning came at no taxpayer expense. Both industry and government saw weigh station bypass as part of their shared commitment to highway safety and efficiency.
A UID/Level VIII inspection system, whatever its cost, would be entirely funded by taxpayers, or potentially visited upon the trucking industry through additional taxation.
Safety
PrePass continues to work with commercial vehicle law enforcement on projects that improve highway safety. That commitment to highway safety was a fundamental premise of the Crescent Project, where PrePass was born.
Increasing the percentage of trucks inspected, the goal of Level VIII inspections, is laudable. But increased inspections should not be conflated with automatically improved safety. A 2009 CVISN (Commercial Vehicle Information Systems and Network) report, “Evaluation of the National CVISN Deployment Program,” showed that electronic screening of trucks and drivers addressed only three of the top 19 causes of truck crashes.
Those three – brake problems, load securement, and tire issues – are clearly important. Those three are already addressed by current weigh station inspections, without the presence of UID/Level VIII, and are detectable by truck drivers during pre-and post-trip truck inspections.
It is the remaining 16 top causes of truck crashes that a UID/Level VIII inspection system –as well as the current weigh station inspection – do not capture. Those 16 are primarily related to unsafe driver behavior. They include speeding, driver distraction, DUI, and car-truck crashes (where 70% of those accidents are initiated by the passenger car driver). Even if some unsafe driver behavior can be electronically recorded as a past event (e.g., speeding earlier in the day), due process requires direct observation for enforcement.
Ironically, increasing the percentage of trucks inspected through a UID/Level VIII system could entail funneling more trucks through weigh stations… potentially creating the same delays and inefficiencies that the Crescent Project sought to address forty years ago.
A PrePass Path Forward
Safety and efficiency remain the goals that trucking and commercial vehicle law enforcement have embraced ever since the Crescent Project. Five steps by FMCSA could enhance highway safety and efficiency:
- Manage truck driver detention and delay at shipper facilities. Unnecessary delays cut into the time truck drivers have available to complete scheduled operations, seek appropriate parking, obtain needed rest, and even inspect their own trucks. Delays can lead to unsafe driver behavior – speeding, particularly.
- Increase and improve truck parking. Truck drivers spend a substantial portion of their available hours of service looking for safe and convenient parking, often to get needed rest. A rested truck driver is a safer truck driver..
- Provide better oversight of truck driver training. The COVID-19 pandemic brought FMCSA waivers, allowing third parties to conduct aspects of truck driver training, evaluation, and testing. But it is not just who is teaching prospective drivers but what is being emphasized. Young drivers should learn that thorough pre- and post-trip inspections are not just a regulatory requirement but are an essential safety step, one that can achieve the same crash-prevention result on brake problems, load securement, and tire issues as the costly and intrusive UID/Level VIII inspection proposal.
- Increase commercial law enforcement presence and focus it on on-road driver behavior. Sixteen of the top 19 causes of truck crashes relate to truck and passenger car driver behavior on the highway. Let’s put our time, money and emphasis where it does the most good.
- Leave the bypass process where it is. Continue the laudable FMCSA efforts to improve the agency’s Safety Measurement System (SMS), Safety Fitness Determination process (SFD), and Crash Preventability Determination Program, so that motor carriers and electronic weigh station bypass providers like PrePass have the most accurate assessment of carrier safety – and then leave the bypass process where it is.
Consider: 1) motor carriers participating in PrePass have voluntarily agreed to the transmission of their carrier identification and ISS rating, thereby avoiding the legal challenges which will follow mandatory transmission of PII and proprietary data under a UID/Level VIII inspection program; 2) the existing bypass programs, like PrePass, come at no cost to the government, while avoiding the costly dismantling of the existing bypass systems; and 3) existing bypass systems, like PrePass, act as an incentive to motor carriers to achieve and maintain a good safety record and not as a government mandate.
In the forty years since the Crescent Project, PrePass has embraced highway safety and efficiency. These five steps will help trucking and law enforcement meet our shared goals.