As those who reviewed the rulemaking well know (April 28, 2003 (Volume 68, Number 81), Rules and Regulations, pp. 22455-22517), the FMCSA actually increased driving hours from 10 to 11 hours for the trucking industry. If one failed to notice or apply junior high school math, the effective service area size for a single trucker’s workday was increased by nearly a fourth. Before we abstain from our next opportunity, it is worth exploring what an additional hour of driving could mean to both the safety and economic viability of the motorcoach industry – not to mention additional benefits which might accrue from the application of science and technology to clear thinking and effort.
The Head of the Class
Shortly before the Iraqi invasion, my nephew’s high school class took a one-day field trip from Kingston, RI to Manhattan. The major contractor’s coach left his school at roughly 6:30 A.M., and arrived in Manhattan at about 11:00 A.M. After a whirlwind tour of Ellis Island, Wall Street, the United Nations and South Street Seaport – to three of which the driver also transported the students – the coach left Manhattan at 6:30 P.M. and arrived back at school at roughly 11:00 P.M. My nephew’s geography teacher was fortunate to actually arrange a group interview with the Iraqi Ambassador to the United States. When I asked my nephew if anyone asked any good questions, he replied, “Our driver did!”
From an operating and regulatory perspective, this trip was roughly 160 miles each way. Of course, to provide the students with enough activity to justify nine hours of travel, the trip encompassed 16.5 hours, not even including the deadhead time that likely made the driver’s shift 18 hours long. Including travel time within Manhattan, he also spent more than 10 hours driving. He not only took no naps but, as noted, participated in the passengers’ activities.
Principles and Practices
Is such a trip typical of the industry? Probably not. But it illustrates the constraints which the current regulatory structure imposes: Without violating its tenets, this trip would not have been possible. As a charter and tour service rule of thumb, passengers are unwilling to spend much more time traveling than they do at the actual destination. Applying this caveat to the current regulatory structure, a 7.5-hour outing at the destination(s) can be coupled with no more than 7.5 hours of travel. With part of the trip traversing a heavily-trafficked, metropolitan area, and a single, short rest-stop each way, this translates roughly into a 125-mile radius. If one were to factor in reasonable deadhead time, this radius might be reduced to as little as 100 miles.
In simple geometry terms, the 100-mile radius translates into a service area of roughly 31,416 square miles – or pi R squared. Of course, those living near the center of this circle would not likely travel to it by motorcoach. But eliminating an “inner circle” of even 40 miles in radius deducts only 5026 square miles from the larger circle – leaving an effective “ring” of market potential roughly 26,390 square miles in size. Because a bus route cannot reasonably meander throughout the entire ring, the “genuine” market area for any given trip is considerably smaller. Regardless, section of the ring that comprises the effective market is directly proportional to the radius of the ring –a linear rather than geometric relationship.
Because passengers traveling for hours on out-and-backs reasonably want to spend some time at the actual destination, this formula means that the potential market five hours away from the trip origin (assume the coach covers 40 net miles per hour of passenger travel) is 56 percent greater than that for service four hours away. For service five-and-a-half hours away, the potential market is 89 percent larger – practically double. Conversely, increasing the radius by 41% effectively doubles the service area.
It is naive to think that these dynamics are a minor industry concern. Admittedly, the extra 60 to 90 minutes of one-way travel time is more important to trips encompassing a metropolitan area than a rural area. Regardless, for a travel mode with not only multiple-stop, but even flexible-stop capabilities, expanding the size of the service area is the most critical operating dynamic. While price is often a formidable variable, such is not always the case: Twenty members of my nephew’s public high school class will soon be taking a two-week, school-related Summer trip to Costa Rica!
Far and away, the biggest opportunity missed by the failure to restructure the HOS for the motorcoach industry is the failure to increase the potential market for “out-and-backs” – the meat-and-potatoes of the industry’s charter and tour sectors. Such trips also represent the largest untapped market. Face it: The fully-comped, high-stakes gamblers who merit special rooms and show-girl croupiers are not traveling by motorcoach. Sixty percent of motorcoach riders are elderly, and another 30 percent are schoolchildren. These are the folks for whom transit services offer discount passes – in the case of elderly riders, as a matter of Federal law. These passengers have plenty of time but very little money. If many of them are to visit something far away, they are napping on the coach and sleeping in their own beds. Thus, the distance a coach can travel away from its home base essentially defines most of the motorcoach market. But it defines even more of the future motorcoach market, since this market’s growth is largely a reflection of the rapidly-disappearing middle class.
Studies and Intuition
For those who know the details, the FMCSA’s inability to adequately research the subject matter was not its own failure, but that of the contractor it hired to obtain and analyze the data. Many motorcoach industry officials and members, including myself, were never shown the draft report before its submittal. But this failure was well-known. It was not only inappropriate to criticize the FMCSA for it, but an act of bad faith.
Apart from this particular study, the scope of the FMCSA’s efforts to examine the bases for revamping the HOS in general are evident to anyone reviewing the rulemaking. But no study is needed to establish that a well-rested driver with a long nap sandwiched between two six-hour runs is a much safer driver on either leg of the trip, and a far better insurance risk, than one driving in the final hours of a continuous 10-hour run. But the difference between these duty cycles is equally or more significant in economic terms: The disparity between a 12/18 versus 10/15 formula could mean the difference between industry prosperity and, possibly, industry collapse.
No one, including this author, is advocating such change without conditions. But a 12/18 duty cycle including (a) a long nap (which existing technology can verify), (b) a hot shower, (c) a nutritious meal, (d) no consecutive days on-duty, and (e) the driver rising at roughly the same hour on his or her off-days are hardly a burden. Nor would such conditions – including a day-rate in a convenient hotel – be unaffordable for a system with twice the market reach, as the arithmetic above clearly demonstrates.
Under such a structure, a driver could make a decent living working 15 days a month. One can barely fathom the impact such shifts would likely have on recruiting – assuming that the industry monitored and enforced the drivers’ propensity to take second jobs. But even part-time jobs that did not require the driver to arise earlier or retire later than usual – or even earlier and/or later if the driver similarly napped on those days – would not present any serious problems. Who knows: We might even end up with a cadre of drivers whose median age is lower than that of the passengers!
Safety and Perception
From a marketing perspective, the perception of safety is even more important than its reality. In not expanding the safety envelope, and the enormous public relations possibilities that could have accompanied it, the motorcoach industry lost an invaluable opportunity to advertise the safety that we devote so much time bragging about internally. Such improvements are wasted on the trucking sector since, as the UMA and ABA so aptly pointed out, packages do not care.
In truth, the motorcoach-riding public could not give a rat’s buttocks about HOS. But they would be comforted to know that their drivers have a long nap, a clean shower and a decent meal between trip segments. They might even be willing to pay more for the ride. If not, as the analysis above demonstrates, at least there would be twice as many of them.
Legitimate motorcoach operators argue, with considerable merit, that deregulation dealt a near-death blow to the industry by unleashing a hoard of cutthroat owner-operators onto the landscape. But by maintaining the HOS status quo, these operators lost a rare opportunity to gain a competitive edge against them. After all, even pirates have to sleep sometime. There is an obvious limit to how many consecutive hours even the most unscrupulous or victimized motorcoach driver can remain awake. But, with expanded hours and performance-based driver assignment and scheduling, an enlightened operator would have the advantage of competing with bandits and low-ballers by virtue of the fact that, with a larger market, it could afford to give its drivers a nap, a shower and a square meal.
As we were so often reminded in recent months, it took a considerable effort by the industry to maintain the status quo. One supposes that this effort was less costly than conducting research. In all fairness, we cannot continue to expect the Federal government to finance our research. We surely cannot expect the Federal government to finance our thinking. If we are to enjoy the benefits which might accrue from exploring practical and responsible alternatives which modern science and technology make possible, it is only fair to bear the costs. Our industry has clearly failed to do so. Instead, we just frittered away almost half our potential market.
The FMCSA is incorrect that drivers falling asleep at the wheel is our industry’s worst problem. Our genuine worst problem is that we are. If the motorcoach industry implodes from the forces of its own intensely-lobbied dynamics, we will have only ourselves to blame.