The Federal Motor Carrier Safety Administration’s most recent Strategic Plan was published in 2021 and covered 2021 through 2023. Its Vision is to prevent all crashes, including those involving injuries and fatalities involving large trucks and buses. Its four strategic goals in support of this vision are Safety, Collaboration, Innovation and Mission-enabling support. In the document it offers objectives and strategies for meeting the goals in alignment with the broader DOT Strategic plan. What is missing, however, is how they intend to measure progress and impacts. This, in our view, is a strategic MISS.
At STC we know that measuring safety progress is not easy. In some cases, large, overarching metrics like crash rates and Out of Service rates are simple to measure. What is harder are more subtle, underlying data that, when taken together can paint a picture of what activities are contributing to these overarching measures. In FMCSA’s 2024-2027 Strategic Plan presentation to the Motor Carrier Safety Advisory Committee in June of 2023, it offered some insight into Agency efforts, as well as its goals for the coming years. They mentioned carrier investigations, roadside inspections, and New Entrant Safety Audits and noted grant monies distributed to states and other entities, along with outreach campaigns and research efforts. What was MISSing from this briefing was the impacts of these activities, and how they contributed (or not) to the Agency’s Vision. What also is MISSing is the Agency’s final 2024-2027 Strategic Plan, which has yet to be published.
We know that from 2021 to 2023 the Agency reports that fatalities in large truck and bus crashes declined from 6,065 to 5,176. While this is progress in the right direction, it is a long way from the 3,619 fatalities that occurred in 2009. FMCSA has developed Carrier Intervention and Roadside Intervention Effectiveness Models to evaluate the efficacy of its enforcement interventions. The problem here is that the reports are issued only sporadically, if at all. These are just two examples of FMCSA programs where we believe improvements can be made, and timely evaluation are critically important.
As another example, rulemakings require cost-benefit analyses and projections on the impacts to crash and fatality reduction. While this is an important step in the process, the problem is the Agency rarely publishes post-rule analysis on whether their cost-benefit projections were accurate, or even in the right ballpark. In April 2023, FMCSA issued a report to Congress on the effectiveness of the Electronic Logging Device mandate. The report noted several “confounding” factors that made analysis of the rule difficult to tease out the safety impacts. Disappointing.
What does this all mean? Clearly FMCSA is working hard on many initiatives to move the needle, but are they working smart enough? Spending more energy on identifying the critical and key performance metrics, conducting the analysis—and making them public – will create many more opportunities for helping the Agency realize its vision by focusing resources on tactics that are working, and discarding the ones that are not. It also will aid the regulated community in knowing the problem areas to which they need to pay closer attention. STC knows FMCSA has it in them, and we remain optimistic they will get there.