Development and Evaluation of Alternative 

Concepts for Wireless Roadside Truck and 

Bus Safety Inspections 

July 2007 
FOREWORD 

This study focused on developing and analyzing various concepts of operations that would link 

advanced onboard monitoring technologies with a means of wirelessly communicating such 

information to inspection sites in order to improve the quality and/or quantity of commercial 

vehicle inspections completed annually in the United States. This project is being administered 

by the Federal Motor Carrier Safety Administration (FMCSA) and is sponsored by the U.S. 

Department of Transportation’s (USDOT’s) Joint Program Office (JPO) on Intelligent 

Transportation Systems (ITS). 

The work performed under the project included: 

• Analysis of historical inspection and crash data to determine requirements for a wireless 

inspection system and a safety data message set (SDMS) 

• Development of wireless inspection operational concepts defined by different wireless 

technologies, venues, and methodologies for collecting the data, IT support systems, and 

other operating and implementation scenarios 

• Evaluation of the benefits of increasing levels of sophistication relative to the type and 

detail of diagnostic information collected from the vehicle, and of the sensors and 

diagnostic systems needed to support such concepts. The evaluation focused on the 

capital and operating costs, safety benefits, institutional issues, and deployment 

challenges associated with each alternative 

• Development of a deployment plan for FMCSA, including a roadmap for testing, 

demonstrating, and deploying the most feasible SDMS alternative and concept of 

operations 

Note: This document is the Final Report for the contract under which the study was performed. 

During the course of the study, separate Task Reports for each of the major tasks completed were 

also delivered, as were several Appendices. These are available under separate cover. 

NOTICE 

This document is disseminated under the sponsorship of the Department of Transportation in the 

interest of information exchange. The United States Government assumes no liability for its 

contents or use thereof. 

The contents of this report reflect the views of the contractor, who is responsible for the accuracy 

of the data presented herein. The contents do not necessarily reflect the official policy of the 

Department of Transportation. 

This report does not constitute a standard, specification, or regulation. 

The United States Government does not endorse products or manufacturers named herein. Trade 

or manufacturers’ names appear herein only because they are considered essential to the 

objective of this document. 
Technical Report Documentation Page

1. Report No. 

FMCSA-RRT-07-005 

2. Government Accession No. 3. Recipient's Catalog No. 

5. Report Date 

July 2007 

4. Title and Subtitle 

Development and Evaluation of Alternative Concepts for 

Wireless Roadside Truck and Bus Safety Inspections 6. Performing Organization Code 

7. Author(s) 

Robert M. Kreeb, Brian T. Nicosia, Hussam S. Alibrahim, Sebastian Silvani 

(Booz Allen Hilton Inc.) 

8. Performing Organization Report No. 

9. Performing Organization Name and Address 10. Work Unit No. (TRAIS) 

Booz Allen Hamilton Inc. 

8283 Greensboro Dr 

McLean, Virginia 

11. Contract or Grant No. 

DTFH61-04-D-00003 

13. Type of Report and Period Covered 

Final Report 

12. Sponsoring Agency Name and Address 

Federal Motor Carrier Safety Administration 

Office of Research and Analysis 

1200 New Jersey Ave., SE, Room 600 West 

Washington, DC 20590 14. Sponsoring Agency Code 

FMCSA 

15. Supplementary Notes 

This program was administered through the Federal Motor Carrier Safety Administration (FMCSA). The FMCSA 

Program Manager is Jeff Loftus. 

16. Abstract 

This study focused on developing and analyzing various concepts of operation that would link advanced onboard vehicle and 

driver monitoring technologies with a means of wirelessly communicating such information to local enforcement agencies in 

order to improve the quality, efficiency, and effectiveness of the North American Standard (NAS) roadside safety inspection 

program. The hypothesis which prompted the study was that wireless inspection technology could be widely deployed at both 

traditional and “virtual” inspection sites to dramatically increase the number of “inspections” completed, and to improve prescreening of vehicles for more detailed manual inspections. Information about the condition of the vehicle and the driver would

be assembled electronically in a standard “safety data message set” and then transmitted to the infrastructure, using dedicated

short-range communication (DSRC) technology. Concepts developed were differentiated from current electronic pre-screening 

programs in that real-time information about the vehicle and driver would be conveyed. 

Based on a review of inspection and crash data, as well as discussions with the commercial motor vehicle (CMV) industry, the 

high-level requirements for a wireless commercial vehicle inspection concept should focus on gathering data related to the 

brakes, tires, lighting systems, Hours-of-Service (HOS), commercial driver’s license (CDL) information, carrier identity, and 

vehicle identification number (VIN). All of this information already exists on the vehicle (via discrete sensor systems or 

electronic control modules) and, by using conventional technologies, could be electronically linked to the serial databus for 

subsequent transmission to the infrastructure access points. This information, when combined with the historical information 

already available on carriers and drivers—accessible via Motor Carrier Management Information System (MCMIS) and/or 

State CMV databases—would provide the enforcement community with a very powerful decision support tool for screening 

vehicles and/or implementing virtual, automated, wireless inspection sites. 

17. Key Word 

Commercial Vehicle Inspections, Wireless Inspections, DSRC, 

Enhanced Screening, Safety Data Message Set 

18. Distribution Statement 

No restrictions 

19. Security Classif. (of this report) 

Unclassified 

20. Security Classif. (of this page) 

Unclassified 

21. No. of Pages 

84 

22. Price 
SI* (MODERN METRIC) CONVERSION FACTORS 

APPROXIMATE CONVERSIONS TO SI UNITS APPROXIMATE CONVERSIONS FROM 

Symbol When You Know Multiply By To Find Symbol Symbol When You Know Multiply By 

LENGTH LENGTH 

in inches 25.4 millimeters mm mm millimeters 0.039 inft feet 0.305 meters m m meters 3.28 feyd yards 0.914 meters m m meters 1.09 Ymi miles 1.61 kilometers km km kilometers 0.621 m

AREA AREA 

in2 square inches 645.2 square millimeters mm2 mm2 square millimeters 0.0016 sft2 square feet 0.093 square meters m2 m2 square meters 10.764 syd2 square yards 0.836 square meters m2 m2 square meters 1.195 sac acres 0.405 hectares ha ha hectares 2.47 ami2 square miles 2.59 square kilometers km2 km2 square kilometers 0.386 s

VOLUME VOLUME 

fl oz fluid ounces 29.57 milliliters ml ml milliliters 0.034 flgal gallons 3.785 liters l l liters 0.264 gft3 cubic feet 0.028 cubic meters m3 m3 cubic meters 35.71 cyd3 cubic yards 0.765 cubic meters m3 m3 cubic meters 1.307 c

MASS MASS 

oz ounces 28.35 grams g g grams 0.035 olb pounds 0.454 kilograms kg kg kilograms 2.202 pT short tons (2000 lbs) 0.907 megagrams Mg Mg megagrams 1.103 s

TEMPERATURE (exact) TEMPERATURE (exact) 

°F Fahrenheit 5(F-32)/9 Celsius °C °C Celsius 1.8 C + 32 F

temperature or (F-32)/1.8 temperature temperature te

ILLUMINATION ILLUMINATION 

fc foot-candles 10.76 lux lx lx lux 0.0929 fofl foot-Lamberts 3.426 candela/m2 cd/m2 cd/m2 candela/m2 0.2919 fo

FORCE and PRESSURE or STRESS FORCE and PRESSURE or ST

lbf pound-force 4.45 newtons N N newtons 0.225 ppsi pound-force per square inch 6.89 kilopascals kPa kPa kilopascals 0.145 p

p

* SI is the symbol for the International System of Units. Appropriate rounding should be made to comply with Section 4 of A
TABLE OF CONTENTS 

ACRONYMS.................................................................................................................................V

EXECUTIVE SUMMARY .......................................................................................................VII

1.0 INTRODUCTION.................................................................................................................1

1.1 STUDY ORGANIZATION AND TASKS ...................................................................2 

1.2 INFORMATION SOURCES.........................................................................................3 

2.0 DEFINE REQUIREMENTS................................................................................................5

2.1 BACKGROUND ON CURRENT ROADSIDE INSPECTION PROGRAM ..............5 

2.2 NEED FOR CHANGE ..................................................................................................6 

2.3 OTHER FACTORS DRIVING CHANGE IN ROADSIDE INSPECTIONS...............9 

2.4

........................................................................................16 

WHAT VEHICLE AND DRIVER DATA SHOULD BE TARGETED FOR 

WIRELESS INSPECTION?

2.5 POTENTIAL IMPACTS OF MORE FREQUENT INSPECTIONS ..........................20 

2.6 PUBLIC COMMENT ON WIRELESS INSPECTIONS............................................22 

2.7 STATE ENFORCEMENT AGENCY SURVEYS......................................................23 

2.8 SUMMARY OF REQUIREMENTS ANALYSIS......................................................24 

3.0 DEVELOP ALTERNATIVE CONCEPTS OF OPERATION ......................................25

3.1 ENHANCED SCREENING AT EXISTING FIXED FACILITIES ...........................26 

3.2 VIRTUAL, UNMANNED INSPECTION STATIONS..............................................26 

3.3 VIRTUAL, UNMANNED INSPECTION STATIONS..............................................27 

3.4 MOBILE INSPECTION UNITS .................................................................................28 

3.5 UBIQUITOUS INSPECTION CONCEPT..................................................................28 

3.6 KIOSK SELF-INSPECTION CONCEPT...................................................................31 

3.7 NON-COOPERATIVE INSPECTION CONCEPT ....................................................32 

4.0 CONCEPT EVALUATION...............................................................................................34

4.1 DEFINE A NATIONAL WIRELESS INSPECTION INFRASTRUCTURE.............35 

4.2 VEHICLE MODIFICATION COSTS FOR EACH ALTERNATIVE .......................40 

4.3

....................................................................47 

INSTITUTIONAL AND DEPLOYMENT ISSUES FOR ALTERNATIVE 

WIRELESS INSPECTION CONCEPTS

4.4 SAFETY BENEFITS OF WIRELESS INSPECTION CONCEPTS ..........................50 

4.5 OVERALL EVALUATION AND SELECTION OF SDMS ALTERNATIVES ......56 

i 
5.0 DEPLOYMENT PLANNING............................................................................................64

5.1 RATIONALE FOR CONTINUED RESEARCH........................................................64 

5.2 CHALLENGES FOR DEPLOYMENT ......................................................................66 

5.3 ALTERNATIVE DEPLOYMENT STRATEGIES.....................................................66 

ii 
LIST OF TABLES 

Table 1. Roadside Inspection Violation Data (All Trucks)—Summary......................................... 5 

Table 2. Roadside Inspection Violation Data (All Trucks)—Detail............................................... 6 

Table 3. Truck Population by Type ................................................................................................ 6 

Table 4. Truck Population by Range of Operation......................................................................... 7 

Table 5. Average Miles between Inspections (CY 2003)............................................................... 9 

Table 6: Leading Vehicle and Driver Out-of-Service Violation Categories ................................ 17 

Table 7. CMV Weight Inspections ............................................................................................... 21 

Table 8. Responses to the RFI ...................................................................................................... 22 

Table 9. Alternative Wireless Inspection Concepts Based on (SDMS) Content......................... 34 

Table 10. Fixed and Virtual Inspection Station Estimated Cost per Station ................................ 37 

Table 11. Mobile Inspection Unit Estimated Cost per Unit.......................................................... 38 

Table 12. Total Hypothetical Wireless Facilities and Equipment Costs ...................................... 38 

Table 13. Information Technology Enhancement Costs............................................................... 39 

Table 14. Total Wireless Inspection Infrastructure Costs............................................................. 39 

Table 15. Incremental Vehicle Cost: “Vehicle Basic”.................................................................. 40 

Table 16. Incremental Vehicle Cost: “Vehicle Enhanced”........................................................... 41 

Table 17. Incremental Vehicle Cost: “Driver Basic”.................................................................... 42 

Table 18. Incremental Vehicle Cost: “Driver Enhanced”............................................................. 44 

Table 19. Incremental Vehicle Cost: “Vehicle and Driver Basic” ............................................... 44 

Table 20. Incremental Vehicle Cost: “Vehicle and Driver Enhanced” ........................................ 45 

Table 21. Summary of Incremental Vehicle Costs for Each SMDS Alternative Concept ........... 46 

Table 22. Non-Cooperative Alternative Cost Estimate ................................................................ 46 

Table 23. Institutional and Deployment Challenges for SDMS Alternatives............................... 49 

Table 24. Commercial Vehicle Roadside Inspection Violations—CY 2004 ............................... 53 

Table 25. Damages Attributable to Fatigue .................................................................................. 54 

Table 26. Estimated Percent Reduction in CMV Crashes for Each SMDS Alternative Concept 57 

Table 27. Breakdown of Accidents Involving Commercial Vehicles (CY 2002)........................ 58 

Table 28. Estimated Fatality Reduction Rate by SDMS (in crashes attributed to a commercial 

vehicle).................................................................................................................................... 58 

Table 29. Estimated Injury-Reduction Rate by SDMS (in crashes attributed to a commercial 

vehicle).................................................................................................................................... 59 

Table 30. Estimated Property-Damage-Only Crash Reduction Rate by SDMS (in crashes 

attributed to a commercial vehicle)......................................................................................... 59 

Table 31. Total Estimated Safety-Related Benefit by SDMS (in crashes attributed to a 

commercial vehicle)................................................................................................................ 60 

Table 32. Cost-Benefit Analysis by SDMS (in Crashes Attributed to a Commercial Vehicle)... 61 

Table 33. Overall Comparison of Wireless Inspection SDMS Alternatives—by Criteria ........... 63 

iii 
iv 

LIST OF FIGURES 

Figure 1. Potential Vehicle and Driver Parameters Included in a “Virtual” Inspection................. 1 

Figure 2. Growth in the Commercial Vehicle Sector ..................................................................... 8 

Figure 3. CMV Inspections by Level Type (1994 to 2003)............................................................ 8 

Figure 4. Rendition of the REAL ID card..................................................................................... 13 

Figure 5. Out-of-Service Violation Rates: 1994 to 2004.............................................................. 17 

Figure 6. Overview: Analyses of LTCCS Data ............................................................................ 19 

Figure 7. High-Level Vehicle Modifications to Support a Wireless Data Transfer ..................... 25 

Figure 8. Enhanced Screening Concept........................................................................................ 27 

Figure 9. Ubiquitous Inspection Concept ..................................................................................... 30 
ACRONYMS 

ABS Anti-lock Brake Systems 

ATA American Trucking Association 

ATMs Automated Teller Machines 

AVI Automatic Vehicle Identification 

CAN Controller Area Network 

CARB California Air Resources Board 

CDL Commercial Driver’s License (also referred to as “Driver Identification 

Information”) 

CDLIS Commercial Driver’s License Information System 

CMV Commercial Motor Vehicle 

CSA Comprehensive Safety Analysis 

CVII Commercial Vehicle Infrastructure Integration 

CVISN Commercial Vehicle Information System and Network 

CVO Commercial Vehicle Operations 

CVSA Commercial Vehicle Safety Alliance 

DHS Department of Homeland Security 

DMV Departments of Motor Vehicles 

DSRC Dedicated Short-range Communication 

ECBS Electronic Controlled Brake Systems 

ECM Electronic Control Module 

ECU Electronic Control Unit 

EOBR Electronic Onboard Recorder 

EPA Environmental Protection Agency 

ESS Enhanced Screening Stations 

FARS Fatality Analysis Reporting System 

FCC Federal Communications Commission 

FMCSA Federal Motor Carrier Safety Administration 

FOT Field Operational Test 

GES General Estimates System 

HOS Hours-of-Service 

IEEE Institute of Electrical and Electronics Engineers 

IRIS Infrared inspection system 

ISS Inspection Selection System 

ITS Intelligent Transportation Systems 

v 
JPO Joint Program Office 

LDWS Lane Departure Warning Systems 

LTCCS Large Truck Crash Causation Study 

MCMIS Motor Carrier Management Information System 

NAS North American Standard 

NHTSA National Highway Transportation Safety Administration 

OBD Onboard Diagnostic 

OEM Original Equipment Manufacturer 

O&M Operation and Maintenance 

OOS Out-Of-Service 

PBBT Performance-based Brake Tester 

PDO Property Damage Only 

PRISM Performance and Registration Information Systems Management 

RFI Request for Information 

RFID Radio Frequency Identification 

ROI Return-On-Investment 

SAE Society of Automotive Engineers 

SEA Safety Evaluation Area 

SDMS Safety Data Message Set 

TMC Truck Maintenance Council 

TPMS Tire-Pressure-Monitoring Systems 

TRB Transportation Research Board 

TSA Transportation Security Administration 

TWIC Transportation Workers Identification Credentials 

USDOT U.S. Department of Transportation 

VIN Vehicle Identification Number 

VII Vehicle Infrastructure Integration 

VIS Virtual Inspection Station 

VMT Vehicle Miles Traveled 

WiFi Wireless Fidelity 

WIM Weigh-In-Motion 

vi 
EXECUTIVE SUMMARY 

PURPOSE 

This study focused on developing and analyzing various concepts of operation that would link 

advanced onboard vehicle and driver monitoring technologies with a means of wirelessly 

communicating such information to local enforcement agencies in order to improve the quality, 

efficiency, and effectiveness of the North American Standard (NAS) roadside safety inspection 

program. The hypothesis which prompted the study was that wireless inspection technology 

could be widely deployed at both traditional and “virtual” inspection sites to dramatically 

increase the number of “inspections” completed, and to improve pre-screening of vehicles for 

more detailed manual inspections. Information about the condition of the vehicle and the driver 

would be assembled electronically in a standard “safety data message set” (SDMS) and then 

transmitted to the infrastructure using some type(s) of short-range communication media. 

Concepts developed were differentiated from current electronic pre-screening programs in that 

real-time information about the vehicle and driver was conveyed.

The technology deployed would allow for “safe” vehicles to bypass inspection points, while 

vehicles with defects, or for which proper credentialing could not be verified, would be required 

to enter the station for more complete (manual) inspections. As the technology matures, it might 

eventually be used to issue warnings or violations directly to operators in a manner analogous to 

red-light running cameras. Therefore, this technology could offer a significant deterrent effect 

and lead to improved vehicle safety and driver operations. 

PROCESS 

This study represents a comprehensive initial examination of wireless commercial motor vehicle 

(CMV) inspection concepts. The study process included the following steps: 

• Issuance of a public Request For Information (RFI) 

• Survey of State enforcement agencies 

• Interviews with key stakeholders, including fleet operators and vehicle Original 

Equipment Manufacturers (OEMs) 

• Site visits to State commercial motor vehicle (CMV) inspection facilities 

• Attendance at industry meetings [Truck Maintenance Council (TMC), Society of 

Automotive Engineers (SAE), and Transportation Research Board (TRB)] 

• Inspection data analysis [Motor Carrier Management Information System (MCMIS)] 

• Comprehensive crash data analysis [Large Truck Crash Causation Study (LTCCS), 

General Estimates System (GES), Fatality Analysis Reporting System (FARS), MCMIS] 

vii 
RATIONALE AND BACKGROUND 

While it has been successful at identifying a portion of the unsafe vehicles and drivers operating 

on the roads of the United States, the North American CMV inspection program is challenged by 

several factors: 

• A very large population of CMVs with diverse operations 

• Significant growth and fleet turnover in the CMV industry 

• Limited resources 

In addition, there are other important events taking place in the CMV industry which will shape 

the manner in which roadside inspections are completed in the future: 

• Advances in onboard, automated diagnostic technologies 

• Standardization efforts for Electronic Onboard Recorders (EOBRs) 

• Developments in the Commercial Driver License (CDL) area 

• Standardization efforts for wireless vehicle-to-roadside communications 

• Needs of other Federal agencies for monitoring CMVs 

Because of these technology, market, and institutional issues, there is a need to do more with 

less, and wireless, automated inspection technology offers such a means. 

STUDY FINDINGS 

Key findings from the investigation are as follows: 

• If a CMV is not overweight, the probability of its being inspected is exceedingly low. 

The average CMV is inspected less than once a year—and for fleets with “poor” safety 

practices, safety inspections are likely not a major deterrent or “threat.” 

• A large portion of commercial vehicles (e.g., straight trucks and/or “intra-city” 

combination vehicles) may be subjected to a safety inspection rarely or never. A majority 

of safety inspection sites are located along the interstate highway system. However, about 

50 percent of all CMV crashes are on secondary roads.

• The CMV weight enforcement programs administered by States appear to be highly 

successful in reducing weight-related violations, most likely because of the very high 

frequency of weight inspections. This fact suggests that a substantial increase in safety 

inspection frequency could yield similar benefits for other types of violations. 

• Each State would likely mix and match various wireless data collection methods (e.g., 

fixed facilities, virtual stations, mobile units, etc.) to suit their particular needs. 

• A modest wireless, automated inspection infrastructure consisting of 2,000 to 3,000 

access points could potentially generate 300 to 500 million CMV electronic inspections 

each year—compared with a total of 3 million “manual” inspections currently completed 

by States. 

• With the support of the U.S. Department of Transportation (USDOT), 5.9 GHz Dedicated 

Short-Range Communications (DSRC) will likely become the nation’s standard vehicleviii 
to-roadside communications media for both the heavy- and light-duty vehicle sectors, and 

will support a variety of market-driven safety and commercial applications. This 

communications media is therefore an appropriate technology to support the CMV 

wireless inspection concept. 

• Fleets will not voluntarily support wireless inspections unless economic benefits can be 

demonstrated—and current electronic pre-screening programs already allow trucks to 

bypass inspection stations. Federal Government-sponsored initiatives (standards, publicprivate partnerships, regulations, etc.) will be required to spur widespread deployment. 

• Based on work completed to date, the high-level requirements for a wireless commercial 

vehicle inspection concept should focus on gathering data related to the brakes, tires, 

lighting systems, Hours-of-Service (HOS), CDL information, carrier identity, and 

Vehicle Identification Number (VIN). All of this information already exists on the 

vehicle (via discrete sensor systems or electronic control modules) and, by using 

conventional technologies, it could be electronically linked to the serial databus for 

subsequent transmission by a wireless communications media. When combined with the 

historical information already available on carriers and drivers (accessible via Inspection 

Selection System [ISS], Commercial Driver’s License Information System [CDLIS], or 

other State databases), this information would provide the enforcement community with a 

very powerful decision support tool for screening vehicles and/or implementing virtual, 

automated wireless inspection sites. 

• The Environmental Protection Agency (EPA) is currently engaged in the development of 

a heavy-duty emissions inspection program. The technical development work needed to 

support the EPA effort has many parallels with work that would be required to develop 

automated safety inspections. Therefore, the opportunity exists for EPA and FMCSA to 

work cooperatively on a combined wireless safety and emissions inspection program.

• Increased inspection frequency and subsequent enforcement tactics such as violations, 

fines, etc., would result in a positive shift in carrier safety practices, particularly for those 

carriers with “poor” safety records. 

• While there will be substantial institutional challenges associated with gathering even 

basic driver and vehicle information wirelessly, the fact that such information is already 

regularly required by enforcement agencies and routinely given by fleet operators 

suggests that such challenges can be met. 

CONCLUSIONS 

Considering FMCSA’s role as an enforcement agency, should FMCSA move forward with 

research in wireless inspection concepts? Is the time right to pursue research in this area, or 

would technical, institutional and/or cost considerations negatively impact this initiative?

Based on the calculated cost-benefit ratios, interviews with a variety of industry stakeholders, 

feedback from the public RFI process, and the important changes occurring within the 

commercial trucking industry, the Research Team concluded that the answer is a clear “yes.” 

ix 
The rationale for pursuing research related to the wireless inspection concept is summarized as 

follows: 

• The concept offers an overwhelmingly positive cost-benefit ratio. 

• No new technology is required. 

• The concept would support the needs of other Federal agencies as they relate to emission 

inspections and security-related applications. 

• Implementation costs are likely to come down, while available onboard safety 

information will increase as onboard diagnostics, driven by market forces, continue to 

improve. 

• The wireless inspection concept supports Comprehensive Safety Analysis (CSA) 2010 

Goals. 

• The current Commercial Vehicle Information System and Network (CVISN) and 

COMPASS efforts provide an ideal information and communications platform for 

supporting the wireless inspection concept.

DEPLOYMENT STRATEGIES 

Two broad approaches for deploying the wireless inspection concept were identified: 

1. Leverage the current Vehicle Infrastructure Integration (VII) effort being sponsored by 

the Joint Program Office (JPO). 

2. Use a regulatory-based approach. 

Leverage Current VII Development Efforts 

Wireless inspections represent only one of many safety applications that could be enabled 

through standardized vehicle-to-infrastructure communications using the 5.9 GHz DSRC 

platform. Just as important, the DSRC medium allows for the development of numerous 

commercial and convenience applications that offer added value to commercial vehicle fleets, 

shippers, and vehicle OEMs. Therefore, the deployment of a wireless inspection program could 

coincide with a larger initiative to encourage the adoption of DSRC technology within the 

commercial-vehicle heavy-duty sector. From FMCSA’s perspective, wireless safety inspections 

may represent the primary application that is enabled by DSRC, but there are clearly many other 

safety and non-safety applications that will help build the business case for adoption of this 

standardized communications media by the industry.

Once the industry adopts the DSRC technology, costs to introduce the wireless inspection 

concept would be greatly reduced. At that point, either a direct regulatory approach could be 

taken that would require downloading of safety data, or a “soft” regulatory approach could be 

considered whereby FMCSA would leverage its influence with states so that they would modify 

electronic pre-clearance programs to require additional, real-time safety data to be downloaded 

before vehicles would be permitted to bypass inspection stations. Leveraging the VII program 

and DSRC technology to implement a “soft,” voluntary approach to CMV safety inspections is 

recommended. 

x 
xi 

Regulatory Approach 

A regulatory approach appears feasible, based on its potential safety benefits and as 

demonstrated by the encouraging Return-On-Investment (ROI) calculations outlined in this 

Report. The DSRC technology would provide a standardized link to cost-effectively monitor 

HOS, detect major vehicle condition problems, implement required emission diagnostics to 

ensure environmental compliance, and determine whether the operator of the vehicle had a 

current, valid CDL. Security applications that focus on tracking hazardous material shipments, 

including the ability to report real-time proximity of hazardous shipments to high-risk 

infrastructure locations (e.g., schools, urban centers, and stadiums) also represent high-payback 

applications. 

Additionally, a phased-in regulatory approach, particularly one that allows exemptions for 

certain types of fleets, may be supported by some sectors of the industry because it reduces 

uncertainty and risk for both OEMs and fleets. For vehicle OEMs and equipment suppliers, it 

creates a level playing field with regard to product offerings. All trucks would have to be 

equipped with DSRC when the regulations go into effect, thus eliminating an OEM’s concerns 

about whether or not the market would accept the new technology. Additionally, fleets would not 

need to evaluate the way in which purchasing the new technology would impact their 

competitiveness, since the new requirement for wireless inspections would simply be a cost of 

doing business that would be equal for all fleets purchasing new vehicles. 
1.0 INTRODUCTION 

This study focused on developing and analyzing various concepts of operation that would link 

advanced onboard vehicle and driver-monitoring technologies with a means of wirelessly 

communicating such information to local enforcement agencies in order to improve the quality, 

efficiency, and effectiveness of the North American Standard (NAS) roadside safety inspection 

program. The hypothesis which prompted the study was that wireless inspection technology 

could be widely deployed at both traditional and “virtual” inspection sites to dramatically 

increase the number of “inspections” completed and to improve pre-screening of vehicles for 

more detailed manual inspections. Information about the condition of the vehicle and the driver 

would be assembled electronically in a standard SDMS in a manner similar to the way in which 

diagnostic information on vehicle emission systems (for light-duty vehicles) is used to facilitate 

standardized emission inspections. Driver, vehicle, and carrier identifier information would also 

be part of the message set. This information would then be transmitted by an onboard wireless 

communications control module that would “assemble” the message from various sources on the 

vehicle (principally the vehicle’s electronic network) and then transmit the message to the 

infrastructure using some type(s) of short-range communication media. 

The technology deployed would allow for “good” vehicles to bypass inspection points and could 

eventually be used to issue warnings or violations directly to operators in a manner analogous to 

red-light running cameras. Such technology could potentially offer a significant deterrent affect 

and lead to improved vehicle safety and driver operations. The types of vehicle and operational 

data that could be monitored and then transmitted wirelessly to an inspection “access point” are 

shown in Figure 1. 

Tire Condition 

Monitoring

• Vehicle Identification (VIN)

• US DOT Number (Carrier ID)

Brake System 

Performance

Lighting System 

Performance

Other Fault Code Information

• Fuel System

• Transmission

• Air System

• Electrical/ Electronic Systems

• Hours of Service (HOS)

• CDL Number

• Other Driver Monitoring Data

J1939

Figure 1. Potential Vehicle and Driver Parameters Included in a “Virtual” Inspection 

The concept was significantly differentiated from current electronic pre-screening programs in 

that real-time information about the condition of the vehicle (e.g., brake, tire diagnostics; etc.) 

and the driver [e.g., Hours-of-Service (HOS) status] would be transmitted to enforcement 

agencies. Current pre-screening programs such as NorPass and PrePass only transmit a unique 

ID number [via the onboard radio frequency identification (RFID) tag] which is then cross1 
referenced to a U.S. Department of Transportation (USDOT) number in an off-board operation. 

Further, the proposed concept would call for driver- and vehicle-specific ID information to be 

transmitted, thus facilitating the implementation of more sophisticated and accurate screening 

strategies. With current electronic screening programs, vehicles that have significant defects 

and/or that are being operated by drivers who are in violation of HOS regulations (or who have 

invalid CDLs) are regularly permitted to bypass inspection sites as long as they are within weight 

limits and their carrier ID is recognized as a “good carrier. ” Alternatively, many vehicles that 

do not have defects and/or are not in violation of HOS regulations are routinely stopped and 

checked. Under the proposed wireless inspection concept, both of these situations (i.e., false 

positives and false negatives) would be eliminated, or at least significantly reduced—thus 

improving both safety and mobility. 

1.1 STUDY ORGANIZATION AND TASKS 

This study was organized around five key Tasks: 

Task 1. Refine the Work Plan: This was a largely administrative Task to refine the detailed 

analytical approach for conducting the assignment, including resources, industry interviews, and 

overall work scope issues. 

Task 2. Define Requirements: This Task focused on determining the technical and institutional 

requirements (as well as challenges) for a wireless inspection concept. This work included 

developing an understanding of the challenges facing the current roadside inspection program, 

evaluating advanced vehicle diagnostic technologies for detecting safety system defects, 

assessing wireless communication technology alternatives, and analyzing inspection and crash 

data to determine what vehicle- and/or driver-related parameters are most closely linked with 

crash rates (and should therefore be targeted for wireless inspection). 

Task 3. Develop Alternative Concepts of Operation: In this Task, alternative concepts for 

implementing a wireless inspection capability were examined. The concepts were differentiated 

primarily by the venue and methods through which data would be gathered. Concepts examined 

included: 

1. Enhanced Screening at Existing Fixed Facilities 

2. Virtual, Unmanned Inspection Stations 

3. Mobile Inspection Units 

4. Ubiquitous Inspection Concept 

5. Kiosk Self-Inspection Concept 

6. Non-Cooperative Inspection Concept 

Each of the six concepts was profiled relative to overall concept description, information logic 

flow and processes, onboard equipment modifications, infrastructure-based equipment 

requirements, and supporting information system needs. 

Note: This last concept (non-cooperative) did not include provisions for the wireless transfer of 

data by the vehicle, but instead focused on the use of advanced, non-invasive technologies such 

as infrared detection, optical sensors, and/or size and weight detection technologies. 

2 
Task 4. Evaluate and Select an “Optimal” Concept: As initially envisioned, Task 4 was to 

have focused on evaluating each of the above concepts based on costs, safety benefits, 

operational considerations, and institutional deployment issues. A “most favored” concept would 

have been selected and would have become the basis of deployment planning in Task 5. During 

the assignment, however, the Project Team concluded that no single deployment concept was 

“optimal” for all operating environments. Rather, an optimal deployment of wireless inspection 

technology would more likely involve utilization of multiple venue-based concepts (e.g., fixed 

stations, mobile units, virtual stations, etc.) tailored to the specific needs and operating 

environments of each state. In other words, it became apparent that the best approach for states 

would be that of a portfolio whereby states could mix and match the venue-based concepts in the 

way that would be most cost-effective for their particular operating environments and 

geographies. 

To proceed with Task 4, alternative wireless inspection concepts were redefined based on the 

specific types of information to be collected rather than on the venue/processes for collecting it. 

The specific type and amount of data collected will have major impacts on: 

• Required onboard equipment and diagnostic systems 

• Costs for modifying the vehicle 

• Institutional and deployment considerations 

• The likely safety benefits to be derived from long-term changes in fleet and driver 

behavior (resulting from increased inspection of specific parameters) 

The concepts were redesigned to represent a range of complexity, costs-to-implement, and 

potential safety benefits. Again (and by coincidence), six alternative concepts were developed 

ranging from collection of simple fault code data on selected safety systems (data that is for the 

most part already available on the vehicle’s electronic databus) to collection of more complex 

diagnostic information on the condition of the vehicle and the driver. These latter concepts 

would require installation of special-purpose sensors and driver-monitoring systems, and 

therefore offer more safety-related information, but at a higher cost. 

Task 5. Develop a Deployment Plan: Task 5 focused on developing technical and business 

deployment strategies for the most promising concept identified in Task 4. 

Technology research and test plans were outlined, as was a path for widespread deployment in 

the commercial vehicle sector. Alternative plans involving both a regulatory and a market-based 

approach were also developed. 

1.2 INFORMATION SOURCES 

This study represented a comprehensive initial examination of wireless CMV inspection 

concepts. The study process included: 

• Issuance of a Public Request For Information (RFI) focused on advanced vehicle 

diagnostics and wireless inspections. During the study period, responses were received—

and a review of the responses is included in the Report. 

3 
4 

• Survey of State Enforcement Agencies focused on their perspectives on use of 

advanced diagnostic technologies and wireless pre-screening methods [co-sponsored with 

the Commercial Vehicle Safety Alliance (CVSA)]. A high-level summary of the survey 

is provided. 

• Interviews with Key Stakeholders: 

– Fleet Operators 

– Vehicle OEMs 

– Technology Suppliers 

• Site Visits to State CMV Inspection Facilities (in Maryland and Virginia). 

• Attendance at Industry Meetings (TMC Annual Meeting, SAE Commercial Vehicle 

Symposium, and TRB Annual Meeting) to gain additional insight.

• Reviewed and Analyzed MCMIS Inspection Data vehicle and driver violations on 

straight and combination trucks for 2003 and 2004. 

• Reviewed and Analyzed CMV Crash Data Summaries (LTCCS, FARS, MCMIS) to 

categorize “critical reason” and “related factors” contributing to CMV accidents. 

Each Study Task is reviewed in the following sections. 
2.0 DEFINE REQUIREMENTS 

2.1 BACKGROUND ON CURRENT ROADSIDE INSPECTION PROGRAM 

The NAS Inspection Program was developed to coordinate CMV roadside inspection efforts 

among States, and to focus on the vehicle and driver safety factors most often associated with 

CMV crashes. This program is designed to improve safety and promote uniformity in 

compliance and enforcement, while minimizing duplication of inspection efforts and 

unnecessary operating delays for the motor carrier industry. 

The CMV roadside inspection program represents one of USDOT’s most formidable tools for 

monitoring and regulating the condition of the in-use commercial vehicle fleet, as well as for 

auditing and enforcing driver- and operations-related safety practices. Driver parameters 

examined include hours of service logs, CDL status, and other operating credentials, such as 

permits, proof of insurance, and operating authority. Vehicle parameters examined include 

weight, cargo securement, and condition of brakes, tires, suspension, lighting, and other safetyrelated systems. 

In 2003, the NAS Inspection program resulted in approximately 3 million CMV roadside 

inspections, conducted primarily by State enforcement agencies. These 3 million inspections 

resulted in about 6.75 million violations being issued to motor carriers. Approximately 73 

percent of the 3 million vehicles inspected were issued one or more violations—most of them 

minor infractions. However, about 7 percent of driver violations and 23 percent of vehicle 

violations resulted in out-of-service (OOS) violations, indicating that the driver or the vehicle 

was unfit for service. Altogether, these more severe violations (driver plus vehicle) resulted in 

placing about one out of every four vehicles inspected out of service. This data is shown in 

Table 1 and Table 2. 

The process of targeting vehicles for inspection has been aided in the past few years by the 

implementation of the Inspection Selection System (ISS). This system uses information on past 

inspections and carrier safety ratings to assist the inspection officer in making a decision on 

whether or not to inspect a particular vehicle. This system is not yet operational nationwide, and 

only a few States utilize the full capability of ISS. 

Table 1. Roadside Inspection Violation Data (All Trucks)—Summary 

All Inspections Number Percent 

Number of Inspections 3,006,919 

With no Violations 811,335 26.98% 

With Violations 2,195,584 73.02% 

5 
Table 2. Roadside Inspection Violation Data (All Trucks)—Detail 

Total Driver Driver Driver Vehicle Vehicle Vehicle 

Inspections Inspections OOS % Inspections OOS % 

Level 1 1,007,933 1,007,933 52,887 5.25% 1,007,933 294,554 29.22%

Level 2 1,097,392 1,097,392 73,995 6.74% 1,097,392 193,995 17.68%

Level 3 822,635 822,635 71,883 8.74% 0 0 0

Level 4 22,268 0 0 0 0 0 0

Level 5 16,208 0 0 0 16,208 2,314 0

All 2,955,436 2,927,960 198,765 6.79% 2,121,533 490,863 23.14%

2.2 NEED FOR CHANGE 

While it is successful at identifying a portion of the unsafe vehicles and drivers in operation, the 

North American CMV inspection program faces several challenges: 

• A very large population of CMVs with diverse operations 

• Significant growth and fleet turnover in the CMV industry 

• Limited resources 

2.2.1 Profile of CMV Population and Operations 

According to the most recent Vehicle Inventory and Use Survey, there are about 5.5 million 

commercial vehicles operating above 10,000 pounds GVW in the United States. Table 3 shows a 

breakdown of the CMV population by vehicle type and range of operation. As shown in the 

figure, almost two-thirds of all CMVs are straight trucks and, as can be seen by segmenting the 

population based on range of operation, most trucks (65 percent) operate within 50 miles of their 

“home base.” 

1 Table 3. Truck Population by Type

Light- LightMedium Medium 

TRUCK TYPE Weight 

Class: 

WEIGHT 

Weight 

Class: 

% 

Heavy 

Weight 

Class: 

WEIGHT 

Heavy Heavy Heavy 

Weight 

Class: 

% 

Weight Weight 

Class: 

WEIGHT 

Class: Total: Total:

% WEIGHT % 

Total 1,914 100% 911 100% 2,590 100% 5,415 100%

Straight Truck 1,512 79% 821 90% 1,102 43% 3,435 63%

Combination Truck 402 21% 90 10% 1,488 57% 1,980 37%

 

1

 United Status Census Bureau, Vehicle Inventory and Use Survey 2002, U.S. Department of Commerce, 

Washington, DC: 2004. 

6 
2 Table 4. Truck Population by Range of Operation

RANGE OF OPERATION 

Medium 

Weight 

Class 

WEIGHT 

Light- LightMedium 

Weight 

Class 

% 

Heavy 

Weight 

Class 

WEIGHT 

Heavy Heavy Heavy 

Weight 

Class 

% 

Weight Weight 

Class 

WEIGHT 

Class Total Total 

% WEIGHT % 

Total 1,915 100% 910 100% 2,590 100% 5,415 100%

50 miles of Less 1,365 71% 702 77% 1,451 56% 3,514 65%

51 Miles or More 550 29% 208 23% 1,139 44% 1,902 35%

Since most inspection stations are located on major Federal interstate highways, these statistics 

suggest that a large percentage of commercial vehicles (straight trucks and/or larger “intra-city” 

combination vehicles) will rarely or never be subjected to safety inspections by commercial 

vehicle enforcement agencies. To some extent, the focus on combination vehicles and long-haul 

trucks is appropriate, as the majority of crashes and fatalities in the commercial vehicle sector 

involve combination vehicles. However, it should be noted that about 27 percent of all CMV 

fatalities involve straight trucks, and about 50 percent of all CMV crashes are on secondary 

roads. Many States are successfully using mobile/portable inspection sites to better target intracity trucks and/or trucks that use non-interstate roads. The use of mobile inspections is growing, 

and it is estimated that 800,000 to 1,200,000 of the 3 million roadside inspections are completed 

using portable or mobile equipment. 

2.2.2 Industry Growth 

The NAS roadside inspection program is also challenged by significant growth in the heavy-duty 

vehicle segment, as shown in Figure 2. For example: 

• Combination vehicle population and vehicle miles traveled (VMT) are growing at about 

3.3 percent per year. 

• The population of straight trucks is also growing at about 3 percent per year, while VMT 

is growing at a slightly lower rate, about 2 percent annually. 

• There are about 40,000 new entrants into the commercial vehicle operations (CVO) 

market each year, and about half of those drop out. 

• Over the last 20 years, there have been one million new combination vehicles added to 

our nation’s highway network. 

2.2.3 Limited Resources 

The number of roadside inspection facilities has remained relatively static over the past several 

years, with a total of approximately 1,200 facilities in the United States staffed by about 10,000 

employees. Very few States have invested in fixed-facility inspection stations and some States 

have even reduced their fixed-station activities while slightly increasing their mobile/portable 

 

2

United Status Census Bureau, Vehicle Inventory and Use Survey 2002, U.S. Department of Commerce, 

Washington, DC: 2004. 

7 
inspection programs. While detailed historical investment data is lacking on a State-by-State 

basis, the consensus among those interviewed (which included CVSA staff and State CMV 

enforcement agencies) is that increases in labor and facilities (fixed and mobile combined) for 

roadside inspections has, at best, remained flat, with some notable exceptions, such as Texas and 

California, which have invested heavily in their roadside inspection programs. 

Combination Trucks: 

Annual Registered Vehicles and VMT

-

500,000

1,000,000

1,500,000

2,000,000

2,500,000

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

Registered Trucks

-

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

VMT (millions)

registered trucks

VMT

Figure 2. Growth in the Commercial Vehicle Sector 

The increase in the overall CMV population has put a strain on the roadside inspection program. 

States appear to be responding by increasing the relative percentage of Level 2 (driver-pluswalk-around) or Level 3 (driver-only) inspections as a substitute for full Level 1 inspections, in 

order to keep up with the increasing vehicle population. This trend is shown in Figure 3. 

Combination Trucks 

0%

20%

40%

60%

80%

100%

1994199519961997199819992000200120022003

% Inspection

s

Levels 4&5

Level 3

Level 2

Level 1

Figure 3. CMV Inspections by Level Type (1994 to 2003) 

8 
In 1994, Level 1 inspections represented about 45 percent of all inspections, while in 2003 this 

number had dropped to about 30 percent. Also, as noted, it appeared that States were increasing 

their mobile inspection efforts, with approximately one-third of all inspections completed by 

mobile units. 

Overall, however, the current level of roadside inspection activities results in relatively 

infrequent inspections for the average truck. This data is shown in Table 5. 

Table 5. Average Miles between Inspections (CY 2003) 

VMT VMT Registered RCV Total # of TIC Avg Annual Avg Miles 

(million 

miles) 

% Commercial 

Vehicles 

% Inspections 

Completed 

% Miles per Between 

Vehicle Inspections

Combination 

Vehicles 

142,802 65% 2,344,961 29% 2,181,433 74% 60,898 65,463

Straight Trucks 78,164 35% 5,820,138 71% 785,003 26% 13,430 99,571

Total 220,966 100% 8,165,098 100% 2,966,436 100% 27,062 74,489

The data in Table 5 suggests that, based on a comparison of annual miles per vehicle and miles 

between inspections, the average combination vehicle will be inspected about once every 13 

months, while the average straight truck will be inspected about once every 7.4 years. It should 

be recognized, however, that the statistical averages reported here (particularly for straight 

trucks) can be misleading, because of the bias built into State inspection programs. Specifically, 

States use various databases and tools to target high-risk carriers for inspection, most notably 

ISS. Therefore, a large percentage of combination vehicles may operate for two or three years 

without being inspected, while trucks in high-risk fleets may be inspected several times a year. 

The principal point (confirmed through discussions with fleets and operators) is that vehicle and 

driver roadside safety inspections occur very infrequently on any given truck. As long as a 

vehicle is not overweight, the probability of its being selected for a roadside safety inspection is 

very low. For those fleets with lax safety practices (e.g., those that defer proper maintenance 

and/or place only weak emphasis on adherence to HOS and other operating regulations), the 

roadside inspection program does not appear to be a major factor influencing their behavior. 

2.3 OTHER FACTORS DRIVING CHANGE IN ROADSIDE INSPECTIONS 

In addition to the aforementioned challenges, there are also other important events taking place 

within the CMV industry that will shape the manner in which roadside inspections are completed 

in the future: 

• Advances in onboard, automated diagnostic technologies 

• Standardization efforts for Electronic Onboard Recorders (EOBRs) 

• Developments in commercial driver licensing 

• Standardization efforts for wireless vehicle-to-roadside communications 

• Needs of other Federal agencies for monitoring CMVs 

9 
2.3.1 Advances in Onboard, Automated Diagnostic Technologies 

It is well-recognized that heavy-duty vehicle electronics continue to advance at a rapid pace. 

These advances are driven by multiple factors, including competitive pressure to reduce costs, 

increase functionality and features, and conduct more efficient preventative maintenance. A side 

benefit of such advances is that they also allow for the early and automatic detection of defects 

or problems in many subsystems, thus potentially improving vehicle safety. Currently, the output 

of such systems (i.e., fault codes and system performance parameters) is stored in various 

electronic control modules as “message sets.” This information can then be retrieved by 

technicians using diagnostic tools that connect to the vehicle’s high-speed controller area 

network (CAN) databus. Newer heavy-duty vehicles utilize a network conforming to SAE 

standard J1939, while older trucks utilize a slower network called J1708. The output from these 

diagnostic sensors/systems is also used to provide real-time notification to the driver through 

dashboard warning lights and/or information displays. Recently, some truck OEMs have offered 

optional wireless connection capability with the vehicle’s CAN databus so that diagnostics can 

be completed without a physical hardwire connection. 

It is certainly feasible that safety-specific diagnostic data (i.e., an SDMS) could be wirelessly 

transmitted from the vehicle to staffed or non-staffed (virtual) inspection stations at highway 

speeds. The information could then be used to determine whether more detailed inspections 

should be completed, and/or to automatically issue warnings or violations to the operator. This 

concept was recently demonstrated by Volvo and the University of Tennessee in a “Trusted 

Truck” project partially funded by FMCSA. 

Specific safety-related systems in which electronics are increasing the ability to detect defects 

include: 

Brakes: “Standard” anti-lock brake systems (ABS) already have the ability to report failures of 

multiple components that could compromise braking performance, including faulty wheel speed 

sensors, actuators, relay valves, and other switches and solenoids in the brake system. FMCSA 

has recently taken advantage of such ABS system capabilities by requiring that a warning light 

be added inside the cab of a tractor if the ABS system on a trailer detects a fault. In the future, as 

ABS systems continue to become more complex, and/or when Electronic Controlled Brake 

Systems (ECBS) become more commonplace, the ability to automatically detect brake system 

performance abnormalities will increase. While there are already relatively simple brake stroke 

sensors available as an option that can send a signal if the stroke is too far out of adjustment, it is 

likely, as advances in electronics continue, that even more sophisticated brake system diagnostics 

will become available and will be standard on future CMVs. 

Tires: Commercial vehicle tire-pressure-monitoring systems (TPMS) are readily available from 

multiple vendors. The output of these systems often includes individual tire pressures, and many 

provide for temperature compensation to yield accurate readings at highway speeds. The digital 

output signals from such systems could readily be made part of a standard SDMS. TPMS are not 

yet widely deployed in the marketplace, mainly because of cost and reliability concerns. (A 

typical TPMS for a tractor-trailer combination costs in the $800–$1200 range, and many require 

batteries which must be changed periodically.) For the most part, these systems are add-on 

sensors that mount on the valve stems or wheel hub, or are attached to the inside of the tire. 

However, the industry appears poised for the introduction of commercial vehicle tires with 

pressure monitoring chips that are molded into the tires themselves and operate without the use 

10 
of an internal power source (or battery). Such tire technology would lower costs, increase 

reliability, and essentially eliminate the need for maintenance of the systems themselves—

maintenance requirements which have been a detriment to TPMS in the marketplace. 

Other Vehicle Systems: There is a trend in the automotive industry toward use of more by-wire 

systems in which mechanical actuators and controls are replaced by electronic systems using 

controllers, solenoids, electric motors, and various transducers (sensors). As noted, ECBS 

systems are emerging; they are already commonplace in Europe. Electronics are also being 

added to suspension, steering, fuel, and air supply systems on commercial trucks. Conditions 

which could compromise vehicle safety, such as low air pressure or leaks, fuel system leaks, 

suspension system failure, and various types of electrical and lighting system shorts and open 

circuits, can now be reported automatically in many instances. Such diagnostic information (and 

fault codes) could be standardized and built into an SDMS. Again, this is a technical approach 

very similar to what is now commonplace in the light-duty sector for reporting failures or defects 

in emission-related components. The standardized emission data message set and associated 

processes for extracting the data are known as “Onboard Diagnostics II,” or OBD II. The II 

designation represents an enhanced version from the original OBD regulations for light-duty 

vehicles that were introduced in California in the mid-1990s. 

Vehicle Weight: There are several methods for a commercial truck to estimate its gross weight. 

Engine and transmission Electronic Control Modules (ECMs) can use internal algorithms to 

estimate gross weight by monitoring the torque/speed curves during accelerations and comparing 

them with “standard” curves based on a reference weight. However, such an approach has 

limited accuracy, with estimates that may be off by as much as 10 percent (varying wind, road, 

and other conditions preclude higher accuracy levels). For vehicles that are equipped with an air 

bag suspension system (both tractors and trailers), weight can be estimated by monitoring air bag 

pressure and vehicle ride height at each axle. However, these systems add about $1,500 to 

$2,000 to the cost of a combination vehicle and can be applied only to vehicles with an air 

suspension system. Alternatively, load cells can be mounted directly to the axles and/or the fifth 

wheel to directly measure vehicle weights. These systems are more expensive, ranging from 

$2,500 to $4,000 per vehicle. All of these systems involve certain compromises relative to 

accuracy, cost, and/or adaptability to all vehicle types. While self-weighing technologies are 

available from multiple vendors, and are currently offered as an option on many new vehicles, 

this report indicates that accuracy and cost limitations will prevent them from becoming 

widespread in the marketplace. Therefore, wireless virtual inspection sites will need to rely on 

weigh-in-motion (WIM) equipment to determine vehicle weight and to augment the vehicle’s 

SDMS. If and when self-weighing technology does become cost-effective, the digital weight 

information could readily be added to an SDMS and thus allow for even more flexible roadside 

inspection concepts. 

2.3.2 Electronic Onboard Recorders 

FMCSA is currently engaged in rulemaking related to electronic onboard recorders (EOBRs). A 

probable key element of such rulemaking will be the development of a standardized protocol (or 

format) for reporting HOS logbook data. It is envisioned that the standardized logbook data will 

be extracted or downloaded using either a wired connection or a wireless medium such as 

Bluetooth or WiFi (“wireless fidelity”). This standardization effort in which FMCSA is engaged 

is an important first step toward enabling the electronic HOS data to be extracted at highway 

11 
speeds using other wireless media (wireless communication options are discussed in the next 

section of this study). Essentially, the output data file from an EOBR conforming to FMCSA 

format specifications could be readily transferred to the vehicle’s wireless communications 

module, where it would become a part of the larger SDMS. Alternatively, electronic HOS 

recording functionality could be integrated directly into the wireless communications module 

itself. Such integration could lower costs and provide the path for the marketplace to follow if 

technology to support wireless inspections were to become standard on commercial vehicles.

2.3.3 Commercial Driver’s License Developments 

For a wireless commercial vehicle inspection concept to be optimally successful, the SDMS 

should contain fundamental identification information about the driver, the vehicle, and the 

carrier. The VIN is already electronically coded and available on the J1939 databus network, and 

is usually provided by an engine or dash vehicle controller. As such, the VIN could readily be 

made part of the SDMS. The carrier’s USDOT number could be programmed into the onboard 

radio/recorder unit (i.e., a wireless communications control module that would be central to the 

proposed wireless inspection concept) using a compatible diagnostic tool in much the same way 

that such tools are currently used to reprogram electronic control units (ECUs) and clear fault 

codes. If or when the vehicle changes ownership, the carrier’s USDOT number could be 

reprogrammed by the new operator using available diagnostic tools. The management of 

electronic USDOT numbers for specific vehicles and fleets relative to updates, changes in status, 

and ownership would be handled in much the same way that current USDOT number decals are 

handled. An alternative concept would be to transmit only the VIN number (which is 

permanently linked to a particular vehicle) and match the VIN to a particular carrier or USDOT 

number using a reference database. While development and operation of such a database are 

challenging and would require close cooperation with States, such an effort is already being 

implemented under the Performance and Registration Information Systems Management 

(PRISM) effort. 

The inclusion of a driver’s license number as part of the SDMS is more challenging, inasmuch as 

it would require operators to digitally identify themselves to the truck’s electronic CAN. 

Technical solutions are available, such as the use of a standardized CDL “smart license” that 

contains a digitally coded CDL number, expiration date, restrictions, and other information. Such 

a card could be inserted into the vehicle’s dash as part of the ignition and starting procedure. 

Various technologies already exist and are used by some fleets as a way to manage/audit driver 

work hours/miles. Each technology—for example, “contact” and “contactless” cards—has its 

performance and cost trade-offs. The cost of the smart card itself would be very low (less than 

$10). A very rough cost estimate for modifying a vehicle to include a card reader, along with an 

interface to the vehicle’s electronic network, is $50 to $100. 

If positive driver verification is required, then biometric information could also be included on 

the card, and provisions for reading the same biometric identifier would be built into the truck to 

verify a match. Such concepts are readily available and have been demonstrated by FMCSA as 

part of the recent Hazardous Materials Field Operational Test (FOT). However, such concepts 

would also increase cost and complexity. 

There are two important programs which may impact the evolution of CDLs and their use for 

electronically identifying the driver to the truck: Transportation Workers Identification 

Credentials (TWIC) and REAL ID. 

12 
TWIC: The Transportation Security Administration (TSA) is mandated by Federal legislation to 

develop an ID system for individuals who need access to secure areas of the nation’s 

transportation system. The TWIC program will allow implementation of a nationwide standard 

for secure identification of transportation workers and access control for transportation facilities. 

Current estimates are that 12 to 15 million workers will be required to carry TWIC cards. The 

TWIC card is still in the very early stages of development, with the first pilot programs focused 

on port and maritime activities. Technically, the TWIC card is envisioned as a flexible, 

programmable smart card that could readily be used as a secure way for drivers to identify 

themselves to their trucks. Whether and how the TWIC program could be leveraged to support 

the wireless inspection concept requires additional investigation. It is clear, however, that a 

TWIC card could technically provide a standardized and controlled mechanism for digitally 

identifying the driver to the truck, and thus facilitate the inclusion of such data in an SDMS. 

REAL ID: In addition to TWIC, Federal legislation was passed in May of 2005 for the U. S. 

Department of Homeland Security (DHS), along with individual State Departments of Motor 

Vehicles (DMVs), to begin working together to develop what would be a national ID card. In 

practical terms, the Federal Government will establish technical and physical standards for the 

ID card to which States must adhere. Most likely, the REAL ID card, depicted in Figure 4, will 

take the form of a driver’s license. The focus of the REAL ID program is to increase security and 

authenticity standards for the issuance of State IDs or driver’s licenses. Information contained on 

the card will include, at a minimum, name, birth date, sex, ID number, a digital photograph, 

address, and a common machine-readable technology. This could be a magnetic strip, enhanced 

bar code, or RFID chip. The card must also support “physical security features designed to 

prevent tampering, counterfeiting, or duplication of the document for fraudulent purposes.” 

DHS is permitted to add additional requirements, such as a fingerprint or retinal scan, on top of 

these minimal information requirements. Like the TWIC card, the REAL ID card could become 

an important tool for positively (and electronically) identifying the driver to the truck. 

Digitally Coded Inform ation :

• Name

• CDL Number

• Restrictions

• Class

• Age , W eight

• Biom etric Identifier

Figure 4. Rendition of the REAL ID card. 

As noted, the inclusion of an operator’s CDL number as part of the SDMS would permit 

enforcement personnel (either at a stationary inspection facility, or in a mobile patrol vehicle) to 

download the information, check it against CDLIS and other databases for any issues/problems, 

and then decide whether the vehicle/driver should be targeted for more detailed inspections. 

While the benefits of having the CDL information as part of the downloaded data set would 

appear significant, it is not necessarily critical to the wireless inspection concept. Real-time 

13 
information on vehicle diagnostics, driver HOS logs, the VIN number, and USDOT number 

would also provide important and useful data. 

2.3.4 Wireless Vehicle-to-Roadside Communications 

There are numerous wireless technologies currently available or under development that could 

support wireless inspections. These technologies vary significantly in range, bandwidth, security, 

current deployment level, complexity, and cost. Due to the many technical challenges associated 

with the wireless inspection concept (i.e., speed of the traveling vehicles, message size 

requirements, security provisions, and implementation costs), the most promising short-range 

communications technologies appear to be 5.9 GHz DSRC, WiFi, or 900 MHz DSRC. 

WiFi (or Conventional 802.11a/b): For wireless inspection stations located at fixed facilities or 

at “virtual” locations, WiFi technology (802.11a operates in the 5 GHz band, while 802.11b 

operates at 2.4 GHz) could work, but with significant operational compromises. Significant 

application engineering and development work would be required, as WiFi is not intended to be 

used by a moving vehicle. The range on an 802.11b access point is only 300 feet, which means 

that a vehicle traveling 60 mph would only be in range for 3.4 seconds, not enough time to 

connect with the access point and download the SDMS securely. A significant development 

effort involving multiple roadside antennae, high-speed message transfers, and merging of data 

would be needed. Using WiFi, a vehicle would probably have to slow down and be directed to a 

dedicated, single-file lane to perform the transfer. Overall, WiFi technology would be a viable 

interim technology for testing and demonstration, but would not be viable to support efficient, 

cost-effective data transfer. 

Conventional Toll Tag Technology: Nine hundred (900) MHz DSRC communications are 

widely used in Europe and U.S. toll collection and transponder systems. This is also a viable 

short-range technology, and commercial systems are currently available. The technology has 

been proven in the moving vehicle environment and the radios are relatively affordable. 

However, because the range of existing 900 MHz DSRC is typically less than 30 meters, 

dedicated lanes or multiple access points (one for each lane) similar to current toll tag lanes 

would be required. In addition, the data rate available with 900 MHz systems is limited. The rate 

is approximately 0.5 Mbps (compared with 27 Mbps for 5.9 GHz DSRC). This limited 

bandwidth could significantly impact the size and complexity of the SDMS and could result in 

reduced inspection data, possible need for onboard compression, slower vehicle speed to transmit 

more data, or multiple access points. 

Dedicated Short-Range Communication (DSRC) at 5.9 GHz (802.11p): While still in 

development, 802.11p is a new Institute of Electrical and Electronics Engineers (IEEE) standard 

that is uniquely focused on facilitating vehicle-to-infrastructure and vehicle-to-vehicle 

communications. The proposed standards (IEEE P1609 series of documents) outline functional 

and performance requirements, as well as protocols for communicating in a 75 MHz bandwidth 

range between 5.850 GHz and 5.925 GHz. With support from USDOT, the Federal 

Communications Commission (FCC) made this spectrum available solely for vehicle use in 

2004. DSRC is ideally suited for the wireless inspections, since multiple vehicles could 

simultaneously communicate with a roadside access point within a one-half-mile range while 

traveling at high speeds. Most important, 5.9 GHz DSRC is being targeted as the technology of 

choice to support many other safety and convenience applications currently under development. 

With USDOT’s support, 5.9 GHz DSRC will likely become the standard for vehicle-to-roadside 

14 
and vehicle-to-vehicle communications in both heavy- and light-duty vehicles. It will support a 

variety of safety applications, including intersection collision avoidance, road condition warning, 

curve speed assistance, cooperative cruise control, and many others. So-called convenience 

applications, such as electronic funds transfer, advanced parking notification, rest stop 

information, or mobile media will also use the high-data rates of 5.9 GHz communications. 

Therefore, there will be opportunities to leverage the DSRC infrastructure and onboard vehicle 

transceivers well beyond just wireless electronic inspections. The aforementioned analysis 

indicates that DSRC technology is sufficiently robust, offers good security, supports two-way 

communications, and as a result is well- suited to supporting commercial vehicle wireless 

inspections. 

2.3.5 Needs of Other Federal Agencies for Monitoring CMVs 

The technology and infrastructure for electronically interrogating CMVs could be leveraged by 

other Federal agencies, including the Environmental Protection Agency (EPA) and the 

Transportation Security Administration (TSA), for emerging environmental and security needs. 

EPA: For 2008, the U.S. EPA has mandated a significant reduction in exhaust emissions from 

heavy-duty vehicles. At the same time, EPA is developing a complete technical and 

programmatic plan for checking/auditing the in-use compliance of trucks with these new 

standards. This plan calls for automated onboard diagnostics to report on the performance and/or 

failure of all emission system components. The heavy-duty program is modeled after the lightduty OBD II program. It requires the vehicle to be capable of assembling and storing a standard 

“emissions data message set” that reports the performance of emission components under predetermined conditions. The emission compliance check would most likely be made by 

connecting a standardized diagnostic tool to the vehicle’s controller area network (the J1939 

databus) and downloading the data. In other words, just as light-duty vehicles are required to 

complete emission system checks periodically, heavy-duty vehicles will be required to do the 

same in the future. 

Discussions with EPA and the California Air Resources Board (CARB) indicate that the logistics 

for how, where, and when emission inspections would take place have not yet been detailed. 

(California has given some indication that CMV emission inspections might be completed at the 

roadside by an appropriately trained officer.) Initial discussions with EPA about FMCSA’s 

interest in wireless safety inspections were enthusiastically received. If such a wireless 

interrogation infrastructure were put into place, it might be leveraged to collect diagnostic data 

on both emission and safety-related components. Further, EPA is already pursuing the basic 

technical work to standardize an emissions-related message set. Rather than pursue a different 

messaging framework and protocol for storing and downloading safety data, FMCSA could 

choose to leverage the basic technical protocols being put into place by EPA for emission system 

monitoring. Overall, there appears to be substantial common ground for EPA and FMCSA to 

work together on a broad wireless inspection project, and early discussions indicate that EPA 

would like to pursue this idea with FMCSA. 

TSA: New strategies and programs are currently being considered for tracking hazardous 

materials shipments. TSA has recently awarded a contract to General Dynamics to establish a 

nationwide hazardous materials tracking center. The focus of this work is on leveraging 

communications between both cellular and satellite telematic service providers and their fleet 

customers to monitor movement of goods. While satellite/cellular communications may be a 

15 
reasonable solution for hazardous materials carriers (the large majority of such carriers already 

utilize these telematic services), it is likely not a viable solution if there were a requirement for 

monitoring a much larger portion of the CMV freight industry. Standardized, short-range, 

wireless communication which does not require a service fee for operators does, however, offer a 

solution that might allow for more widespread tracking and monitoring options. 

Wireless information exchange applications that would support the efficient movement of goods 

across the Canadian and Mexican borders, while also increasing security levels, are also being 

considered by U.S. Customs. For example, a pilot program is being developed that would call for 

an electronic freight manifest to be forwarded by carriers about 45 minutes prior to their arrival 

at the border. The manifest would include information such as bill-of-lading, driver’s license 

number, VIN, carrier number, and other trip data. This data would be checked against various 

databases to determine if the vehicle, driver, and/or contents were authorized for entry. The 

ability to transfer such data wirelessly could enhance the effectiveness of the concept by 

allowing for all data to be contained within the vehicle and for the easy off-loading of the data 

along the roadside. Messages/instructions back to the vehicle operator would also be facilitated. 

As the wireless safety inspection concept moves forward, it will be important to determine if and 

how the needs of other Federal agencies involved in freight transport will be included in the 

overall program. Specifically, additional discussions with EPA, DHS, U.S. Customs, and 

possibly other agencies, are needed to determine how the wireless inspection concept might be 

broadened to include the information exchange needs those agencies have in regard to 

commercial vehicle operators. An FMCSA deployment plan focused only on safety might not be 

optimal for the trucking community because of the cross-cutting capabilities afforded by 

standardized wireless-to-roadside vehicle communication. 

2.4 WHAT VEHICLE AND DRIVER DATA SHOULD BE TARGETED FOR 

WIRELESS INSPECTION? 

To achieve maximum effectiveness, a wireless inspection program should target the vehicle and 

driver parameters that are most closely linked to crash causation. It should target those factors 

that led, either directly or indirectly, to a crash based on historical analysis of the data. An 

examination of historical inspection and crash data identified such causal factors. 

2.4.1 Inspection Data Analysis 

Inspection data from 1994 through 2004 were examined, and a detailed analysis of the inspection 

data was presented in the Task 2 Report. In general, the violation rates in various categories 

changed very little over the time period, with out-of-service rates caused by driver violations 

running between 5 and 10 percent, while vehicle out-of-service violation rates remained around 

25 percent, as shown in Figure 5. 

16 
Combination Vehicles

30

25

Figure 5. Out-of-Service Violation Rates: 1994 to 2004 

To obtain a better understanding of inspection violations, data from 2004 was analyzed in more 

detail. A high-level summary of the analysis (Table 6) shows that a relatively small number of 

major violation categories accounted for a large majority of all out-of-service violations. For 

example, defects associated with brakes accounted for 41 percent of all vehicle OOS violations 

(which, as noted earlier, account for about 73 percent of all OOS violations). Defective lighting 

systems (failed brake lights, turn signals, marker lamps, etc.) and poor tire conditions (no tread, 

low pressure, etc.) were also major OOS violation categories. Improper load securement was also 

often cited. 

Table 6: Leading Vehicle and Driver Out-of-Service Violation Categories 

OOS Group Category % of OOS Group 

Monitorable using currently 

available sensor systems and 

electronic data recording 

technology? 

Brakes 41.2% Yes 

Lighting 16.6% Yes 

Tires 9.4% Yes 

Load Securement 15.7% No 

Vehicle 

Total 82.8% 

All Logbook-Related 67.1% Yes 

Disqualified Drivers 4.7% Yes 

All Other Driver Violations1 23.4% No 

Driver 

Total 95.2% 

(1) “All Other Driver Violations” includes CDL-related violations, registration issues, proof of insurance, and other 

documentation/permit issues. 

0

5

10

15

20

Percent

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Vehicle

Driver

17 
For driver-related or non-vehicle-related violations (which account for 27 percent of all OOS 

violations), problems associated with the logbook were the largest violation category (67 

percent), while disqualified drivers (e.g., no license, improper class of license, expired license, 

etc.) accounted for about 5 percent of driver OOS violations. Problems associated with 

registration, permits, insurance, and other documentation accounted for about 23 percent of all 

non-vehicle OOS violations. 

Additional analyses were conducted comparing the violation rates between all inspections 

completed in 2004. An analysis was also conducted on a subset of these inspections that were 

completed on CMVs which were involved in actual crashes (16,500 such inspections out of a 

total of 3 million). The post-accident inspection data was screened to eliminate any violations 

that may have occurred as a result of the accident itself (such as broken lights, load securement 

problems, etc.). Key findings from this analysis show that: 

• HOS-related violations were about twice as high for vehicles in crashes as for all vehicles 

inspected 

• Disqualified driver violations were almost three times as high for vehicles in crashes as 

for all vehicles inspected 

• Instances of brake-related problems were about 2.5–3 times as high for vehicles in 

crashes as for all vehicles completing inspections 

• Load securement violations were about twice as prevalent on vehicles involved in crashes 

as on all vehicles inspected 

2.4.2 Crash Data Analysis 

An analysis of crash data which focused on identifying the cause of CMV crashes was also 

completed; details are presented in Appendix D. This analysis included a review of historic 

databases [MCMIS, General Estimates System (GES), FARS] and of the newly released Large 

Truck Crash Causation Study (LTCCS). To a great extent, this analysis confirmed many aspects 

of conventional thinking regarding the causes of large-truck crashes. For example, a large 

portion of all commercial vehicle crashes are linked to (or initiated by) the other (non-truck) 

vehicle involved in the crash. Fatigue was a major contributing factor in those crashes where the 

commercial vehicle was linked with the critical event leading to the crash. In general, the 

LTCCS Study provides the most complete, detailed, and recent information about critical events 

and supporting factors leading to commercial vehicle crashes. 

The LTCCS was a 3-year data collection project conducted by the National Highway 

Transportation Safety Administration (NHTSA) and FMCSA. FMCSA commissioned this study 

to collect an extensive and nationally representative database on the primary and secondary 

causes of serious large-truck crashes. Post-crash analyses on vehicles were conducted, as well as 

interviews with drivers, other occupants, and pedestrians who were involved in the accidents, to 

reconstruct a complete picture of the accident’s causes and effects. The database includes 57 

related tables containing information on 1,070 total crashes, each involving at least one large 

truck. Sample weights were calculated and applied for each case so that valid national estimates 

and sample error estimates could be made. 

18 
Figure 6 provides an overview analysis of crash data based on the “critical event” code assigned 

to each crash. This particular table (“critical event”) is a key table within the database that 

assigns the critical event leading to the crash to either the truck or the other vehicle—and then 

further assigns the critical event to one of several driver, vehicle, or environmental factors. 

Key findings from Figure 6 include the following: 

• About 60–65 percent of CMV crashes are linked to the truck entity. (This statistic may 

surprise many industry observers. A somewhat common misperception is that most CMV 

crashes are caused by the driver of the other vehicle, which most often is a passenger car. 

The data from the LTCCS shows that for those crashes that involve two vehicles, one a 

car and the other a truck, more often than not the critical event leading to the crash is 

assigned to the car. However, there are many CMV crashes that do not involve cars or 

light-duty vehicles. When all CMV crashes are considered, in most instances the critical 

event is in fact assigned to the truck.) 

• Most of these crashes (87 percent) are linked to driver error. 

• While “fatigue” is not directly cited as the “critical reason” for a crash, drivers were cited 

as being fatigued in 22 percent of CMV crashes where the truck was linked with the 

critical reason for crash. 

• Where a vehicle defect was the critical reason for the crash, brakes, tires, and load 

securement issues were the factors most often cited. 

All Commercial Vehicle Crashes

100%

64% 36% Critical Event Linked 

to Other Vehicle

Driver Error 87% 10% Vehicle Defects

Sleep, that is, actually asleep 1.7% 39% Brakes

Inattention (i.e., daydreaming) 8.6% 21% Tires

Inadequate surveillance 20.9% 29% Load Securement

External distraction 4.7% 1% Other Vehicle defects

Internal distraction 4.3% 100% Total Vehicle

Too fast for conditions to be able to respond 10.0%

Misjudgment of gap or other's speed 5.0% 2% Environmental

Following too closely to respond to unexpected events 7.6% 1% Unknown

Too fast for curve/turn 2.3%

False assumption of other road user's actions 3.7%

Illegal maneuver 7.3%

Inadequate evasive action 1.7%

Aggressive driving behavior 1.3% In 22% of these crashes the driver 

Panic/Freezing 0.3% was determined to be fatigued.

Overcompensation 2.0%

Poor directional control 2.3%

Heart attack or other physical impairment 1.7%

Other decision error (specify) 4.0%

Other critical non-performance (specify) 0.3%

Unknown recognition error 4.3%

Unknown decision error 0.3%

Type of driver error unknown 5.6%

Total Driver Error 100.0%

Critical Event Linked to Truck

Figure 6. Overview: Analyses of LTCCS Data 

19 
2.4.3 Summary of Inspection and Crash Data Analyses 

Several key observations emerge from the analyses relative to the design of a wireless 

inspections concept: 

• Driver error far outweighs vehicle-related defects as a factor contributing to commercial 

vehicle crashes, and fatigue is among the dominant factors contributing to driver error. 

Therefore, technologies and methods for directly or indirectly monitoring driver 

performance and fatigue will likely yield substantial safety benefits. The results could be 

used for various screening and/or enforcement strategies. These strategies could include 

monitoring of HOS to ensure compliance, and monitoring of the driver using 

technologies such as lane departure warning, eyelid-closure monitoring, and other 

systems. 

• While complex circumstances and driver predisposition traits often contribute to driver 

error, the crash and inspection data analyses completed here, along with other recent 

studies completed by the American Trucking Research Institute, provide additional 

insight. These studies clearly show that drivers who were previously involved in a crash, 

who had prior convictions, or who were not properly licensed (invalid or expired CDLs), 

had a significantly higher probability than other drivers of being involved in a crash in 

the future. Therefore, the ability to remotely identify the driver (by obtaining the CDL 

number) using wireless technologies would provide the basis for a variety of enforcement 

strategies or concepts. For example, the CDL number could be interrogated (downloaded) 

well ahead of a fixed inspection station and checked against CDLIS and other databases; 

then an automated determination could be made as to whether to target the driver/vehicle 

for further inspection. More directly, if the driver were operating without a proper CDL, 

such information would become immediately known to the local enforcement agency, 

and the truck could be targeted and pulled over. 

• For crashes in which the truck (and not the other vehicle) was linked to the critical causal 

event, vehicle defects were cited as causing the critical event in only about one out of 10 

crashes. However, it is well-known that degraded braking performance, worn tires, 

inoperative lighting, and/or improper load securement are important secondary factors 

contributing to the severity of the crash. Therefore, a wireless inspection concept should 

target these vehicle systems. While technologies are available for electronically 

monitoring brakes, tires, and lighting systems, practical technology for electronically 

monitoring load securement is not available. Because of the wide diversity of loads, truck 

and trailer designs, and securement methods, it is unlikely that a practical, standardized 

means of monitoring load securement will be developed in the near future. 

2.5 POTENTIAL IMPACTS OF MORE FREQUENT INSPECTIONS 

It is clear that more frequent inspections of vehicles and drivers (along with follow-up 

enforcement strategies such as warnings, fines, etc.) will lead to a reduction in violations and an 

improvement in CMV safety. However, the level or frequency of inspections sufficient to 

produce a significant change in behavior on the part of operators and fleets remains to be 

determined. The current weight enforcement program provides important insights. 

20 
During hours of operation, a typical CMV inspection station will weigh nearly all of the trucks 

that pass by the station, depending to some degree on traffic density, the availability of labor, and 

other factors. Table 7 shows that in 2003, there were approximately 178 million weight 

inspections completed. This compares with about 3 million safety inspections. Many interstate 

trucks will be inspected for weight on nearly every trip they take. The impact on compliance 

levels is clear. The weight enforcement program has achieved a high degree of success with total 

violation rates at a very low 0.29 percent, as shown in Table 7 Also, the total weight and size 

violation rate is just under 2 percent for the 3 million CMVs selected for Levels I, II, or III safety 

inspections. 

Table 7. CMV Weight Inspections 

Vehicle Weight Inspections 2003 

Static Weighs 82,290,618 

WIM 95,078,759 

All Weighs 177,369,377 

# of Citations 515,587 

Percent of Citations to Weighs 0.29% 

The data suggests that fleet operators know there is a high probability of their vehicle being 

subjected to a weight check if it travels any significant distance on interstate highways. Several 

studies have shown that with no enforcement, weight violation rates can be as high as 20–30 

percent, but with enforcement programs in place, violations drop to 1–3 percent. There is a clear 

economic incentive for many fleet operators to overload their trucks, yet because of the 

successful weight enforcement program that is in place, weight violations are arguably very low, 

as shown in Table 7. 

For a typical fleet operator, the chances of a particular vehicle being selected for a full Level 1 

safety inspection are very low when compared to the systematic weight inspection programs that 

are in place. As noted earlier, many mobile and fixed stations currently rely on weight as a key 

factor in deciding whether the vehicle requires further inspection. Therefore, for underweight 

trucks, the typical inspection station will rely on a random algorithm to select trucks for 

inspection. Anecdotal evidence indicates that many inspection sites set the random selection 

feature to choose approximately 5 percent of the trucks entering the weight/inspection station. 

Even after this filter is applied, the truck may still not be inspected, particularly if the vehicle 

generally appears to be in good condition as judged by the enforcement officer. Analysis of 

safety inspection data shows that for the industry as a whole, the average truck will undergo a 

full Level 1 safety inspection only about once every 3.5 years. Based on these statistics, the odds 

of being subjected to a safety inspection on any given trip are very low. Therefore, a sizable 

portion of commercial vehicle operators take the risk of not being inspected and routinely delay 

maintenance and/or push the limit relative to hours of service. They may rationalize their 

behavior in the belief that if they are selected for inspection, more often than not the violations 

will not result in an OOS condition, and that violations are just part of the cost of doing business. 

The results speak for themselves in that three out of four trucks selected for an inspection receive 

21 
some type of violation, while one out of four trucks randomly selected is actually placed out of 

service. 

The weight enforcement programs in place throughout the country offer a powerful lesson 

concerning inspection frequency, and clearly demonstrate the impact that increased inspections 

can have on modifying the behavior of fleets and operators. Implementation of a wireless 

inspection program which substantially increases the frequency of screening trucks for vehicle 

and/or driver irregularities would likely yield significant improvements in the safety of 

commercial vehicle operations. 

2.6 PUBLIC COMMENT ON WIRELESS INSPECTIONS 

On August 16, 2005, FMCSA published an RFI related to advanced concepts for commercial 

vehicle wireless inspections in the Federal Register (vol. 70, no. 157, Docket FMCSA-2005-

22097). FMCSA invited responses, suggestions, and creative ideas on new operational concepts 

which would improve commercial vehicle safety inspections through more performance-based 

inspections. 

FMCSA received 27 responses to the RFI between August 16 and October 25, 2005. One-third 

of the responses (nine) received came from heavy-vehicle OEMs and component/electronics 

suppliers. Seven industry associations, one fleet, and two State enforcement agencies also 

responded to the RFI. Table 8 shows a breakdown of the responses. 

Table 8. Responses to the RFI 

Number of Type of Respondent Responses 

Vehicle OEMs and Suppliers 9 

Fleets / Motor Carriers 1 

State Enforcement / Inspection Agency 2 

Industry Associations / Advocacy Groups 7 

Transportation Research Centers 2 

Private Party / Unspecified 6 

Total 27 

To help focus responses, the RFI presented 14 specific questions. A complete list of these 

questions, along with a summary of the responses, is included in Appendix F (available upon 

request from the FMCSA Office of Analysis, Research and Technology). 

Several respondents commented that a wireless inspection concept could include a simplified 

“pass/no-pass” output to allow inspectors to screen vehicles more quickly. This concept would 

be similar to current electronic clearance programs which pre-screen vehicles before they enter 

the inspection area, allowing “passed” vehicles to bypass the inspection area, with “no-pass” 

vehicles required to pull in for inspection. 

22 
A variation on the “pass/fail” concept submitted by the American Trucking Association (ATA) 

called for only “ok” messages to be sent by the vehicle. ATA’s argument was that fleets would 

be reluctant to embrace a concept that called for them to wirelessly transmit information that 

would increase their chances of being pulled over for a full inspection. They argued that a fleet 

would be better off sending no signal at all, as opposed to a “not ok” signal. Further, ATA 

argued that a simple “vehicle ok” message could be used to bypass more vehicles, thus allowing 

enforcement agencies to concentrate on the remaining vehicles. 

Nine respondents suggested that driver HOS logs could be accurately monitored by the onboard 

unit. These respondents also suggested that the driver CDL and vehicle DOT numbers could be 

stored on the onboard unit to identify the driver and vehicle. Two of the respondents referenced 

the possible use of biometrics to identify drivers, as well as scanning of the driver’s CDL card 

when he/she entered the vehicle. 

Two respondents suggested that electronic screening of vehicles could be used on non-interstate 

roads to catch high-risk vehicles that try to avoid passing inspection stations. A response from 

the Public Utilities Commission of Ohio (the agency that regulates commercial vehicles in Ohio) 

stated: 

“Any increase in the volume of inspections will likely have an impact on behavior. 

However, there may be other factors that should also be considered that could 

impact behavior. For instance, if inspections can be conducted using electronic 

data that is quicker, easier to access, and more accurate than that which can be 

collected by individual inspectors, this may increase compliance since carriers 

will know that enforcement personnel have better tools to determine if a violation 

is occurring. Also, enhancing the ability to more easily conduct vehicle 

inspections on other non-interstate roads where inspection facilities are not 

located may help to catch those who currently attempt to avoid mainstream 

inspection facilities, which may increase compliance too.” 

In general, the comments received from the RFI provided valuable insight into the requirements 

and thoughts of the motor carrier industry on possible wireless inspection alternatives. These 

comments were taken into consideration as part of this analysis of the requirements for wireless 

inspections. 

2.7 STATE ENFORCEMENT AGENCY SURVEYS 

In addition to the RFI process, the Study Team also specifically targeted State-based CMV 

enforcement agencies for comments and suggestions related to a wireless inspection concept. 

Several State inspection stations were visited. Wireless inspection presentations were made at 

two industry meetings, one hosted by TMC) and the other by CVSA. 

The results of discussions with State inspectors yielded the following observations and 

recommendations: 

• To be truly valuable, a wireless inspection concept should facilitate a substantial increase 

in the number of inspections that can be completed. 

• Onboard sensors should augment accuracy and efficiency of traditional Level 1 

inspections. 

23 
24 

• Tamper resistance and security of data transmissions must be ensured. 

• Concepts should target those portions of the CMV population that are not currently being 

inspected or are underinspected: 

– Carriers and drivers who routinely select bypass routes 

– Straight trucks 

– Local and/or intrastate trucks 

• Diagnostics and associated data to be transmitted wirelessly should target vehicle 

components and operational parameters that are linked to vehicle accidents and high 

violation rates. 

Several enforcement officers at the State level were interviewed, as were State administrators 

responsible for overseeing State inspection programs. When asked what information they would 

like to see collected on vehicles as a means of improving either the screening process or the 

inspection itself, they gave responses that were consistent and focused on the following 

information (not listed in order of importance): 

• Advanced message that contains the USDOT number to check carrier history 

• Advanced message that contains the CDL information to check status of credentials 

• Advanced message that contains the VIN or other vehicle identifier information to check 

results of last inspection 

• Advanced message that provides electronic HOS record 

• Brake diagnostics data 

• Tire diagnostic data 

• Advanced information that relates to size and weight 

2.8 SUMMARY OF REQUIREMENTS ANALYSIS 

Based on work to date, the high-level requirements for a wireless commercial vehicle inspection 

concept should focus on gathering data related to the brakes, tires, lighting systems, HOS, CDL 

information, carrier identity, and VIN. All of this information already exists on the vehicle via 

discrete sensor systems or electronic control modules. By using conventional technologies, it 

could be electronically linked to the vehicle’s serial databus for subsequent transmission by an 

onboard wireless communications module. This information, when combined with the historical 

information already available on carriers and drivers and accessible via ISS, CDLIS, or other 

State databases, would provide the enforcement community with a very powerful decision 

support tool for screening vehicles and/or implementing virtual, automated wireless inspection 

sites. 

It should be understood that while the raw data exists on the vehicle, there may be considerable 

work and consensus-building required to develop “pass/fail” or rating criteria based on new 

electronic diagnostic information. The technical and regulatory work to be completed would be 

similar in concept to that which supported the development of emission inspection protocols as 

part of the Onboard Diagnostics process implemented by EPA. 
3.0 DEVELOP ALTERNATIVE CONCEPTS 

OF OPERATION 

Under this Task, alternative concepts of operation were developed that were differentiated based 

primarily on the venue and methods through which information is exchanged with the vehicle. 

Concepts examined included: 

1. Enhanced Screening at Existing Fixed Facilities 

2. Virtual, Unmanned Inspection Stations 

3. Mobile Inspection Units 

4. Ubiquitous Inspection Concept 

5. Kiosk Self-Inspection Concept 

6. Non-Cooperative Inspection Concept (i.e., conventional, non-wireless inspections using 

advanced infrastructure-based sensing equipment)

With the exception of the last concept, all would rely on the same basic modifications to the 

onboard electronic architecture to support the wireless transfer of information to and from the 

vehicle. The Wireless Communication Control Module would become the core of the system. 

Functionally, this module would consist of a simple application processor with moderate 

memory requirements for storing the SDMS (i.e., fault codes, HOS data, etc.). The application 

processor would assemble the electronic data from various subsystems and discrete inputs, and 

would perform any formatting of the data necessary for transmission. A high-level schematic of 

vehicle modifications needed to support a generalized wireless inspection concept is shown in 

Figure 7. 

Application Processor

DSRC 

Tranceiver

GPS 

Tranceiver

Potential Discrete Inputs

• EOBR Device

• “Smart” RFID Driver’s 

License

• Trailer Information 

Module

Wireless 

Communications 

Control Module

CAN Bus (J1939)

Lighting

Brakes

Tires Fuel 

System

Air System Other Vehicle 

Diagnostics

Controller Area Network

Dash 

Display

• Other Driver Monitoring 

Systems (LDWS, 

Collision Warning)

Antenna

Figure 7. High-Level Vehicle Modifications to Support a Wireless Data Transfer 

25 
Instead of transmitting raw sensor data, the application processor would be programmed to 

analyze data (such as comparing sensor measurements against pre-set limits) to determine 

whether “pass,” “fail,” or other types of messages should be transmitted. Depending on concept 

requirements, the application processor could also assemble vehicle or driver performance 

histograms or other summary statistics from various input sensors. For example, the unit could 

be programmed to record the number of hard-braking events that occurred during various time or 

mileage histories. It would also be comparatively simple to include EOBR functionality in the 

application processor if appropriately programmed. 

The Wireless Communications Control Module would also contain the DSRC (5.9 GHz) radio 

needed to transmit and receive messages. Again, depending on the concept of operations, the 

wireless control module would include an integrated GPS module, since location data would be 

needed to support HOS recording as well as other functions. The Wireless Communications 

Module would be linked to a dash module in order to display the status of various systems as 

well as messages sent or received from the infrastructure. It is important to understand that the 

onboard architecture shown in Figure 7 is notional. In reality, truck manufacturers would 

implement the required functionality as cost-effectively as possible. The manner in which GPS, 

DSRC radio, EOBR, and application-processing modules are physically combined and integrated 

will probably vary among manufacturers. 

Each of the six venue-based concepts for collecting wireless data from the CMVs is described in 

the following sections. 

3.1 ENHANCED SCREENING AT EXISTING FIXED FACILITIES 

This concept focuses on the use of a conventional fixed-facility inspection site with advanced 

information about the safety status of an approaching vehicle that will determine whether the 

vehicle must pull into the facility for a full Level 1 inspection. This concept would enable realtime or near-real-time information about the safety condition of the vehicle and driver to be 

relayed to the station. 

The technologies and components needed to support this concept would be packaged in fixed 

installations called enhanced screening stations (ESS) and would be located approximately 1–2 

miles before weigh stations (see Figure 8). This concept focuses on improving the efficiency of 

the pre-screening process by combining identification data used to retrieve historical safety data 

(such as existing pre-screening systems) with actual real-time data about the vehicle maintenance 

and/or driver performance. As this concept is refined further, it could automatically identify 

noncompliant vehicles and direct them to be inspected at weigh stations, or, as confidence in the 

accuracy of the diagnostic systems becomes established, it could directly issue citations. 

3.2 VIRTUAL, UNMANNED INSPECTION STATIONS 

The virtual inspection concept is a derivative of the enhanced screening concept. However, it 

eliminates the need to be located near existing fixed-facility stations. An automated, unmanned 

inspection station (a virtual inspection station or VIS) could be located anywhere on the highway 

system and could incorporate short-range wireless communication to interrogate and receive the 

26 
Figure 8. Enhanced Screening Concept 

vehicle’s SDMS while it is traveling at normal highway speeds. In addition, the VIS would 

include a WIM scale and could also include additional non-cooperative diagnostic technologies 

such as digital cameras for recording license plates numbers and/or infrared brake detection. 

Unlike the enhanced screening concept, however, the data gathered would be used primarily to 

issue warnings and/or citations directly to the carrier/operator via mail or email, rather than for 

supporting decisions to inspect or bypass the station. The data collected would also be used to 

update State and Federal CVO safety and operations database, and the results could be used to 

update SafeStat scores. Since the largest part of in inspection facility’s operating cost is labor, 

this concept provides for the cost-effective expansion of inspection points and would therefore 

increase the probability and frequency of CMV inspections. 

3.3 VIRTUAL, UNMANNED INSPECTION STATIONS 

The virtual inspection concept is a derivative of the enhanced screening concept. However, it 

eliminates the need to be located near existing fixed-facility stations. An automated, unmanned 

inspection station (a virtual inspection station or VIS) could be located anywhere on the highway 

system and could incorporate short-range wireless communication to interrogate and receive the 

vehicle’s SDMS while it is traveling at normal highway speeds. In addition, the VIS would 

include a WIM scale and could also include additional non-cooperative diagnostic technologies 

such as digital cameras for recording license plates numbers and/or infrared brake detection. 

Unlike the enhanced screening concept, however, the data gathered would be used primarily to 

issue warnings and/or citations directly to the carrier/operator via mail or email, rather than for 

supporting decisions to inspect or bypass the station. The data collected would also be used to 

update State and Federal CVO safety and operations database, and the results could be used to 

update SafeStat scores. Since the largest part of in inspection facility’s operating cost is labor, 

27 
this concept provides for the cost-effective expansion of inspection points and would therefore 

increase the probability and frequency of CMV inspections. 

3.4 MOBILE INSPECTION UNITS 

Currently, mobile inspection stations are vehicles equipped with portable scales and other 

equipment needed to perform a roadside inspection. They offer CMV enforcement personnel the 

ability to inspect vehicles that would not routinely pass by a fixed station or that purposely avoid 

such stations. These mobile inspection units typically include the following capabilities: 

• Portable scales 

• Wireless access to carrier, driver, and vehicle licensing and inspection databases (via 

SAFETYNET, CDLIS, MCMIS, and other , State-based IT support systems described in 

Task 2) 

• Tools and equipment needed to perform a Level 2 or 3 safety inspection 

Numerous States are currently using mobile inspection units in addition to fixed inspection sites, 

and some States use only mobile inspections, with no fixed inspection sites. Mobile inspection 

units provide a flexible method for locating vehicle inspection points, and make it possible for 

enforcement personnel to adjust the geographic focus of inspection efforts. Such strategies are 

particularly effective for targeting inspection of trucks that may not normally pass by fixed 

inspection sites, or may use a convenient bypass route around a permanent fixed inspection site. 

Under this concept, both the commercial vehicle and the police vehicle would be equipped with 

compatible or interoperable wireless short-range communication technology. When a police 

vehicle approached a moving or stationary commercial vehicle, the enforcement officer could 

electronically query/poll the vehicle and request an inspection file or SDMS. The SDMS would 

be transmitted to a processing unit on- board the police vehicle that contained evaluation and 

analysis algorithms similar to those that would be employed at a fixed site under the enhanced 

screening concept. It is also assumed that the mobile unit or police vehicle would have wireless 

access to SafeStat scores and other State and Federal databases that contain information on 

credentials, permits, taxes, and fees, and other historical data that would be needed by the officer 

to help make a determination as to whether to pull the vehicle over for additional visual and 

manual inspection. Additional application programming work would be required to refine and 

synthesize the results of the safety evaluation so that they could be conveniently viewed by the 

officer on an onboard display/reader in the police vehicle. For example, the onboard transceiver 

in the police vehicle might initially display high-level results from the SDMS download, but also 

include menu options that would allow the officer to quickly drill down into the data. SafeStat 

scores might initially be displayed, followed by summary information related to the real-time 

safety data collected via the SDMS. The enforcement officer would be able to pull this vehicle 

over based on the information provided. 

3.5 UBIQUITOUS INSPECTION CONCEPT 

This concept is focused on leveraging vehicle monitoring and diagnostic service offerings 

currently being implemented by selected commercial telematic service providers such as 

Qualcomm, PeopleNet, Orbcomm, and others. Such companies are beginning to offer option 

28 
packages for a fixed monthly fee that would equip vehicles with onboard technology capable of 

collecting and storing various diagnostic and fault code data available on the vehicle’s serial 

databus network. Some systems also allow for monitoring and recording the output of other 

optional electronic systems such as electronic HOS recorders and lane tracking, collision 

warning, and tire pressure monitoring systems. Normally, the carrier will work with its telematic 

service provider to determine:

• The specific data to collected and the optional driver and/or vehicle monitoring systems 

that should be added to the vehicle (if any) 

• The various rules for when and where such data should be downloaded 

For example, some carriers may only wish to periodically collect vehicle maintenance 

information, while others will want to focus on monitoring driver performance parameters. Also, 

some carriers may wish to collect such information based on a fixed time interval (perhaps once 

a day), while others may choose to collect data only on an ad hoc basis or when some predetermined condition or threshold is exceeded. For example, a carrier may wish to be notified 

and have various operating parameters recorded only when vehicle speed exceeds a certain limit, 

or when an ABS event takes place. Additionally, since virtually all telematic service providers 

offer vehicle location capability, carriers may wish to have vehicle and/or driver diagnostic data 

communicated or downloaded using location-based rules. 

Under the ubiquitous inspection concept, the SDMS containing various vehicle health and/or 

driver performance parameters would be shared with the State CMV enforcement agency 

whenever such data was downloaded by the telematic service provider, based on its contract with 

the customer. Alternatively, the enforcement agency could require the telematic service provider 

and carrier to gather and download an SDMS based on: 

• Regulated conditions (such as when a vehicle is in the vicinity of an inspection station, or 

perhaps when a vehicle is entering a new State) 

• A simple random querying of vehicles equipped with such telematic monitoring and 

communications capability 

After receiving the SDMS, the telematic service provider would forward the information to the 

enforcement agency in the most cost-effective way (probably using traditional landline 

connections). The information would then be analyzed to determine safety conditions (most 

likely using automated algorithms) and an appropriate message/instruction set would be sent 

back to the telematic service provider by the enforcement agency. The telematic service provider 

would then relay the message to the vehicle via satellite or cellular communications. Such 

messages might call for the vehicle to pull over at the next inspection station, authorize the 

vehicle to bypass the next station, or issue other warnings and advisory messages. 

Carriers would need to voluntarily participate in the program and instruct their telematic service 

providers to forward a copy of SDMS to the enforcement agency, or a regulatory framework 

would have to be developed that would mandate carriers having long-distance telematic 

capability to comply with programmed and/or ad hoc requests from the Government or 

enforcement agency for the SDMS. 

A robust and sophisticated communications and Information Technology plan would need to be 

established for backhaul communications and IT systems. The backhaul network would enable 

telematic service providers to quickly and reliably transfer data collected from specific vehicles 

29 
not only to the appropriate enforcement agency having jurisdiction, but also to the specific 

inspection facility that is closest to, and in the direction of travel of, the vehicle being monitored. 

It is assumed that the telematic service provider would interface with the enforcement agency as 

well as with FMCSA, using access points available either through CVISN and/or COMPASS 

networks. The concept would call for the telematic service provider to electronically download 

its inspection data into an ASPEN-like program that would then automatically forward the data 

to SAFETYNET. 

An overview of the information flow and processes involved in this concept is shown in 

Figure 9. 

Carrier Dispatch 

Center

Satellite-to-Vehicle 

Communications

Mobile

Enforcement

Units Telecommunication 

Service Provider (Cellular)

CDMA Cellular 

Modem

Self-Inspection

Enforcement 

Agency Portal

(possibly via 

CVISN linkages)

Telecommunications Infrastructure / Internet

FMCSA IT Networks 

and Applications

(COMPASS)

Telecommunication 

Service Provider (Satellite)

Pre-Screening,

Warnings, 

and/or 

Citations

Warnings, 

Citations issued 

directly to Carrier

Pre-Screening,

Warnings, 

and/or 

Citations

Roadside

Inspection 

Stations

Figure 9. Ubiquitous Inspection Concept 

The primary advantage of this concept is that it leverages communications and monitoring 

equipment already onboard a large number of vehicles (approximately 500,000) that are using 

long-distance telematic services. For these fleets and vehicles, little additional equipment would 

need to be installed on the vehicle. Also, this concept focuses on simply requiring or otherwise 

encouraging the sharing of this data with FMCSA and with the local enforcement agency. The 

incentive for equipped vehicles would be the ability to bypass inspection stations without the 

need to purchase and install RFID tags from organizations like Pre-Pass or NorPass. 

30 
Challenges include the following privacy and institutional issues, costs, and communication 

system and IT complexities: 

• Privacy and Institutional Issues: This concept could allow the Government or State 

enforcement agencies to monitor HOS, driver performance, and vehicle condition on an 

almost-continuous basis, or to be instantly warned of violation conditions, based on 

certain triggers and thresholds being exceeded. A large percentage of fleets will be 

concerned about the level of oversight that the Government would acquire if this concept 

were applied. 

• Cost: Data transmissions using long-distance satellite or even cellular communication 

media are expensive compared to short-range communication solutions. Satellite and 

cellular communications include significant per-transaction costs and/or fixed monthly 

service fees. The total costs of such transmissions to support various types of vehicle 

monitoring will need to be investigated, but current pricing at the time of this research is 

in the range of $25–$75 per month. The Government or local enforcement agency having 

jurisdiction would essentially become a third-party customer of the telematic service 

provider, and would incur a monthly service fee for the two-way communications 

established with the commercial motor vehicle population (i.e., the costs that would be 

incurred for downloading and uploading messages to vehicles). On the other hand, with 

short-range communication concepts, there are no transaction costs once the capital costs 

for the onboard and wayside equipment have been covered. 

• IT and Communications System Complexities: The landline communications network 

and the information processing and database systems needed to support this concept are 

somewhat complex. This is partly due to the fact that the telematic service provider is a 

go-between, which doubles the number of messages as compared to a more direct shortrange communications-based concept. The network complexity associated with the 

concept may be able to be simplified by having the telematic service provider act as an 

agent of the Government, but this solution may result in increased risk associated with 

ensuring the integrity and control of proprietary safety data. 

3.6 KIOSK SELF-INSPECTION CONCEPT 

All of the previously described concepts yield control of the time and location of wireless 

inspections to the enforcement agency having jurisdiction. The kiosk self-inspection concept is 

unique in that the inspection or downloading of the SDMS is performed at times and locations 

convenient to the driver. This concept focuses on the portion of the market that would be most 

skeptical or concerned about giving up control of various vehicle maintenance and operating 

data. However, these drivers would also like to participate in programs that might allow them to 

conveniently bypass inspection stations. The target market would most likely be smaller fleets 

and/or owner-operators. 

The self-inspection kiosk is a stand-alone device or station that would consist of a screen and 

terminal similar to those used by banks in the form of automated teller machines (ATMs). The 

terminal would provide a means for the driver to enter information such as his driver’s license 

number, USDOT number, and license plate number. The kiosk would have the capability to scan 

this information if it were available in bar code and/or magnetic strip format. The kiosk would 

also be equipped with a means to wirelessly communicate with the truck (probably using 

31 
currently available WiFi or Bluetooth technology) to pull safety-related information from 

onboard systems and sensors. The driver’s HOS log could also be downloaded wirelessly and 

checked electronically. The key to this approach is that not only could the kiosks be placed at 

locations convenient to the driver, but the inspections could be performed when the truck is off 

the road. Possible locations include fueling stations, truck stops, and rest areas. 

The concept requires the driver to pull up to an inspection kiosk, enter in the required 

information, allow the safety inspection data to be downloaded from the truck, and wait for the 

results. Upon confirmation of a “passing grade,” for driver and vehicle, the kiosk could issue a 

decal or possibly an inexpensive passive RFID tag the driver could display or mount on the 

outside of the vehicle; display of that decal or tag would allow the driver to bypass inspection 

stations. The data generated by the self-inspection kiosk would also be made available to the 

local enforcement agency, as well as to Federal databases (e.g., MCMIS). 

There are several advantages to the kiosk self-inspection concept, including: 

• Decentralized safety inspections that would reduce congestion at weigh stations 

• Driver ownership of, and buy-in to, the vehicle safety inspection process 

Challenges in implementing this concept include: 

• Capital and maintenance costs associated with kiosks 

• Integrating data from the kiosks with existing fixed stations would require stations to be 

equipped with an RFID reader and/or an optical character recognition system to 

positively ID the truck 

• Particular concern for potential tampering and fraud related to falsifying of decals, 

electronic tags, and/or other documentation 

3.7 NON-COOPERATIVE INSPECTION CONCEPT 

Concepts 1–5 rely on technical cooperation between the commercial vehicle and the roadside for 

wirelessly downloading self-diagnostic safety data. Whether such concepts are deployed though 

market-based incentives or are regulated, there is still technical cooperation between the vehicle 

and the off-board reader device. If, however, such concepts become impractical because of 

various institutional, cost, political, and/or policy concerns, then advanced non-contact, noncooperative technologies for assessing the condition of the vehicle might be employed to help 

automate and speed up the inspection process. The term “non-cooperative” as used here means 

that it is not necessary for the vehicle to participate (or cooperate) in facilitating the 

advanced/remote diagnostic procedures. 

The non-cooperative inspection systems could be integrated with any existing roadside 

inspection station and might consist of the following elements: 

• WIM sensing system 

• Automatic vehicle identification (AVI) equipment 

• Roadside message displays 

• Infrared inspection system (IRIS) 

32 
33 

Other inspection equipment, such as performance-based brake testers (PBBTs), acoustic sensors, 

and/or gas sniffer sensors, could be added to the inspection area. The screening system does not 

require that special equipment be installed on vehicles, nor does it require any feedback from 

vehicles in order to operate. 

The advantage of this concept is that it can be readily implemented by State CMV enforcement 

agencies, provided sufficient funds are made available. The disadvantages, however, are that 

such a concept would not significantly increase the number of inspections that could be 

completed, nor would it allow for the real-time identification of the driver through the 

downloading of the CDL number. 
4.0 CONCEPT EVALUATION 

As initially envisioned, Task 4 was to have focused on evaluating each of the concepts 

(developed in Task 3) based on cost, safety benefits, operational considerations, and institutional 

deployment issues. During the assignment, however, the Project Team concluded that no single 

deployment concept was optimal for all operating environments. Rather, an optimal deployment 

of wireless inspection technology would more likely involve utilization of multiple venue-based 

concepts (e.g., fixed stations, mobile units, virtual stations, etc.) tailored to the specific needs and 

operating environments of each State. To proceed with Task 4, alternative wireless inspection 

concepts were redefined based on the specific types of information to be collected, rather than on 

the venue/processes for collecting it. The new concepts developed represented a range of 

complexity, costs-to-implement, and potential safety benefits. The six new SDMS concepts are 

summarized in Table 9. 

Table 9. Alternative Wireless Inspection Concepts 

Based on Safety Data Message Set (SDMS) Content 

Required Onboard Hardware and SDMS Alternative Key Output Data Collected Modifications 

DSRC Transceiver with integrated data 

storage buffer and operating system for 

storing and staging fault code and ID data 

for wireless transmission. 

Currently or readily available fault code 

information on the J1939 network related 

to brakes, transmission, engine, electrical 

and lighting system, and other electronic 

components. 

1 Vehicle-Basic 

As above but includes Tire Pressure 

Monitoring and Brake Performance 

Diagnostic systems. 

As above, but includes specialized 

diagnostic data for brakes, tires, and 

lighting systems. 

2 Vehicle-Enhanced 

Electronic HOS Record and CDL number 

of the operator. 

DSRC transceiver plus an integrated 

EOBR, and provisions for electronically 

identifying driver to vehicle. 

3 Driver-Basic 

Same as 3, but includes a Lane Departure 

Warning, or a Drowsy Driver System. 

Same as 3, but includes key performance 

and output information from a lane 

departure warning or drowsy driver 

system. 

4 Driver-Enhanced 

5 Vehicle- and 1 and 3 combined. 1 and 3 combined. Driver-Basic 

6 Vehicle- and 2 and 4 combined. 2 and 4 combined. Driver-Enhanced 

34 
To complete an overall evaluation of the above concepts, the following steps were undertaken: 

• Define a National Wireless Inspection Infrastructure that would be common to all of 

the proposed SDMS concepts: 

• Estimate the increased coverage implied by the hypothetical infrastructure, including 

additional vehicles that would be inspected and increased inspection frequency 

• Estimate the costs to implement such an infrastructure 

• Estimate costs for modifying the vehicle to collect the information implied by each 

concept 

• Evaluate institutional issues, including political, policy, and likely market acceptance 

differences among the concepts 

• Evaluate safety impacts, specifically, the impact on carrier and driver behavior relative 

to improving maintenance and operating practices, and estimate the reduction in 

commercial-vehicle-related crashes, fatalities, and injuries 

• Conduct Overall SDMS Alternative Evaluation and Selection by developing an 

overall cost-benefit analysis for the wireless inspection concepts, and select a mostfavored SDMS alternative option for moving forward 

4.1 DEFINE A NATIONAL WIRELESS INSPECTION INFRASTRUCTURE 

4.1.1 Hypothetical Wireless Network Footprint 

In this first step, selected concepts of operation identified in Task 3 were combined to create a 

hypothetical national deployment footprint of wireless inspection access points. Our goal was to 

develop an infrastructure with coverage such that vehicle inspections would occur with sufficient 

frequency to significantly change the behavior of carriers and drivers relative to safe vehicle 

maintenance and operating practices. 

Our interviews with the enforcement community, as well as stakeholder agencies such as CVSA 

and ATA, indicate that States would most likely want to mix and match venues and strategies for 

collecting wireless data (i.e., the concepts of operation from Task 3), so that a cost-effective 

inspection net would be created that would: 

• Reduce the ability of drivers and carriers to take bypass routes 

• Place inspection sites in appropriate locations to increase the number and type of trucks 

that are being inspected 

• Leverage the existing fixed inspection facilities 

• Allow mobile commercial vehicle patrol units to wirelessly inspect trucks to fill in the 

gaps of coverage and augment the fixed facilities 

To this end, the hypothetical implementation plan would be to establish an infrastructure that 

would deploy wireless inspection points at all of the current fixed inspection facilities and at 

numerous locations that would be somewhat closer to the centers of major metropolitan areas. 

These close-in inspection points would be virtual stations and would target that portion of the 

population that operates within 50 miles or less of their home base. A plan for supplementing 

35 
this deployment strategy with additional mobile inspection units would be developed. To 

evaluate the overall wireless inspection concept, the following deployment plan was established: 

• Twelve hundred fixed facility inspection sites would be located at all existing 

inspection/weigh stations and would be targeted at the current population of trucks that 

pass by these inspection points 

• One thousand virtual inspection stations would be located strategically in and around 

major metropolitan areas and would be focused on intra-city trucking operations as well 

as intrastate trucks 

• Five hundred mobile inspection vehicles would be targeted for inspecting vehicles that 

might regularly use bypass routes around the fixed and virtual stations 

Based on the described hypothetical deployment plan, the number of inspections completed 

annually would increase dramatically. If a wireless inspection capability was deployed only at 

current fixed inspection stations, at least as many truck inspections as the current number of 

trucks weighed (i.e., roughly 176 million each year) would be accomplished. It should be noted 

that trucks are weighed only during hours in which inspection stations, portable scales, and 

WIMs are open. When inspection facilities are closed, vehicles are allowed to bypass. A wireless 

inspection concept would facilitate inspection of vehicles at these 1,200 fixed facilities 24 hours 

a day, 7 days a week. Therefore, a figure of 176 million inspections is a very conservative 

estimate if electronic inspections could be performed and citations issued even when the station 

is unmanned. 

Strategically located virtual inspection stations would significantly increase the number of CMV 

inspections completed, since 65 percent of trucks operate within a 50-mile range of their home 

base or are straight trucks. Therefore, they rarely, if ever, receive a State safety inspection. It is 

possible to envision approximately 274 million inspections from the 1,000 virtual inspection 

stations).*

Currently, there are about 900 to 1,200 mobile inspection units in the United States. These 

inspection units perform approximately one million inspections annually. Since mobile wireless 

inspection units or appropriately equipped police vehicles could inspect trucks with considerably 

higher efficiency than a conventional mobile inspection, the 500 hypothetical mobile wireless 

inspection units would probably inspect at least as many trucks as the current one million mobile 

units. The higher efficiency would result from improved targeting of trucks and reduced time 

involved in completing the actual inspection, since the results of the electronic diagnosis would 

allow officers to pinpoint problem areas. 

Based on the hypothetical wireless inspection infrastructure outlined above, there could be an 

estimated 450 million electronic inspections performed annually on all vehicles that passed by a 

wireless inspection point (i.e., fixed, virtual, or mobile). This would result in an average 

frequency of inspections for the average commercial vehicle of every 1,000 miles (450 million 

inspections per 444,400 million commercial vehicle miles). Once again, many vehicles could be 

electronically inspected every day. 

 

*

176 million inspections per 1,200 fixed stations × 1,000/1,200 virtual stations × 65 percent/35 percent. 

36 
4.1.2 Wireless Infrastructure Cost Estimates 

Costs for implementing a wireless inspection concept would consist of: 

• Capital and operating costs for facilities and equipment 

– Fixed and virtual facilities 

– Mobile units 

• Capital and operating costs for IT and communications system enhancements 

– Federal-level enhancements 

– State-level enhancements 

4.1.2.1 Facility and Equipment Costs 

The cost of a wireless inspection station would likely be about the same, whether it were located 

at a current fixed-inspection facility or at a strategically located virtual inspection location. Costs 

for these various components can be estimated based on similar equipment listed in the 

Intelligent Transportation Systems (ITS) Benefits and Cost Database. Table 10 shows the 

breakdown of cost for these various components, adapted from the ITS Benefits and Cost 

Database. 

3 Table 10. Fixed and Virtual Inspection Station Estimated Cost per Station

O&M Cost Fixed/Virtual Inspection Station Capital Cost per Year 

Infrastructure Modifications (radio mounting fixture) $10K–$15K $1K–$1.5K 

Short-Range Wireless Transceiver Radio $2K–$5K $0.2K–$0.5K 

Communications Infrastructure $10K–$20K $0.5K–$1K 

WIM Scale $14K–$21K $1.4K–$2.1K 

Optical Automatic Vehicle Identification $10K–$15K $1K–$1.5K 

Total $46K–$76K $4.1K–$6.6K 

A mobile inspection system, integrated with a patrol car or a portable trailer, would probably 

include a portable computer with printer and a short-range wireless transceiver radio, and would 

require a wireless telecommunications connection to download, record, and upload carrier, 

vehicle, and driver safety database records at field locations. It would also include portable scales 

or a portable WIM to measure vehicle and axle load. 

 

3

 Cost estimate data adapted from the U.S. Department of Transportation, Intelligent Transportation Systems 

Benefits, Costs Database, ITS Joint Program Office, http://www.benefitcost.its.dot.gov/ 

37 
Table 11 shows the breakdown of cost for a mobile inspection unit adapted from the ITS 

Benefits and Cost Database. 

4 Table 11. Mobile Inspection Unit Estimated Cost per Unit

Mobile Inspection Unit Capital Cost O&M Cost 

Enforcement Vehicle or Trailer System $7.5K–$9.2K $0.44K–$0.66K 

Portable Scales or Portable WIM $4K–$8K $0.4K–$0.8K 

Total $11.5K–$17.2K $0.84K–$1.46K 

Therefore, the total cost to build out and maintain the facilities and equipment for a wireless 

inspection network is shown in Table 12. 

Table 12. Total Hypothetical Wireless Facilities and Equipment Costs 

Hypothetical Wireless Stations/Units Capital Cost O&M Cost Inspection Infrastructure 

Fixed Inspection Sites 1,200 $55M–$91M $4.9M–$7.9M 

Virtual Inspection Sites 1,000 $46M–$76M $4.1M–$6.6M 

Mobile Units 500 $5.8M–$8.6M $0.4M–$0.7M 

Total 1,700 $106M–$176M $9.4M–$15.2M 

4.1.2.2 IT and Communications System Enhancements 

Additional costs will be required to implement major modifications to back-office hardware and 

information system infrastructure to handle the inspection data and to perform enforcement of 

inspection violations. These costs will likely be divided among Federal agencies and States. 

There will also likely be an initial capital cost to make these improvements, along with the 

annual increase in operating and maintenance costs. 

For instance, at a Federal level, even if the raw inspection data is not retained or included as part 

of MCMIS, it will still be necessary to expand the MCMIS database to handle summary data for 

the significant increase in inspections performed (i.e., from 3 million to approximately 452 

million). A significant capital expenditure will be needed to upgrade the FMCSA’s Federal IT 

systems, possibly as an add-on or enhancement to the current COMPASS program. As the 

COMPASS program progresses, provisions would have to be made for the handling, storing, and 

mining of wireless inspections (even summary data), as well as changes to the ISS algorithms 

based on real-time wireless inspection data. A nationwide database will be needed to maintain 

records of CDL and vehicle registrations status by coordinating with State agencies. A very 

rough preliminary estimate for capital costs necessary for upgrading and expanding the 

COMPASS program is between $10 million and $15 million. An annual increase in IT operating 

 

4

 Cost estimate data adapted from the U.S. Department of Transportation, Intelligent Transportation Systems 

Benefits, Costs Database, ITS Joint Program Office, http://www.benefitcost.its.dot.gov/ 

38 
costs of between $1 million and $2 million has also been allowed for in order to analyze and 

maintain the expanded data set. 

States will also need to make significant improvements in both their roadside enforcement IT 

applications as well as back-office CMV IT support systems. New information systems for 

linking VIN, USDOT number, CDL number, and license plate numbers will have to be 

developed and implemented. Enhancements to CDL administration, SAFETYNET support, and 

other licensing, insurance, and tax systems will also likely need upgrading and expansion in 

order to fully leverage the benefits of the wireless inspection concept. Additional coordination 

and integration of these systems will be required, as well as refined levying and processing 

systems, if an automated enforcement strategy is adopted, similar to IT and data-processing 

systems that support red-light-running cameras and automated speed enforcement. It is possible 

that these improvements and coordination would be facilitated through the CVISN program as a 

means to standardize systems across both the State and Federal levels. A significant initial 

capital expenditure would be required for improvements in each State’s IT systems, perhaps 

between $2 million and $3 million per State ($100 million to $150 million total). Additionally, 

there would be increased annual IT system operating and maintenance costs for States, which is 

estimated at $250,000 to $500,000 per State ($12.5 million to $25 million total). 

Table 13 summarizes the estimated capital and annual O&M (operation and maintenance) costs 

for IT system enhancements for both the Federal Government and the States. 

Table 13. Information Technology Enhancement Costs 

O&M Cost IT Enhancement Costs Capital Cost per year 

Federal Level (COMPASS) $10M–$15M $1M–$2M 

State Level (CVISN) $100M–$150M $12.5M–$25M 

Total $110M–$165M $13.5M–$27M 

4.1.2.3 Total Infrastructure Costs 

The total costs for establishing a CMV wireless inspection infrastructure are estimated at 

between $216 million and $341 million, while increased operating costs are between $23 million 

and $42 million, as shown in Table 14. 

Table 14. Total Wireless Inspection Infrastructure Costs 

O&M Cost Infrastructure Cost Capital Cost per year 

Total Facilities and Equipment $106M–$176M $9.4M–$15.2M 

Total IT and Communication Systems $110M–$165M $13.5M–$27M 

Total $216M–$341M $22.9M–$42.2M 

39 
4.2 VEHICLE MODIFICATION COSTS FOR EACH ALTERNATIVE 

4.2.1 Vehicle Costs: Alternative 1—“Vehicle Basic” 

A wireless inspection module that records only basic vehicle-related information would probably 

be similar to current in-cab ECUs, and would interface primarily with the J1939 and J1587 

networks. This fundamental vehicle inspection module would record the minimum vehicle-only 

SDMS, including: 

• Vehicle identification information 

• Standard fault codes 

To implement this concept, an approach similar to that adopted by the EPA for standardizing 

emission system fault codes could be taken. Essentially, the EPA and CARB focus on 

developing performance-based reporting standards for emissions-related components, and then 

place the burden on manufacturers to determine what faults to report and under what conditions. 

For example, if a particular component (such as an oxygen sensor) is out of calibration to such an 

extent that it degrades emission performance beyond a regulatory limit, then the manufacturer is 

required to determine the point at which an out-of-calibration condition becomes significant, and 

to report it as a fault. The USDOT could implement a similar strategy for safety-related systems. 

While the strategy is simple in concept, it should be recognized that substantial technical 

development work and testing would be required to implement safety system fault code 

guidelines and to link them with pass/fail inspection criteria. 

It is estimated that basic vehicle-only wireless inspection module could be manufactured, 

integrated in the vehicle, and sold to fleets in new vehicles for between $273 and $485. 

Table 15 shows a breakdown of this cost. 

Table 15. Incremental Vehicle Cost: “Vehicle Basic” 

Inspection Module Cost 

Data Recorder Per-Unit Hardware Cost $125–$175 

Short-Range Wireless Radio Per-Unit Cost $30–$40 

Total Per-Unit Cost (including amortized tooling and software development costs) $160–$223 

OEM Vehicle Integration Costs Per Vehicle $50–$150 

Cost to Fleets (per vehicle) $273–$485 

4.2.2 Vehicle Costs: Alternative 2—“Vehicle Enhanced” 

An enhanced vehicle-only inspection module would be similar to the basic vehicle-only module 

except that it would include additional sensors or systems for tire-pressure monitoring and for 

measuring brake performance. An enhanced vehicle-only inspection module would record an 

extensive SDMS, including: 

• Vehicle identification information 

• Fault codes and warnings 

40 
• Lighting faults 

• Tire pressure status 

• Brake performance and/or adjustment (e.g., wheel speed sensors, stroke sensors, 

instrumented anchor pins) 

An enhanced vehicle-only wireless inspection module could be manufactured, integrated into the 

vehicle, and sold to fleets in new vehicles for between $1,378 and $4,320, including the 

advanced sensor systems. Table 16 shows a breakdown of this cost. 

Table 16. Incremental Vehicle Cost: “Vehicle Enhanced” 

Inspection Module Cost 

Data Recorder Per-Unit Hardware Cost $125–$175 

Short-Range Wireless Radio Per-Unit Cost $30–$40 

Brake Performance/Adjustment System $250–$1,500 

Tire Pressure Monitoring System $500–$1,200 

Total Per-Unit Cost (including amortized tooling and software development costs) $910–$2,923 

OEM Vehicle Integration Costs Per Vehicle $150–$400 

Cost to Fleets (assuming 30-percent markup) $1,378–$4,320 

4.2.3 Vehicle Costs: Alternative 3—“Driver Basic” 

Alternative 3 would record a fundamental driver-centric SDMS which would include: 

• Vehicle identification information (VIN) 

• Driver identification information (principally, the operator’s CDL number) 

• HOS logs with GPS locations 

Adding the capability to record a driver’s HOS logs is highly variable in complexity and cost. 

Currently, FMCSA is researching the use of EOBRs for electronically capturing HOS logs. 

These EOBRs could take many forms. They could be a stand-alone module, a functionality built 

into the device/system from a commercial telematic company, or a portable device such as a 

PDA or cellular-phone-based design. Therefore, it is likely that a wireless inspection module 

designed to record driver identification and HOS logs could take one of two forms: 

1. The inspection module could interface directly with a stand-alone EOBR and pull the log 

records and driver identification information from this unit. 

2. The wireless inspection module could be integral with the EOBR functionality and could 

maintain the logbook itself, making it a single wireless inspection module with a dual 

function capability. 

41 
It is unclear which approach the industry might adopt, as EOBR regulations have not yet been 

published. The timeline, industry acceptance, EOBR design form (i.e., integrated with the 

vehicle or in a PDA), technical design synergies between the two devices, and cost will affect the 

approach finally adopted. 

The two approaches vary significantly in cost, and will impact design of the wireless inspection 

module. If the EOBR as a stand-alone unit is chosen, then relative cost increases to the wireless 

inspection module would be minimal, and only an interface between the EOBR and the 

inspection module would be necessary. If integration of the EOBR functionality with the 

wireless inspection module is chosen, that could have a significant cost impact. The module 

would have to include capabilities to directly record information from a driver’s license using bar 

code, magnetic strip, or RFID technology as described earlier; a GPS receiver to record location 

and time data in the log; and a screen or other interface with the driver to review his or her logs. 

It is estimated that a basic driver-centric wireless inspection module could be manufactured, 

integrated in the vehicle, and sold to fleets in new vehicles for between $468 and $875. Table 17

shows a breakdown of this cost. It should be understood that these cost estimates are based on an 

assumption of large-scale deployment and the associated economies of scale for electronic 

devices. 

Table 17. Incremental Vehicle Cost: “Driver Basic” 

Inspection Module Cost 

Data Recorder Per-Unit Hardware Cost $125–$175 

Short-Range Wireless Radio Per-Unit Cost $30–$40 

Hours-of-Service Recording Capability Per-Unit Cost (integrated EOBR) $50–$150 

GPS Receiver Cost (integrated EOBR) $50–$100 

Total Per-Unit Cost (including amortized tooling and software development costs) $260–$473 

OEM Vehicle Integration Costs Per Vehicle $100–$200 

Cost to Fleets (assuming 30-percent markup) $468–$875 

4.2.4 Vehicle Costs: Alternative 4—“Driver Enhanced” 

An enhanced driver inspection module would be similar to the basic driver module in that it 

would record VIN, driver identification information (CDL), and HOS logs, but it would also 

include capabilities to directly measure and record driver performance and fatigue. There are 

several commercially available technologies that can detect drowsy, distracted, or fatigued 

drivers. 

Most use one of three monitoring methods: 

• Lane position 

• Driver eye 

• Steering wheel position 

42 
Lane departure warning systems (LDWS) use video cameras and digital video processing to 

determine the location of the vehicle relative to the lane. In some systems, this data is 

supplemented by forward-looking radar. The digital video-processing tracks road features such 

as lane markings to determine the relative location of the truck. It then provides audible and/or 

visual alert indicators when the vehicle begins to drift out of the lane. Monitoring of lane 

position to detect weaving and erratic steering behavior can provide an indication of driver 

fatigue or inattention. Since these are video-based systems, they often have difficulty tracking 

during adverse conditions (e.g., white-out snowstorm, heavy and/or nighttime rain, or glare). 

Several companies offer LDWS. 

Monitoring the behavior of a driver’s eye and eyelid is another method for drowsy-driver 

detection. A metric of drowsiness that has gained popularity, particularly with NHTSA, is 

PERCLOS, the percentage of eyelid closure over the pupil in a given period of time, reflecting 

slow eyelid closures rather than blinks. However, accurately measuring PERCLOS in a vehicle 

during operation has proven difficult. Typically, PERCLOS systems use small cameras and an 

infrared illumination source to pick up and discern a driver’s eye. Daytime sunlight can cause the 

infrared camera signal to become washed-out or less clear. These systems operate best at night. 

Additionally, drivers’ glasses and sunglasses can cause interference. The technology is still in 

development, and NHTSA is conducting research to determine the accuracy of the system. 

A third type of driver performance measurement technology currently under development is 

based on monitoring steering wheel inputs. With this approach, empirically developed 

algorithms are used to analyze driver steering adjustments and to determine if there is too much 

or too little input/correction given the specific operating conditions. This type of technology is 

also still under development. 

While each of these monitoring systems shows promise, extensive research, testing, and 

consensus- building efforts would be needed to develop standardized criteria for driver fatigue. 

Also, the incremental cost associated with adding such capability has yet to be established. 

However, current LDWS designed for CMVs sell for between $1,000 and $1,500. This figure 

was used as an estimate for this analysis. 

It is estimated that an enhanced driver-only wireless inspection module could be manufactured, 

integrated in the vehicle, and sold to fleets in new vehicles for between $1,573 and $3,085. 

Table 18 shows a breakdown of this cost. 

43 
Table 18. Incremental Vehicle Cost: “Driver Enhanced” 

Inspection Module Cost 

Data Recorder Per-Unit Hardware Cost $125–$175 

Short-Range Wireless Radio Per-Unit Cost $30–$40 

Hours-of-Service Recording Capability Per-Unit Cost $50–$150 

GPS Receiver Cost $50–$100 

Onboard Drowsy Driver-Monitoring Device (i.e., LDWS) $800–$1,500 

Total Per-Unit Cost (including amortized tooling and software development costs) $1,060–$1,973 

OEM Vehicle Integration Costs Per Vehicle $150–$400 

Cost to Fleets (assuming 30-percent markup) $1,573–$3,085 

4.2.5 Vehicle Costs: Alternative 5—“Vehicle and Driver Basic” 

A combined basic vehicle-plus-driver inspection module would be the combination of 

Alternatives 1 and 3. This alternative would record the following parameters: 

• Vehicle identification information (VIN) 

• Driver identification information (CDL number) 

• HOS logs with GPS locations 

• Currently available vehicle fault codes 

A basic vehicle-plus-driver wireless inspection module (i.e., a combination of Alternatives 1 and 

3) could be manufactured, integrated in the vehicle, and sold to fleets in new vehicles for $533 to 

$940. Table 19 shows a breakdown of this cost. 

Table 19. Incremental Vehicle Cost: “Vehicle and Driver Basic” 

Inspection Module Cost 

Data Recorder Per-Unit Hardware Cost $125–$175 

Short-Range Wireless Radio Per-Unit Cost $30–$40 

Hours-of-Service Recording Capability Per-Unit Cost $50–$150 

GPS Receiver Cost $50–$100 

Total Per-Unit Cost (including amortized tooling and software development costs) $260–$473 

OEM Vehicle Integration Costs Per Vehicle $150–$250 

Cost to Fleets (assuming 30-percent markup) $533–$940 

44 
4.2.6 Vehicle Costs: Alternative 6—“Vehicle and Driver Enhanced” 

An enhanced vehicle and driver inspection module would be the combination of Alternatives 2 

and 4, and would be the most extensive wireless inspection module. This alternative would 

record monitoring and record the following parameters: 

• Vehicle identification information (VIN) 

• Driver identification information (CDL number) 

• HOS logs with GPS locations 

• Currently available vehicle fault Codes (such as braking, electrical, powertrain, and/or 

lighting system faults) 

• Tire pressures 

• Brake adjustment and performance using dedicated sensors (i.e., stroke sensors) 

• Driver performance and fatigue via LDWS 

It is estimated that an enhanced vehicle and driver wireless inspection module (i.e., a 

combination of Alternatives 2 and 4) could be manufactured, integrated in the vehicle, and sold 

to fleets in new vehicles for $3,783 to $6,595. Table 20 shows a breakdown of this cost. 

Table 20. Incremental Vehicle Cost: “Vehicle and Driver Enhanced” 

Inspection Module Cost 

Data Recorder Per-Unit Hardware Cost $125–$175 

Short-Range Wireless Radio Per-Unit Cost $30–$40 

Hours-of-Service Recording Capability Per-Unit Cost $50–$150 

GPS Receiver Cost $50–$100 

Brake Adjustment and Defect Sensing System (i.e., MGM E-Stroke) $1,000–$1,500 

Tire Pressure Monitoring System $500–$1,200 

Onboard Drowsy Driver Monitoring Device (i.e., LDWS) $1,000–$1,500 

Total Per-Unit Cost (including amortized tooling and software development costs) $2,760–$4,673 

OEM Vehicle Integration Costs Per Vehicle $150–$400 

Cost to Fleets (assuming 30-percent markup) $3,783–$6,595 

4.2.7 Summary of Vehicle Cost Impacts for Each Concept Alternative 

The low- and high-incremental vehicle cost estimates for each alternative are summarized in 

Table 21. These incremental cost estimates are for new vehicles that have been designed to 

support the data monitoring and wireless downloading capabilities required for each of the 

concepts. Further, the costs assume high-volume economies of scale with all new vehicles being 

equipped on an industry-wide basis. 

45 
Table 21. Summary of Incremental Vehicle Costs for Each SMDS Alternative Concept 

 1 2 3 4 5 6 

Total Cost 

per Unit 

Vehicle 

Basic 

Vehicle 

Enhanced 

Driver 

Basic 

Driver 

Enhanced 

Vehicle and Vehicle and 

Driver Basic Driver 

Enhanced 

Low $237 $1,378 $468 $1,573 $533 $3,783 

High $485 $4,320 $876 $3,085 $940 $6,595 

Average $361 $2,849 $672 $2,329 $737 $5,189 

4.2.8 Vehicle Costs: Non-Cooperative (Baseline) Alternative 

In addition to the six cooperative wireless concepts previously described, one of the concepts 

outlined in Section 3 involves a non-cooperative approach that relies only on advanced 

infrastructure-based sensors. In summary, this concept would include: 

• A WIM to measure vehicle and axle weights 

• An AVI system using optical recognition of license plate and USDOT numbers 

• An infrared brake sensor to detect significantly misadjusted or defective brakes 

• Other advanced technologies, such as an acoustic sensor for detecting suspension or 

exhaust problems, optical or acoustic sensors for detecting tire inflation, or an electronic 

sniffer sensor for detecting hazardous chemical leaks or radiation 

This concept of operations is not groundbreaking, since some States have already been 

researching and installing these technologies to screen vehicles more efficiently. It is likely that 

as these technologies mature, and as the enforcement community becomes comfortable with 

them, more States will implement them. Therefore, this alternative can be considered a baseline 

concept. Some of these non-cooperative technologies may eventually become more prevalent if a 

wireless inspection program does not move forward. Table 22 shows a breakdown of component 

costs, although costs were not yet available for some components that are in early stages of 

development. 

Table 22. Non-Cooperative Alternative Cost Estimate 

O&M Cost Fixed/Virtual Inspection Station Capital Cost per Year 

Infrastructure Modifications (mounting fixtures) $20K–$35K $2K–$3.5K 

Communications Infrastructure $10K–$20K $0.5K–$1K 

Weigh-In-Motion Scale $14K–$21K $1.4K–$2.1K 

Optical Automatic Vehicle Identification $10K–$15K $1K–$1.5K 

Infrared Brake Sensing Technology Not Available Not Available 

Acoustic Sensors for Exhaust, Suspension, and/or Tire Failures Not Available Not Available 

Sniffer Sensors for Hazardous Gas and Radiation Detection Not Available Not Available 

46 
4.3 INSTITUTIONAL AND DEPLOYMENT ISSUES FOR ALTERNATIVE 

WIRELESS INSPECTION CONCEPTS 

All six of the wireless inspection alternatives described herein (“vehicle basic,” “driver basic,” 

“vehicle enhanced,” “driver enhanced,” “vehicle and driver basic,” and “vehicle and driver 

enhanced”) are technologically feasible using readily available components, sensors, and 

communications technology. The costs of implementation, safety benefits, and institutional 

issues, however, will differentiate the alternatives. Institutional issues include policy, political, 

and market acceptance. These institutional and deployment barriers are often the most important 

considerations to be addressed before moving forward. 

In general, all six of the SDMS alternatives will face similar challenges relative to institutional 

deployment issues. Some types of direct or indirect Federal Government initiative (e.g., 

regulations, standards development, public-private partnerships, and/or funding support of 

programs such as CVISN) will be needed to spur widespread adoption by the industry. All of 

these options focus on wirelessly extracting information that could be used for issuing violations 

and/or impacting Safety Evaluation Area (SEA) scores. They could even be used for litigation 

purposes, should a vehicle become involved in a crash just after undergoing a wireless 

inspection. To this extent, fleets will not be voluntarily supportive unless operational and 

economic benefits can be demonstrated. Existing electronic pre-screening programs already 

allow CMVs to bypass inspection stations in many States, thus undercutting this potential benefit 

of wireless inspections. In other words, the de facto standard of information needed to allow a 

truck to bypass a station has been established as the simple transmission of the carrier’s USDOT 

number. If bypassing inspection stations is to be used as the carrot for fleets to adopt wireless 

inspection technology, then limitations inherent in current pre-screening programs will need to 

be highlighted. States will need to be encouraged to require more real-time information to be 

transmitted before allowing a vehicle to bypass the inspection station. 

Given the above understanding, there are still some differences in the institutional and market 

acceptance challenges that the SDMS alternatives would have to overcome. 

4.3.1 Institutional Challenges for Extracting Vehicle-Based Data 

Those alternatives that would extract only vehicle-based information (Alternatives 1 and 2) 

would probably face fewer challenges in the marketplace. Alternative 1 (“vehicle basic”) focuses 

on extracting only information that is already available on the J1939 network. To this extent, the 

SDMS associated with this alternative would make available the same type of information that 

could be collected by conventional diagnostic tools if the vehicle were stationary. It is envisioned 

that the message set would also include the VIN, since this information is readily available on 

the vehicle databus. It could be argued that the SDMS for Alternative 1 would simply allow the 

enforcement agency to determine more conveniently whether or not there are major faults 

present on the vehicle. It would also allow the enforcement agency to more conveniently and 

positively identify the vehicle (using the VIN). Conceptually, gathering such information is no 

different than identifying the vehicle using optical character recognition of the license plate 

and/or USDOT number (a practice which is already common and accepted by the marketplace).

The SDMS associated with Alternative 2 (“vehicle enhanced”), on the other hand, would be 

more difficult to implement from a technical and policy perspective. As reviewed earlier, 

standard methods, performance metrics, and failure criteria have not been established for tire47 
pressure monitoring and/or brake diagnostic systems. It may be possible to establish such metrics 

based on current measurement and failure criteria associated with a Level 1 inspection. However, 

it is possible, because of the manner in which the diagnostic technologies may be implemented, 

that one-for-one use of existing failure criteria would not be applicable, and that new criteria 

would need to be developed. For example, violations are currently issued for individual brake 

assemblies that are too far out of adjustment. While automated stroke measurement systems 

exist, other systems that rely more directly on braking force (or even monitoring of wheel 

speeds) may produce even better diagnostics than stroke sensors, although no standard criteria or 

measurements criteria yet exist. Even if brake-stroke sensing systems were made standard, the 

details of how such a system would work, the accuracy requirements, and the reporting 

requirements would still need to be worked out. While automated diagnostic systems for brakes 

and tires are available and reliable, the process of agreeing on standards for issuing violations 

using these new systems would be challenging. Given the challenges FMCSA is already facing 

concerning use of PBBTs for determining brake system compliance, standards based on even 

newer technologies would be quite challenging. 

4.3.2 Institutional Challenges for Extracting Driver-Based Data 

The information to be gathered under Alternatives 3–6 includes gathering driver-related data, 

which by definition will be more institutionally difficult since personal privacy issues will arise. 

However, Alternative 3 (“driver basic”) and Alternative 5 (“vehicle and driver basic”) focus only 

on gathering driver data that would already be available to a roadside inspector—specifically, the 

operator’s CDL number and his/her HOS logbook information. It could be argued that gathering 

such information wirelessly is simply a more convenient and accurate means of performing this 

function. While there are no doubt substantial institutional and policy challenges associated with 

gathering even basic driver information wirelessly, the fact that such information is already 

regularly requested by enforcement agencies, and routinely given by fleet operators, suggests 

that such challenges can be met. In many respects, gathering HOS data wirelessly is simply a 

technical extension of EOBR regulatory actions that are under consideration. (EOBRs are 

already making available the electronic HOS data that would become part of the SDMS, so the 

only added twist is that with Alternatives 3 and 5, such information would be extracted more 

conveniently through wireless communications technology.) 

Alternatives 4 (“driver enhanced”) and 6 (“vehicle and driver enhanced”) both call for the 

addition of equipment that would directly monitor driver performance. As reviewed earlier, such 

equipment may include lane departure warning and/or drowsy-driver monitoring systems. There 

will be major deployment challenges on two levels for including the output of such systems in an 

SDMS. The first involves standardizing functional requirements and performance metrics, and 

developing violation criteria for these types of comparatively new driver monitoring systems. 

There would need to be large, sustained research programs and field tests before Government 

and industry could arrive at some consensus on the output format from such systems, the 

accuracy and reliability requirements, and most important, the measurement levels that would 

lead to various type of violations. These challenges are similar to those of the advanced vehicle 

monitoring systems described for SDMS Alternative 2, although the challenges are even more 

severe since the systems involve monitoring drivers to determine whether they are performing 

acceptably, rather than monitoring a comparatively simple mechanical system (such as brakes 

and tires). 

48 
Alternatives 4 and 6 would also face major institutional, policy, and political challenges related 

to concerns over operator privacy, use of the data for tort litigation, and general industry and 

driver acceptance. The institutional challenges overlap with the technical challenges (i.e., the 

lack of standardization) described above. Fleets and drivers would have major concerns that the 

output of these driver-monitoring systems could be used against them—not necessarily for 

issuing violations or fines, but rather for lawsuits against them in crash cases. Interviews 

conducted with fleets and fleet associations suggest that their real concern is not that the systems 

may result in increased fines, or may highlight poor operator performance (fleet managers and 

Government are on the same side of this issue), but that the systems will be collecting data that 

may get misinterpreted by courts and may substantially increase their liability. The trucking 

industry would be concerned that similar information would not be available from the passenger 

cars involved in the accident. As an operations manager at a large TL fleet stated, “We will 

collect and report such data as soon as the same information is available about the passenger car 

driver. Otherwise, we are at a disadvantage.” 

Driver-monitoring systems (particularly collision warning, rollover, and LDWS) are enjoying a 

moderate degree of success in the marketplace because they are being positioned as driver aids, 

and the output data is generally not being recorded by most fleets. Indeed, one manufacturer of 

LDWS recently removed such recording features from its product in order to improve customer 

acceptance. A program to standardize the output of such devices among all manufacturers, 

record the information, and then permit State enforcement agencies to wirelessly access the 

information at any time or location would face major opposition. 

Based on the Research Team’s interviews with industry stakeholders, and a review of relevant 

research in this area, a summary of how the six SDMS alternatives rank relative to institutional 

issues is shown in Table 23. 

Table 23. Institutional and Deployment Challenges for SDMS Alternatives 

SDMS Alternative Data Collected Ranking 

1) Vehicle Basic Readily available fault code data 3 

2) Vehicle Enhanced As above + brake, tire, and lighting system data 1 

3) Driver Basic CDL number + HOS logbook data 2 

4) Driver Enhanced As above + driver performance measurements 1 

5) Vehicle + Driver Basic 1 + 3 2 

6) Vehicle + Driver Enhanced 2 + 4 0 

Baseline / Non-Cooperative External Roadside Sensors Only 4 

Key to Rankings: 4 = Little/No Institutional and Deployment Challenges 

1 = Severe Institutional and Deployment Challenges

49 
4.4 SAFETY BENEFITS OF WIRELESS INSPECTION CONCEPTS 

Safety benefits from implementing the various alternative concepts are based on the premise that 

a substantial increase in inspection frequency, together with the specific information collected 

under each alternative, would result in changing fleet and driver behavior. Specifically, frequent 

wireless inspections of vehicle-based systems (e.g., tires, brakes, lights) would hypothetically 

result in discovery and assessment of violations that would otherwise go undetected. This 

enforcement activity would impact carrier SEA scores, thus increasing the carrier’s cost of doing 

business through increased fines, increased insurance, and reduced competitiveness and 

attractiveness to shippers (for for-hire carriers). Fleets and carriers would therefore act in a 

variety of ways to improve their vehicle maintenance practices, including retaining more and 

better mechanics, investing in more and more advanced diagnostic equipment, implementing 

improved in-house vehicle inspection and quality control programs, and working with drivers to 

enhance pre-trip inspections. 

Similarly, if the operator’s daily log were accessed and analyzed wirelessly on virtually every 

significant trip taken (as it would be, based on the wireless inspection infrastructure described in 

earlier sections), then enforcement agencies would immediately know of violations of HOS and 

the fleet operator/driver would be caught. Aside from the possibility of tampering with the 

EOBR and integrated wireless equipment, it could be argued that abuse or disregard of HOS 

rules would be nearly eliminated and compliance levels would in the long run likely approach 

95–100 percent, as the nation’s fleets transitioned to wireless inspection technology. Essentially, 

a wireless commercial vehicle inspection program would bring about a dramatic reduction in 

violation levels for those systems and operations that were being monitored. 

If wireless inspection technology were mandated for new vehicles beginning in a given year, the 

large majority of in-use vehicles would be equipped within less than 10 years, as the turnover 

rate for heavy trucks is quite high, with many large carriers turning vehicles over every 4–5 

years. To evaluate the safety benefits of the SDMS alternatives, full market penetration is 

assumed. That is, the analysis represents the long-term benefits accruing if a wireless inspection 

program were implemented. With this background, safety benefits for each of the SDMS 

alternatives are examined in the following sections. 

4.4.1 Safety Benefits: Alternative 1—Vehicle Basic 

Under SDMS Alternative 1, vehicle diagnostic data to be downloaded would be limited to fault 

code data on major subsystems such as brakes, engine, transmission, and lighting systems. The 

impact of Alternative 1 would be to nearly eliminate cases in which a truck is being driven with a 

significant defect in any of these systems. Operators would know that if a dash light (or message) 

were being presented to them showing a malfunction in the brakes, lights, engine, or 

transmission, this same fault information would be transmitted to the local enforcement agency, 

and that their vehicle would most likely be targeted for a more complete inspection. 

To accomplish this, it would be necessary to develop a complete regulatory approach. For 

example, enforcement strategies might call for initially issuing warnings for vehicle defects and 

then allowing fleets a specified amount of time to make repairs. If the repairs were not made, or 

multiple warnings were given, then fines might be assessed. Essentially, Alternative 1 would 

strongly encourage fleets and drivers to investigate and repair malfunctions of major vehicle 

safety systems. 

50 
Overall, it is likely that this alternative would have only a marginal impact on safety. First, our 

interviews with fleets indicated that drivers and fleets already act fairly quickly when a “check 

engine” or similar message is illuminated and presented to the driver. Second, crash data shows 

that comparatively few crashes are directly caused by vehicle mechanical problems. 

Given the type of diagnostic data that would be efficiently monitored under Alternative 1, the 

degree to which fleets and operators would be motivated to improve their overall vehicle 

maintenance practices is unclear. Although, under this particular alternative, detailed diagnostic 

information would not be available to the enforcement agencies on many systems (e.g., tires, 

suspension, steering, load securement, etc.), there still may be a “halo” effect from monitoring 

the vehicle’s databus for general system diagnostic information. The electronic systems on 

commercial trucks are sufficiently complex that many fleets are simply not sure exactly what can 

and cannot be reported on the vehicle’s network databus. Therefore, even though under 

Alternative 1, direct monitoring of tire, suspension, or steering system performance may not be 

included, fleets may still improve maintenance in these areas. Some fleets may choose to 

improve their maintenance and vehicle inspection programs in all areas simply to ensure that 

their vehicles are not targeted for inspection. The uncertainty and complexity of onboard 

diagnostic systems would, in effect, work in the enforcement community’s favor. 

For this analysis, it was assumed that such monitoring would reduce by 10 percent the number of 

crashes in which vehicle-related defects of safety systems were cited as the critical reason. This 

is a conservative estimate, since in many instances major vehicle defects that directly lead to 

crashes should identifiable through fault code information, with the vehicle being taken promptly 

out of service. For example, if a vehicle had a major failure of the ABS, that would be detected 

through self-diagnostics and reported to the local enforcement agency as soon as the vehicle 

passed an inspection point. The vehicle would not be permitted to operate very long before it was 

targeted for detailed inspection and removed from service. 

Further, there would clearly be some reduction in the number and/or severity of crashes where 

the critical reason for the crash was driver error, but where vehicle defects were nevertheless a 

contributing factor. The report’s analysis of safety benefits did not take this into account. 

4.4.2 Safety Benefits: Alternative 2—Vehicle Enhanced 

Under this alternative, more detailed performance monitoring and reporting of brake, tire, and 

lighting system performance would be included as part of the message set, along with the same 

type of fault code information described in Alternative 1. 

An analysis of roadside inspection data supported the LTCCS and showed that there is an 

important link between vehicle defects and crashes. Table 24 shows the result of roadside 

inspections for all inspections completed in the U.S. in 2004 (3 million inspections in total), as 

well as for a subset of these inspections completed on commercial vehicles that were actually 

involved in crashes (a total of 16,500 such inspections). The post-accident inspection data was 

screened to eliminate any violations that might have resulted from the accident itself (such as 

broken lights, load securement problems, etc.). 

Table 24 shows that the number of OOS violations issued per inspection was three times as high 

for trucks involved in crashes as for trucks in general. Further, as a percentage of total 

inspections completed, brake-related OOS violations represented about 11 percent for all trucks, 

but about 30 percent for trucks involved in crashes. Tire-related problems (OOS violations) were 

51 
also about three to four times more likely to occur on trucks involved in crashes as on trucks in 

general. Of interest is the fact that lighting-system OOS violations rates were similar between the 

two sample populations (all inspections versus post-accident inspections), and the LTCCS also 

showed that there were essentially no crashes in which the critical reason was given as a failed 

lighting system. 

Available diagnostic technologies and methods for monitoring brakes and tires are quite 

comprehensive and, when combined with basic fault code information, they would likely be able 

to detect a majority of significant vehicle defects. Proceeding from this assumption, and 

recognizing that each commercial vehicle would probably be wirelessly inspected on almost 

every trip made, it would be highly unusual for a CMV to operate on the public roadways for any 

significant length of time without being detected by the local enforcement agency and 

appropriate actions being taken, including issuance of warnings, violations, and fines, as well as 

targeting the vehicle for more detailed Level 1 inspections. In the long run, it is likely that OOS 

violations related to brakes, tires, and lighting systems would be dramatically reduced (in much 

the same way that overweight violations have been dramatically reduced because of the high 

level of inspections and enforcement activity). It could be argued that once all vehicles were 

equipped with the type of technology envisioned by this alternative, crashes that have 

traditionally been directly caused by brake, tire, and lighting problems would be significantly 

reduced. For this analysis, and to take a conservative approach, it was assumed that 50 percent of 

all cases in which brake, tire, and/or lighting system failures were the critical reason for a crash 

would be eliminated. 

4.4.3 Safety Benefits: Alternative 3—Driver Basic 

Under this alternative, the operator’s CDL number and electronic HOS log would be included in 

the SDMS. Because of the very high frequency of wireless inspections to be completed, fleets 

and operators would be highly motivated to fully abide by all HOS rules. It can be argued that 

abuse or disregard of HOS rules would be nearly eliminated, since violators would know they 

would be instantly caught. (It should be recognized that tampering and message falsification 

issues will no doubt exist, but should have little overall impact—particularly if severe 

enforcement actions are in place for operators caught tampering with the wireless inspection 

systems.) Compliance levels would, in the long run, probably approach 95—100 percent as the 

nation’s fleets transitioned to wireless inspection technology. 

To calculate safety benefits, the relationship of HOS violations to fatigue—and ultimately to 

crashes—must be established. The post-accident inspection data shown in Table 24 again 

provides some insight. Specifically, the analysis showed that OOS logbook violations are about 

twice as likely to be present for drivers involved in crashes as for the commercial vehicle driver 

population in general. 

52 
53 

Table 24. Commercial Vehicle Roadside Inspection Violations—CY 2004 

[All Inspections (ALL-Insp) = 3 million; Post-Accident Inspections (PA-Insp) = 16,500]

INSPECTION VIOLATION 

CATEGORY DESCRIPTION 

ALL-Insp:

Count of 

OOS 

ALL-Insp:

All 

Violations 

divided 

by Total 

Insp 

ALL-Insp:

OOS 

Violations 

divided 

by Total 

Insp 

PA-Insp: 

Count of 

OOS 

PA-Insp: 

All 

Violations 

divided 

by Total 

Insp 

PA-Insp: 

OOS 

Violations 

divided 

by Total 

Insp 

Medical Certificate 484 5.90% 0.02% 12 7.93% 0.07%

False Log Book 25,464 1.30% 0.8% 408 3.28% 2.47%

General Log Violations 70,536 9.40% 2.35% 702 13.15% 4.25%

10/15 Hours 56,081 5.40% 1.87% 391 6.86% 2.37%

60/70/80 Hours 9,572 0.30% 0.32% 46 0.30% 0.28%

All Other Hours-of-Service 1,912 6.00% 0.06% 14 7.11% 0.08%

All HOS Related 163,565 22.00% 5.50% 1,561 31.00% 9.50%

Disqualified Drivers 11,409 0.40% 0.38% 154 0.96% 0.93%

Drugs 2,000 0.10% 0.07% 63 0.40% 0.38%

Alcohol 3,979 0.10% 0.13% 164 1.06% 0.99%

Seat Belt 43 1.60% 0.00% 1.56% 0.00%

Traffic Enforcement 8 0.10% 0.00% 0.22% 0.00%

Radar Detectors 6 0.40% 0.00% 0.40% 0.00%

All Other Driver Violations 57,085 21.70% 1.90% 701 42.80% 4.25%

Brakes Out of Adjustment 96,307 9.60% 3.21% 1,764 31.75% 10.69%

Brakes, all others 229,124 25.40% 7.64% 3,196 41.22% 19.37%

Coupling Devices 8,058 0.60% 0.27% 230 2.08% 1.39%

Fuel Systems 9,361 0.90% 0.31% 247 2.14% 1.50%

Frames 13,911 1.50% 0.46% 323 4.02% 1.96%

Lighting 156,735 46.50% 5.22% 1,061 52.38% 6.43%

Steering Mechanism 10,610 1.70% 0.35% 256 2.65% 1.55%

Suspension 39,595 3.10% 1.32% 1,014 8.90% 6.15%

Tires 83,108 12.70% 2.77% 1,624 26.67% 9.84%

Wheels, Studs, Clamps, etc. 13,315 1.70% 0.44% 354 4.43% 2.15%

Load Securement 114,509 5.60% 3.82% 1,105 9.70% 6.70%

Windshield 406 4.00% 0.01% 21 5.32% 0.13%

Exhaust Discharge 1,866 3.00% 0.06% 35 2.93% 0.21%

Emergency Equipment 175 9.60% 0.01% 10.20% 0.00%

Periodic Inspection 230 6.00% 0.01% 2 8.39% 0.01%

All Other Vehicle Defects 64,695 23.60% 2.16% 1,303 37.05% 7.90%

Misc. Moving Violations, Others 

and Unknown 

21,458 18.93% 0.72% 170 16.00% 1.03

Totals 1,102,042 36.70% 15,360 97.10%
While this information indicates a direct link between fatigue, HOS violations, and crashes, the 

most detailed study on this relationship was undertaken as part of the Regulatory Impact Analysis 

for HOS Options, completed in December 2002 by ICF Consulting and Jack Faucett Associates 

(the RIA HOS Study). This study compared the safety and economic impacts of alternative HOS 

regulatory options with the current HOS regulations, assuming 100-percent compliance and with 

current levels of non-compliance. A high-level summary of the findings of this study is shown in 

Table 25. The only things shown are data on the current HOS regulations with and without 100-

percent compliance, as well as FMCSA’s new HOS rules, since the other regulatory options 

examined in the study are not relevant here. 

5 Table 25. Damages Attributable to Fatigue

FMCSA 

New HOS Rules “Old” Rule “Old” Rule, 

Long- and Short-Haul Categories (100% Compliance) (100% Compliance) Status Quo 

% of Long-Haul Crashes Attributable 

to Fatigue 7.1% 8.5% 11.2% 

Total Damages of Fatigue-related 

Long-Haul Crashes $1,138 $1,361M $1,791M 

% of Short-Haul Crashes Attributable 

to Fatigue 3.7% 3.8% 3.9% 

Total Damages of Fatigue-related 

Short-Haul Crashes $492 $506M $528M 

The RIA HOS Study suggested that 100-percent compliance with HOS rules will have little 

impact on short-haul operations (defined as 150 miles or less in that study), but will have a major 

impact on long-haul operations. It should be noted that the percentage of crashes attributed to 

fatigue in this study were referenced to all commercial vehicle crashes, not just crashes for which 

the truck was assigned the critical reason. Table 24 indicates that fatigue-related crashes would 

be reduced from 11.2 percent to 8.5 percent with 100-percent compliance; this is roughly a 24-

percent decrease in fatigue-related accidents.*

If the percentage reduction in crashes due to 100-percent compliance with HOS reported in the 

RIA Study (i.e., 24 percent) were to be applied to those crashes identified in the LTCCS as being 

linked to fatigue, then crash rates associated with fatigue would be reduced from 22 percent to 17 

percent (again, only for those crashes for which the truck entity was linked to the critical reason). 

No credit is taken for reducing crashes or injuries for those crashes in which the other vehicle 

was assigned the critical reason, even though some percentage of commercial vehicle drivers in 

these accidents were also fatigued, and therefore full compliance with HOS regulations would 

likely have led to at least some small decrease in the number or severity of these crashes. For 

purposes of calculating crash reductions, it was assumed that a wireless inspection alternative as 

 

5

 Federal Motor Carrier Safety Administration Regulatory Impact Analysis for Hours of Service Options, Prepared 

by ICF Consulting, Inc. and Jack Faucett Associates; Washington D.C.: 2002. 

*

11.2 percent minus 8.5 percent, divided by 11.2 percent 

54 
described for Alternative 3 would lead to nearly 100-percent compliance with HOS rules. This 

would, in turn, lead to a 24-percent reduction in fatigue-related crashes. 

It can also be argued that for other crashes which cited commercial vehicle driver error as the 

critical reason, there would also be some percentage reduction in crashes above and beyond 

those linked directly to fatigue. In other words, a wireless inspection program that routinely 

collected CDL credentials and HOS logbook data would yield additional indirect benefits related 

to improved driver hiring, screening, and training practices. For example, instances of 

disqualified drivers becoming involved in crashes would be reduced, since an operator that did 

not have a valid and current CDL would be quickly identified and cited. Over time, such drivers 

would simply not get behind the wheel, since they would know that they would be quickly 

identified and fined. For purposes of calculating potential savings, it is conservatively estimated 

that possibly 3 percent of the crashes caused by driver error (but not directly by driver fatigue) 

would be eliminated by a wireless inspection program of the type implied by Alternative 3. This 

percentage roughly corresponds to the percentage of commercial drivers involved in fatal crashes 

who were operating without valid CDLs. The inspection concept described would arguably 

reduce to nearly zero the percentage of drivers operating without a proper license. 

4.4.4 Safety Benefits: Alternative 4—Driver Enhanced 

Under this alternative, in addition to including CDL and HOS data in the message set (as in 

Alternative 3), direct operator performance measurement data would also be included using 

technologies such LDWS, eyelid-closure monitoring, and/or steering wheel sensors to measure 

alertness. Research conducted for this study did not uncover any individual fleet studies or case 

histories, even anecdotally, that credited such systems with a quantitative reduction in accidents. 

However, as noted in the discussion of Alternative 2, fatigue appears to be a significant 

contributing factor in 22 percent of all crashes in which the truck was linked to the critical reason 

for the crash. If full compliance with HOS regulations (which provide only an indirect link to 

fatigue) can achieve a 24-percent reduction in such crashes, it is reasonable that directly 

measuring fatigue (using LDWS and/or other drowsy-driver systems) could perhaps achieve a 

50- percent reduction in crashes from the level of crashes that occur with full compliance with 

HOS regulations alone. Further, it is reasonable to assume that driver-monitoring systems would 

also reduce crashes that are related to driver error, but not directly linked to fatigue. For purposes 

of this analysis, it was assumed that such driver-monitoring systems would reduce those crashes 

associated with driver error (but not directly related to fatigue) by an additional 3 percent, 

beyond the 3-percent reduction noted under Alternative 3. It should be noted that while these 

percentage estimates are speculative, the end result in terms of reduction in number of crashes 

and fatalities is similar to the estimates contained in FMCSA’s Draft Report for the MACK Field 

Operation Test (FOT), which included the use of LDWS. This study reported a reduction of 

between 90 and 140 fatalities for a nationwide deployment of LDWS. This is similar to the 

incremental increase in fatality reduction between Alternative 3 (“driver basic”) and Alternative 

4 (“driver enhanced”). 

4.4.5 Safety Benefits: Alternative 5—“Vehicle and Driver Basic” 

Under this alternative, the SDMS would consist of basic fault code data as described in 

Alternative 1, and the CDL and electronic HOS logs as described in Alternative 3. In a practical 

sense, this would probably be the case if Alternative 3 were implemented. That is, if a wireless 

55 
inspection program were implemented that focused on electronically and wirelessly extracting 

HOS logs, it would be simple to add existing fault code information to the message set, since 

such data is already available on the high-speed databus of commercial vehicles. This alternative 

then would yield the combined safety benefits of Alternatives 1 and 3. 

4.4.6 Safety Benefits: Alternative 6—“Vehicle and Driver Enhanced” 

Under this alternative, the SDMS would consist of the following: vehicle fault code data; 

performance monitoring of brake, tire, and lighting systems; CDL and HOS electronic logs; and 

direct measurement of driver fatigue indicators. This alternative represents the combined SDMS 

from Alternatives 2 and 4, and would yield roughly the combined safety benefits of both 

alternatives. 

4.4.7 Safety Benefits: Baseline/Non-Cooperative Alternative 

Estimating safety benefits from using advanced non-cooperative technologies to improve the 

current inspection process is troublesome. It is anticipated that by improving pre-screening of 

vehicles, there would most likely be some reduction in the incidence of crashes in which one of 

the inspected components is the cause. However, the major limitation of a non-cooperative 

approach is that there would be virtually no additional, real-time information collected about the 

driver. From a practical perspective, advanced non-cooperative vehicle inspection technologies 

can target only selected vehicle defect areas—specifically, brakes, major suspension problems, 

and lights using advanced sensor systems. Such vehicle defects account for perhaps 3–4 percent 

of commercial vehicle crashes. Thus, this concept would not target the principal cause of 

crashes, i.e. drivers. 

4.5 OVERALL EVALUATION AND SELECTION OF SDMS ALTERNATIVES 

Selection of the optimum wireless inspection concept is based on an evaluation of: 

• A cost-benefit comparison 

• Comparison of real-world institutional and deployment challenges 

The first step to selecting the optimal SDMS alternative is to compare the expected safety 

benefits of each alternative (assuming a fully implemented inspection network) with the 

combined costs to establish the inspection infrastructure and to phase in the onboard units on all 

new Class III–VII commercial vehicles. 

4.5.1 Monetizing Safety Benefits 

The annual savings (in terms of reduced fatalities, injuries, and property damage) is used to 

estimate the monetary safety benefits for each of the wireless inspection alternatives. A summary 

of the estimated percentage reduction in crashes linked to various Critical Reason categories for 

each of the wireless inspection alternatives is presented in Table 26. 

To calculate safety benefits, the percentage reduction estimates are applied only to that portion of 

total CMV crashes which would be impacted as discussed in the previous sections. For example, 

under Concept 5 (“vehicle and driver basic”), a 24-percent reduction in CMV crashes related to 

fatigue is estimated. However, according to the LTCCS study, only 64 percent of all CMV 

56 
crashes are linked to the truck entity, and in only 22 percent of those crashes were the 

commercial vehicle drivers officially found to have been fatigued. In other words, commercial 

driver fatigue was a significant factor in 14 percent of all CMV crashes (22 percent × 64 

percent), based on estimates from the LTCCS. Therefore, the estimate of a 24-percent reduction 

in fatigue-related crashes is applied to the 14 percent of all CMV crashes that are linked to 

fatigue, resulting in a reduction of about 3.4 percent in the total number of CMV crashes. 

Similarly, the 50-percent reduction in crashes directly linked to poor brakes (under Concept 2, 

“vehicle enhanced”), results in only a 1.3-percent reduction in total CMV crashes since poor 

brake performance is cited as the critical reason for the crash in only 2.6 percent of all CMV 

crashes. 

Table 26. Estimated Percent Reduction in CMV Crashes for Each SMDS Alternative Concept 

As a % of 

Total CMV 

Crashes 

As a % of all crashes 

where the Truck was 

assigned the critical 

reason for the crash 

1 

Vehicle 

Basic 

2 

Vehicle 

Enhanced 

3 

Driver 

Basic 

4 

Driver 

Enhanced 

5 

Vehicle 

and Driver 

Basic 

6 

Vehicle 

and Driver 

Enhanced 

Critical Reason 

for Crash 

Driver Error: 

Fatigue 22% 14.1% 0% 0% 24% 36% 24% 36% 

Misc. Driver 65% 41.6% 0% 0% 3% 6% 3% 6% 

Total Driver 87% 55.7% 

Vehicle Defects: 

Brakes 4% 2.6% 10% 50% 0% 0% 10% 50% 

Tires 2% 1.3% 10% 50% 0% 0% 10% 50% 

Load Securement 3% 1.9% 0% 0% 0% 0% 0% 0% 

Misc. Vehicle 1% 0.6% 10% 10% 0% 0% 10% 10% 

Total Vehicle 10% 6.4% 

Total Other (environmental or 3% 1.9% 0% 0% 0% 0% 0% 0% 

unknown)

TOTAL 100% 64% 

Table 27 shows crash data from FMCSA Large Truck Crash Facts Study (2003), along with the 

average cost per event from the FMCSA’s Cost of Crashes Study (2002). As shown in Table 27, 

CMV crashes cost the nation about $32 billion annually in monetary terms, and cause about 

4,000 to 5,000 fatalities annually. 

57 
6 Table 27. Breakdown of Accidents Involving Commercial Vehicles (CY 2002) 

# of Cost per Crash Total ($M) Persons Crashes 

Fatal Crashes 4,289 $3,800,000 $16,298 4,986 

Injury-Only Crashes 84,000 $95,000 $7,980 122,000 

PDO Crashes 347,000 $24,000 $8,328 0 

Total 435,289 74,907 $32,606

Table 28 shows the estimated reduction in fatalities as a result of implementing each SDMS 

alternative. 

Table 28. Estimated Fatality Reduction Rate by SDMS 

(in crashes attributed to a commercial vehicle) 

Fatal Crashes 

Associated 

with Critical 

Reason 

1 

Vehicle 

Basic 

2 

Vehicle 

Enhanced 

3 

Driver 

Basic 

4 

Driver 

Enhanced 

5 

Vehicle 

and Driver 

Basic 

6 

Vehicle 

and Driver 

Enhanced 

% of 

Total 

Crashes 

Critical Reason 

for Crash 

Driver Error: 

Fatigue 22% 604 0 0 145 217 145 217 

Misc. Driver 65% 1784 0 0 54 107 54 107 

Vehicle Defects: 

Brakes 4% 110 11 55 0 0 11 55 

Tires 2% 55 5 27 0 0 5 27 

Load Securement 3% 82 0 0 0 0 0 0 

Misc. Vehicle 1% 27 3 3 0 0 3 3 

TOTAL FATAL CRASHES 

REDUCED 19 85 198 324 218 410 

TOTAL FATALITIES 

SAVED 22 99 231 377 253 476 

Fatality reduction is estimated by first calculating the number of fatalities associated with each 

critical reason for crashes, based on the associated percentage of total CMV accidents. This 

number was multiplied by the estimated percentage reduction from Table 28 shows that SDMS 

Alternative 6 has the highest fatality reduction rate, at 476 lives annually, while SDMS 

Alternative 1 has the lowest fatality reduction rate, at 22 lives annually. 

A similar analysis was conducted for injuries as well as “property damage only” (PDO) 

accidents. 

 

6

 Pacific Institute for Research and Evaluation, Revised Cost of Large Truck- and Bus-Involved Crashes, Final 

Report for Federal Motor Carrier Safety Administration, Washington, DC: 2002. 

58 
Table 29 shows the estimated injury reduction rate for each SDMS alternative, while Table 30

shows reductions in PDO crashes. 

Table 28, Table 29, and Table 30 are multiplied by the data from Table 27 for the average cost of 

a fatality, injury, and PDO accident, and then summed to arrive at total cost savings (or benefits) 

for each SDMS alternative. This data is shown in Table 31. 

Table 29. Estimated Injury-Reduction Rate by SDMS 

(in crashes attributed to a commercial vehicle) 

% of Total 

Crashes 

Injury-Only 

Crashes 

Associated with 

Critical Reason 

1 

Vehicle 

Basic 

2 

Vehicle 

Enhanced 

3 

Driver 

Basic 

4 

Driver 

Enhanced 

5 

Vehicle 

and Driver 

Basic 

6 

Vehicle 

and Driver 

Enhanced 

Critical Reason 

for Crash 

Driver Error: 

Fatigue 22% 11,827 – – 2,839 4,258 2,839 4,258 

Misc. Driver 65% 34,944 – – 1,048 2,097 1,048 2,097 

Vehicle Defects: 

Brakes 4% 2,150 215 1,075 – – 215 1,075 

Tires 2% 1,075 108 538 – – 108 538 

Load Securement 3% 1,613 – – – – – – 

Misc. Vehicle 1% 538 54 54 – – 54 54 

TOTAL INJURY ONLY 376 1,667 3,887 6,354 4,263 8,021 

CRASHES REDUCED 

TOTAL INJURIES 547 2,420 5,645 9,229 6,192 11,650 

AVOIDED 

Table 30. Estimated Property-Damage-Only Crash Reduction Rate by SDMS 

(in crashes attributed to a commercial vehicle) 

PDO Crashes 

Associated 

with Critical 

Reason 

% of Total 

Crashes 

1 

Vehicle 

Basic 

2 

Vehicle 

Enhanced 

3 

Driver 

Basic 

4 

Driver 

Enhanced 

5 

Vehicle 

and Driver 

Basic 

6 

Vehicle 

and Driver 

Enhanced 

Critical Reason 

for Crash 

Driver Error: 

Fatigue 22% 48,858 – – 11,726 17,589 11,726 17,589 

Misc. Driver 65% 144,352 – – 4,331 8,661 4,331 8,661 

Vehicle Defects: 

Brakes 4% 8,883 888 4,442 – – 888 4,442 

Tires 2% 4,442 444 2,221 – – 444 2,221 

Load Securement 3% 6,662 – – – – – – 

Misc. Vehicle 1% 2,221 222 222 – – 222 222 

TOTAL PDO CRASHES 1,555 6,884 16,056 26,250 17,611 33,134 

REDUCED 

59 
Table 31 shows that for SDMS Alternative 1, the estimated total benefits would be 

approximately $146 million annually. For Alternative 6, they would be $3.1 billion annually. 

Table 31. Total Estimated Safety-Related Benefit by SDMS 

(in crashes attributed to a commercial vehicle) 

% of Total 

Crashes 

Total $M 

Associated with 

Critical Reason 

1 

Vehicle 

Basic 

2 

Vehicle 

Enhanced 

3 

Driver 

Basic 

4 

Driver 

Enhanced 

5 

Vehicle 

and Driver 

Basic 

6 

Vehicle 

and Driver 

Enhanced 

Critical Reason 

for Crash 

Driver Error: 

Fatigue 22% $4,591 $0 $0 $1,102 $1,653 $1,102 $1,653 

Misc. Driver 65% $13,564 $0 $0 $407 $814 $407 $814 

Vehicle Defects: 

Brakes 4% $835 $83 $417 $0 $0 $83 $417 

Tires 2% $417 $42 $209 $0 $0 $42 $209 

Cargo Securement 3% $626 $0 $0 $0 $0 $0 $0 

Misc. Vehicle 1% $209 $21 $21 $0 $0 $21 $21 

TOTAL ANNUAL $146 $647 $1,509 $2,467 $1,655 $3,114 

BENEFITS ($MM) 

4.5.2 Total Cost Estimates for Each Alternative and Benefit-Cost Analysis 

To estimate the total annualized costs for each alternative, the inspection facility, equipment, and 

IT-related costs from Table 14 were combined with vehicle-related modification costs from 

Table 21 to calculate the total annualized costs. To simplify the analysis, infrastructure costs 

were amortized linearly over 10 years. This is probably a conservative assumption, since the 

facility modifications will actually last much longer than 10 years. Also, while a present-value 

analysis could be performed, the reality is that a wireless inspection infrastructure will probably 

be built out over several years in a manner that more or less matches the increased market 

penetration of new vehicles equipped with wireless inspection technology. To this extent, the 

one-time capital cost investment is actually an annualized investment, thus making a presentvalue analysis less appropriate. 

Annualized incremental vehicle costs are based on the FY 2003 annual production estimate of 

420,000 commercial vehicles (Class III–VII) from the American Trucking Trends 2004. Table 

32 details the total annualized cost analysis for each alternative, and lists the safety benefits and 

the resulting cost-benefit ratio. 

Note: It is important to understand that the monetized safety benefits presented are total societal 

benefits and not direct benefits to fleets. For example, the cost of a single fatal crash is estimated 

at about $3.8 million and includes the monetized “Quality-Adjusted Life Years” or QALY value. 

These costs are based on the present value of all costs over the victims’ expected lifespan, 

including lost productivity, lost earnings, and the monetized value of the loss of quality of life 

that impacts a family because of the death of a family member. Further, the total costs presented 

60 
in the analysis are not total costs to a fleet, but total costs to society. For example, all costs 

associated with the infrastructure are included. These are not costs that would be incurred by 

fleets. The overall methodology (based on societal cost-benefits) is the same approach taken by 

FMCSA in its Regulatory Impact Analysis for the revised HOS rule. 

Table 32. Cost-Benefit Analysis by SDMS 

(in Crashes Attributed to a Commercial Vehicle) 

1 

Vehicle Basic 

2 

Vehicle 

Enhanced 

3 

Driver Basic 

4 

Driver 

Enhanced 

5 

Vehicle and 

Driver Basic 

6 

Vehicle and 

Driver 

Enhanced 

Critical Reason for Crash 

Annual Benefits: 

Annual Fatalities Saved 22 99 231 377 253 476

Annual Injuries Saved 547 2,420 5,645 9,229 6,192 11,650

Total Annual Benefits ($MM) $146 $647 $1,509 $2,467 $1,655 $3,114

Annual Costs ($MM): 

Amortized Facility & 

Equipment Infrastructure Cost 

(10 yrs) 

$10.6–$17.6 $10.6–$17.6 $10.6–$17.6 $10.6–$17.6 $10.6–$17.6 $10.6–$17.6 

Facility & Equipment 

Infrastructure O & M Costs 

$9.4–$15.2 $9.4–$15.2 $9.4–$15.2 $9.4–$15.2 $9.4–$15.2 $9.4–$15.2 

Amortized IT and 

Communication System 

Capital Costs (10 yrs) 

$11.0–$16.5 $11.0–$16.5 $11.0–$16.5 $11.0–$16.5 $11.0–$16.5 $11.0–$16.5 

IT and Communication 

System Operating Costs 

$13.5–$27.0 $13.5–$27.0 $13.5–$27.0 $13.5–$27.0 $13.5–$27.0 $13.5–$27.0 

Annual Incremental Vehicle 

Costs (based on 420,000 

units/yr) 

$100–$204 $579–

$1,814 

$197–$368 $661–$1,296 $224–$395 $1,589–

$2,770$ 

$144–$280 $623–

$1,891 

$241–$444 $705–$1,372 $268–$471 $1,633–

$2,846 

Total Annualized Cost 

Benefit/Cost Ratio 

High–Low 1.01– 0.52 1.04–0.34 6.26–3.40 3.50–1.80 6.17–3.51 1.91–1.09 

Average 0.77 0.69 4.83 2.65 4.84 1.50

The results of the analysis in Table 32show that Alternative 1 has the lowest overall cost-benefit 

ratio at 0.77, while Alternative 5 (“vehicle and driver basic”) would likely yield the best costbenefit ratio at 4.84, meaning the annualized benefits exceed annualized costs by a margin of 

almost 5 to 1. In other words, on an annual basis, the total costs for Alternative 5 would be repaid 

from savings due to reduction in crashes in about 2.5 months. Alternative 3, “driver basic”, 

offers nearly the same cost-benefit ratio as Alternative 5 (“vehicle and driver basic”), since most 

of the safety benefits are in fact derived from increased HOS compliance and monitoring of the 

driver. 

61 
62 

4.5.3 Summary Comparison 

Table 32 summarizes results of the overall comparison of SDMS wireless concept alternatives. 

Alternatives 1 and 2 offer only marginal improvements in safety in absolute terms, and their 

cost-benefit ratios are poor. On an absolute basis, Alternatives 4 and 6 offer the greatest safety 

benefits, with reductions in fatalities of 377 and 476, respectively. However, the implementation 

costs and institutional issues associated with widespread deployment make these alternatives 

unfeasible for near-term deployment. Both of these alternatives would require extraordinary 

research programs to develop technical standards and violation criteria for direct monitoring of 

vehicles and drivers. 

Alternative 3 (“driver basic”) offers significant safety benefits, and the implementation costs are 

reasonable. However, from a practical perspective, if a vehicle were equipped with the capability 

to wirelessly transmit the driver data implied by Alternative 3, then it would be technically quite 

simple also to include readily available vehicle fault data, (i.e., implementation costs for 

Alternatives 3 and 5 are nearly identical)—and not to do so, according to the findings in this 

Report, would be a wasted opportunity. 

Alternative 5 (“vehicle and driver basic”) does not rely on any new technology for deployment 

and would require only the installation of an appropriately designed data recording system, along 

with the wireless communications hardware (radio) and operating system. Additionally, no new 

standards need to be developed, nor does any consensus need to be reached on new vehicle 

safety systems or driver performance measurement methodologies. This alternative would 

leverage the increased diagnostic information already available on today’s state-of-the-art heavyduty trucks. It would enhance the ability to reap the benefits of the increasing sophistication in 

automated diagnostics that will inevitably occur over time. This alternative would also leverage 

the standardization work that is being considered as part of the EOBR effort—specifically, 

standards surrounding the format and extraction of electronic HOS logs. 

Additionally, deployment of Alternative 5 provides a very good technical, timing, and 

programmatic fit with other industry efforts. Specifically, it complements efforts by the Joint 

Program Office to develop standard vehicle-to-infrastructure communications and efforts by the 

EPA to develop standard emission-related fault codes to monitor compliance with new stringent 

emission regulations that will go into effect near the end of this decade (i.e., heavy-duty OBD II 

standards). 

Based on overall cost effectiveness and ease of implementation, SDMS Alternative 5 is the 

recommended alternative for moving forward into Task 5, and the alternative for which business 

and technical deployment plans are detailed. 
Table 33. Overall Comparison of Wireless Inspection SDMS Alternatives—by Criteria 

(Favorability Ratings: 4 = Very Favorable, 0 = Very Unfavorable) 

SDMS Key Output Data Costs Effectiveness in Institutional Other Development 

Alternatives Reducing Crashes Issues/Challenges Challenges 

1. Vehicle- Likely minor impact. Fault 

code data is not a direct 

measure of safety system 

performance, and vehicle 

defects not strongly linked 

with crash rates.

Wireless vehicle 

diagnostics already 

being offered by OEMs. 

May be able to directly 

leverage OBDII 

technical approach.

Readily available fault 

code information related 

to brakes, transmission, 

engine and electrical 

system. Also VIN 

number. 

Basic Vehicle data likely 

considered less 

“private” than driver 

information.

Favorability: 4 0 3 3 

2. Vehicle- Vehicle data likely 

considered less 

“private” than driver 

information, but lack of 

consensus around 

“failures” will be a 

challenge.

Enhanced Substantial research 

program needed to 

develop violation criteria 

based on safety system 

sensor measurements.

As above, but include 

specialized diagnostic 

data for brakes, tires, 

and lighting systems 

failures. 

Little to moderate impact. 

Brakes, tires and lighting 

defects loosely linked with 

crash rates.

Favorability: 2 1 2 1 

3. Driver- Development of a cost 

effective reliable means 

of positively identifying 

driver to vehicle is a 

challenge programs like 

TWIC and REAL ID 

would need to be 

leveraged.

Likely push back from 

industry due to privacy 

and cost concerns. 

Similar to current 

NPRM for EOBRs only 

more intense due to 

ease with which HOS 

data could be extracted.

Basic 

Likely very effective, 

would dramatically reduce 

HOS violations.

Electronic HOS Record, 

CDL #, and VIN 

Favorability: 3 2 2 2 

4. Driver- Same as 3, but also 

Driver “performance” 

information—specifically 

LDW data. Other drowsy 

driver monitoring 

systems can be added. 

Significantly more 

effective than 3 since 

direct measurements of 

driver performance would 

be added.

Likely strong push back 

due to privacy and cost 

concerns, and technical 

validity of 

measurements.

Substantial research 

program needed to 

develop violation criteria 

based on safety system 

sensor measurements.

Enhanced 

Favorability: 1 3 0 1 

5. Vehicle- Similar to 3 but with 

added complexity of 

developing new 

violation criteria based 

on fault code 

information.

and Driver– Similar to 3, but with 

some added concerns 

with collection of vehicle 

data.

Basic Combined safety benefits 

of concepts 1 and 3. 1 and 3 Combined 

Favorability: 3 2 2 2 

6. Vehicle- Major Safety Benefits. 

Comprehensive 

monitoring of driver and 

vehicle crash causation 

factors.

Substantial research 

program needed to 

develop violation criteria 

for both driver and 

vehicle monitoring.

and Driver- Substantial privacy, 

cost, and technical 

validity concerns.

Enhanced 2 and 4 Combined 

Favorability: 0 4 0 0 

63 
5.0 DEPLOYMENT PLANNING 

5.1 RATIONALE FOR CONTINUED RESEARCH 

A fundamental question to be answered before moving forward with developing strategies for 

implementing the wireless inspection concept is: 

Considering FMCSA’s role as an enforcement agency, should FMCSA move forward with 

research in wireless inspection concepts? 

Based on the cost-benefit ratios calculated in Task 4, the Research Team’s interviews with a 

variety of industry stakeholders, feedback from the public RFI process, and the important 

changes occurring in the commercial trucking industry, the answer would appear to be a clear 

“YES.” The rationale for pursuing research related to the wireless inspection concept is 

summarized as follows: 

• Overwhelmingly positive benefit-cost ratio. The analysis presented in this Report 

showed that the total costs for implementing a wireless inspection concept (both the 

public-sector infrastructure costs and the private-sector incremental vehicle costs) could 

be recouped in well under 1 year, based on savings from reductions in fatalities and 

injuries. 

• No new technology is required. While there are certainly technical challenges related to 

functional requirements, standards, and IT support systems that must be addressed, the 

fundamental technology for collecting the onboard data and transmitting it wirelessly is 

already available. 

• The concept would support real-time identification of CMV operators. Several recent 

studies, including the Large Truck Crash Causation Study and ATA’s Driver Risk Study, 

have confirmed that: 

– Driver error is the leading cause of CMV crashes 

– Drivers with poor safety records are more likely than other drivers to be involved 

in future crashes 

– Drivers with improper or disqualified credentials are involved in a 

disproportionate number of fatalities 

Therefore, real-time identification of the CMV driver could be leveraged to improve vehicle 

screening, identify disqualified drivers, and discourage such drivers from operating a CMV to 

begin with. Coincidentally, programs such as TWIC and REAL ID are developing requirements 

and standards for electronically identifying the driver using smart-card technology. FMCSA does 

not have to develop this capability, and these programs could be leveraged to help spur changes 

in CDL standards to permit drivers to electronically identify themselves to the truck. 

• The selected concept does not call for collecting any information which is not 

already collected by FMCSA. Alternative 5 (“vehicle-plus-driver basic”) would 

wirelessly collect basic vehicle fault code data along with HOS logs, VIN, USDOT 

number, and CDL number. All of this information is already collected by CMV 

enforcement agencies during roadside inspections. Legal and policy issues associated 

with collecting the data should therefore be minimized. 

64 
• The concept augments FMCSA’s ongoing efforts related to EOBRs. FMCSA is 

developing standards for the electronic reporting (or file format) for HOS data. This work 

could be directly leveraged to support inclusion of this information in a wireless SDMS. 

• The concept would support the needs of other Federal Agencies. EPA is currently 

engaged in rulemaking which calls for emission inspections on in-service heavy-duty 

vehicles in the 2010 timeframe using electronic onboard diagnostic (OBD) technology. 

EPA (and CARB) is already engaged in developing an emissions data message set which 

is conceptually identical in form to an SDMS. However, from an implementation 

perspective, EPA has not yet finalized how, where, and when such emission inspections 

will take place. Preliminary conversations with EPA indicate that they are very interested 

in exploring with FMCSA the possibility of leveraging the roadside safety inspection 

program as a venue for completing emission inspections as well. Conceivably, EPA and 

FMCSA could jointly explore a means for wirelessly extracting both safety- and 

emissions- related diagnostic data. 

• Implementation costs are likely to come down, while available onboard safety 

information will increase. As noted above, advances in heavy-duty vehicle design 

continue to emphasize more capability for self-diagnostics, while the cost of such 

technology is dropping. Electronic braking systems, collision warning devices, and other 

driver-monitoring systems continue to increase their market penetration. As these 

technologies become more commonplace, information from these systems might be 

downloaded to augment various screening and enforcement strategies (for example, 

strategies targeted only at carriers with very poor safety records). 

• The wireless inspection concept supports CSA 2010 Goals. Goals of FMCSA’s 

Comprehensive Safety Analysis 2010 effort include: 

– Increased emphasis on driver accountability

– Leveling the playing field through uniform application of compliance and 

enforcement procedures

– Improving the agency’s high-risk motor carrier identification systems 

Clearly, all of these goals would be supported by a wireless inspection program. Driver 

accountability is increased through real-time identification of the driver and verification of 

proper credentials. The playing field is leveled for two reasons: First, the inspection net would be 

widened to include more trucks operating in multiple environments; and second, the frequency of 

wireless inspections would be linked to miles traveled (activity levels) rather than predetermined 

inspection algorithms, the size or history of the carrier, and/or human judgment by enforcement 

officers. Finally, the ability to identify high-risk motor carriers would be greatly improved 

because of much greater overall inspection frequency and collection of safety data on all 

vehicles. 

• The current CVISN and COMPASS efforts provide an ideal platform for rolling out 

the wireless inspection concept. As noted earlier, current State and Federal CMV 

information and communication systems will need to be modified and expanded to take 

full advantage of CMV wireless inspection capability. CVISN is already poised to 

develop standards associated with electronic screening as well as methods for sharing 

such data between States. These efforts will help in standardizing the specific hardware 

and software needed at inspection stations in order to support wireless data download and 

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analysis capability, thus gaining economies-of-scale. At the same time, the COMPASS 

effort is updating FMCSA’s entire suite of customer interface, data analysis, and data 

warehousing applications. It would be an opportune time for making provisions in these 

new applications to accommodate the expanded data to be gathered through wireless 

inspections. 

5.2 CHALLENGES FOR DEPLOYMENT 

While overall, the wireless inspection concept offers tremendous potential for improving the 

safety and efficiency of motor vehicle operations, there remain very significant challenges for 

widespread deployment: 

• Costs to fleets. As with many such initiatives, even though there is a predicted net 

benefit for the industry and public overall, many fleets would not experience a positive 

return on investment because of their already-good safety record. These fleets would 

view the concept only in terms of increased costs. Many of the more sophisticated fleets 

already have the capability for wireless communications through a satellite or cellular 

telematics service provider, and would view it as redundant and/or wasteful to require 

them to add short-range communications capabilities. (Many of the fleets that participate 

in electronic screening programs or electronic toll collection already have dedicated 

short-range communications via their onboard RFID tags.) Most fleets will see the added 

costs to participate in a wireless inspection program as just that—added costs with no 

direct benefit. Although the benefits are long term and are based on reduced crashes, the 

prevailing attitude of fleet managers will be, “Why do I want to spend money on 

something that will make it easier for enforcement agencies to issue violations?” 

• Privacy and misuse of data. An additional major concern among fleets relates to 

whether and how information collected could be misused. Two broad areas of concern 

exist: 1) Data collected by the State could be subpoenaed by trial lawyers for use against 

the trucking company whose vehicle was involved in an accident (this is discussed in the 

institutional issues section); and 2) Vehicle location and other competitive data might 

somehow become publicly available or otherwise be acquired by competitors through 

unlawful means. 

These cost and data privacy concerns on the part of fleets, as well as a general aversion to having 

their vehicles monitored “unnecessarily,” strongly suggests that fleets will not freely adopt such 

technology on their own, especially since current electronic screening programs already allow 

fleets to bypass stations by downloading only the carrier identifier information. 

5.3 ALTERNATIVE DEPLOYMENT STRATEGIES 

With this background there are two broad strategies for moving forward with deployment of the 

wireless inspection program: 

1. Leverage USDOT’s current VII Initiative. This approach would seek to establish a 

long-term, strategic relationship with the CMV industry to develop a standardized 

vehicle-to-infrastructure communications infrastructure and associated value-added 

safety and commercial applications. Specifically, this approach would call for FMCSA to 

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become more fully engaged in the Vehicle Infrastructure Integration (VII) effort now 

being sponsored by the Joint Program Office, and to partner with leading fleets and 

heavy-duty vehicle OEMs in developing a variety of market-driven safety and 

commercial applications that are supported by the 5.9 GHz standards. Such technology 

and applications would offer real and immediate value to fleets—and our preliminary 

discussions with truck OEMs indicate they are anxious to pursue the VII technology. 

Once the industry adopts the DSRC technology, then costs to introduce the wireless 

inspection concept would be greatly reduced. At that point, either a direct regulatory 

approach could be taken that would require downloading of safety data, or a “soft” 

regulatory approach could be considered in which FMCSA would leverage its influence 

with States so that they would modify electronic pre-clearance programs to require 

additional, real-time safety data to be downloaded before vehicles would be permitted to 

bypass inspection stations. In other words, if a truck did not wirelessly transmit an 

electronic SDMS, it would not be permitted to bypass the station and would almost 

certainly be targeted for a full Level 1 inspection. Since all new trucks would be equipped 

with the VII technology, fleets would be highly motivated to voluntarily download their 

SDMSs. The phase-in of such enhanced electronic pre-clearance programs would need to 

be carefully managed and matched to the market penetration of trucks equipped with the 

DSRC technology so that inspection stations would not be overloaded with manual 

inspections at one extreme, or underutilized at the other extreme. This is the approach 

recommended by the Research Team. It is a longer-term approach, but would clearly set 

FMCSA, and the industry, on a path toward major improvements in CMV safety and 

efficiency. 

2. A regulatory approach. From a technical and cost-benefit perspective, there would 

appear to be sufficient justification for initiating a regulatory effort, particularly if a joint 

effort with the EPA were to be adopted. However, this approach is not recommended due 

to the political, policy and institutional obstacles that would have to be overcome. 

Leverage USDOT’s VII Initiative 

Wireless inspections represent only one of many safety applications that could be made possible 

though standardized vehicle-to-vehicle and vehicle-to-infrastructure communications using the 

5.9 GHz DSRC platform. As important, the DSRC medium allows for the development of 

numerous commercial and convenience applications that offer added value to commercial 

vehicle fleets, shippers, and vehicle OEMs. Therefore, the deployment of a wireless inspection 

program could coincide with a larger initiative to encourage the adoption of DSRC technology 

within the commercial-vehicle, heavy-duty sector. From FMCSA’s perspective, wireless safety 

inspections may represent the premier application that is enabled by DSRC, but there are clearly 

many other safety and non-safety applications that will help build the business case for adoption 

of this standardized communications media by the industry. 

Currently, USDOT is aggressively working in the light-duty sector to develop and deploy DSRC 

technology. Fortunately, much of the core wireless communications technology development has 

already been completed under that program, such as the allocation of spectrum by the FCC 

exclusively for transportation applications and the development of functional and performance 

standards for a DSRC radio. Under the light-duty DSRC program, an agreement has been 

established between USDOT and a consortium of light-duty vehicle manufacturers (known as the 

Vehicle Infrastructure Integration Consortium or VIIC) to jointly develop and deploy DSRC 

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technology. The VIIC is focused on integrating the DSRC radio into a light-duty vehicle 

architecture and developing safety and non-safety applications targeted at light-duty motorists. 

Most of these applications are common to heavy-duty vehicles as well (e.g., traffic information 

advisories, intersection collision avoidance, financial transactions, electronic signage, and 

electronic brake lights). 

However, the commercial motor vehicle industry will require unique applications, including: 

• Wireless safety inspections (as described in this Report) 

• Dynamic emission inspections (per EPA proposals) 

• Low-bridge warnings: The infrastructure broadcasting the height of the bridge to 

approaching vehicles and messages sent by the truck that automatically warn the driver 

whether or not he/she has sufficient clearance 

• Lane departure warning assist: The accuracy and efficiency of onboard LDWS can be 

enhanced by having the infrastructure broadcast precise lane geometry and road maps 

• Rollover warning assist: Rollover and stability control systems can also be enhanced by 

having a roadside beacon broadcast details about road conditions, as well as curve 

geometry and inclination 

• Electronic signage for CMVs: The infrastructure would broadcast information specific 

to the needs of CMVs, including the availability of commercial vehicle parking spaces at 

the next exit, availability and price of diesel fuel, and availability of various types of 

maintenance 

• Open-road tolling and electronic commerce: DSRC technology permits the 

development of standardized, open-road tolling applications that would allow trucks (and 

automobiles) to bypass all toll plazas. It would allow the highway operator to develop 

highly tailored pricing structures based on vehicle type and roadway usage. The DSRC 

technology also provides electronic payment applications that would permit truckers to 

pay for various services (including fuel) in a more convenient and automated manner 

• Electronic Freight Manifest. The DSRC technology and infrastructure will also support 

the secure downloading by multiple vehicles (at highway speeds) of complete onboard 

bills-of-lading and freight manifest data. Such capability could be leveraged at various 

intermodal transfer points to improve efficiency of load consignments and increase 

throughput 

• Numerous other safety and non-safety applications (developed to leverage the 

standardized DSRC communication platform). 

In addition to the above, the needs of other Federal agencies could be accommodated by the VII 

technology platform. For example, TSA is interested in more effectively tracking the movement 

of hazardous shipments, and U.S. Customs and Border Protection is interested in improving the 

efficiency of CMV crossings at the border through more advanced exchange of information. A 

standardized means of wirelessly transmitting information from the vehicle to the roadside is an 

important and necessary first step. 

The DSRC infrastructure could be leveraged for private-sector, operationally-focused 

applications that allow for communications of trip, location, manifest, and other data. In other 

words, while considerable infrastructure network design and analysis will be required, it is likely 

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69 

that the DSRC infrastructure could be leveraged by fleets that currently do not subscribe to a 

long-distance telematic service provider to communicate with their vehicles. 

The potential safety and non-safety benefits for the trucking industry from deploying DSRC 

would appear to be at least equal to those for the light-duty sector. Therefore, FMCSA could 

consider engaging the heavy-vehicle sector in a cooperative partnership arrangement to integrate 

DSRC radios into the heavy-vehicle architecture and to develop and demonstrate applications 

focused on the commercial motor vehicle sector. Such applications would eventually include 

wireless vehicle inspections. A consortium of truck manufacturers could be engaged to lead the 

technical development (much like the current light-duty VIIC), and fleets could be engaged to 

help lead development and demonstration of safety and non-safety applications. The highestlevel objectives of the Commercial Vehicle Infrastructure Integration (CVII) program would be 

to: 

• Address and resolve technical issues associated with DSRC integration into a heavy-duty 

vehicle platform 

• Showcase important safety and non-safety applications unique to the commercial vehicle 

sector (including wireless vehicle inspections) 

• Address and resolve privacy, security, and tampering concerns important to the 

commercial trucking and safety enforcement communities 

• Identify need and opportunities for standardizing categories of message sets to support 

safety applications, emission inspections, security applications, and/or unique message 

sets for hazardous material shipments and others 

• Provide additional insight into requirements for the IT and communications infrastructure 

needed to support the applications 

• Provide additional insight into requirements for initial wireless access points (locations of 

roadside units) to serve the commercial vehicle industry. 

Like the light-duty DSRC program, the overall goal of the CVII program would be to complete 

sufficient testing and demonstration so that all key commercial-sector stakeholders (including 

truck OEMs, fleets, States, and Federal agencies) have sufficient information to make a 

consensus decision regarding widespread deployment and adoption of the DSRC technology. For 

the light-duty program, this date falls in late 2008. A unique schedule and set of activities for the 

CMV VII program would need to be developed that paralleled, but did not overlap, the light-duty 

program. 

This deployment strategy hinges on building an overall business case with the commercial 

vehicle sector to the effect that DSRC technology offers substantial benefits for improving 

safety, enhancing mobility, supporting security initiatives, and providing a standardized 

communications link to commercial vehicles that can be used by both the private and public 

sectors. To help encourage participation in an overall CVII program, FMCSA and the USDOT 

would need to enter into a public-private partnership with truck OEMs, fleets, and others, and 

support the program on a shared-cost basis. Preliminary discussions with a limited number of 

fleets and heavy-duty vehicle OEMs indicate a strong interest in working with USDOT on VII 

initiatives.