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Federal Register / Vol. 86, No. 164 / Friday, August 27, 2021 / Proposed Rules
Medical Certificates Applications Submitted in PersonOpportunity Cost of Time Table 7 illustrates the analysis of cost savings to industry as discussed in the following sections. We first determine the number of FCPs who would submit a medical certificate application in person, previously estimated by NMC at 15% of the affected population.
Therefore, the expected number of medical certificate applications submitted in person in a given year, column a t = Reduced FCPs 15%. We assume that each eligible FCP will commute an average of 27.6 minutes in each direction 10 to submit their medical certificate application to an REC, for an average total commuting time of 55.2
minutes, column c. We assume that FCPs who have a farther commute to the REC would submit the applications by mail or email. We also assume that FCPs will drive at an average speed of approximately 57 miles per hour mph based on the following calculation:
From the Department of Transportation
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10 https www.census.gov/newsroom/pressreleases/2021/one-way-travel-time-to-workrises.html.

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DOT National Traffic Speeds Survey II, Overall Speed Estimates in MPH by Road Class Free-Flow by Year, we took the mean speed of the three road classes provided: Limited access 70.5 mph, major arterial 53.28 mph, and minor arterial 47.01 mph, to obtain an average speed of 56.93 mph 70.5 +
53.28 + 47.01 3.11 Considering the estimated average speed, we assume that 55.2 minutes of commuting time will be traveled in approximately 1 hour 55.2 minutes 57 miles per hour 0.97
hrs., reflected in column b.
In order to calculate the opportunity cost of having to commute to submit a medical certificate application to an REC on a less frequent basis, we use GSAs Privately Owned Vehicle POV
Mileage Reimbursement Rates,12 which is used as a proxy for the wear and tear incurred while commuting to an REC.
As of January 2021, the reimbursement rate is $0.56 per mile, column d. We 11 Table 1. Overall Speed Estimates in MPH by Road Class Free-Flow by Year, Fact Sheet, Publication No. DOT HS 811 647, August 2012
https safety.fhwa.dot.gov/speedmgt/data_facts/.
12 https www.gsa.gov/travel/plan-book/
transportation-airfare-pov-etc/privately-ownedvehicle-pov-mileage-reimbursement-rates.

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then estimate the net reduction in timeburden hours if this proposed rule is implemented, reflected in column e t.
The net reduction in time-burden is calculated as the product of the average time it would take FCPs to commute to and from an REC, column b, and the number of FCPs that no longer have to submit a medical certificate on a given year, column a t. Hence, column e t = a t and b. Next we estimate the net reduction in distance miles avoided by FCPs who no longer have to drive to submit a medical certificate application on a given year. The net reduction in distance miles, column f t, is the product of the average miles avoided by FCP who would otherwise commute to and from an REC, column c, and the aggregate time of commuting avoided by FCPs in hours. Finally, we estimate the undiscounted cost savings of FCPs who no longer have to submit a medical certificate application in person, column g t. This column is calculated as the product of GSAs reimbursement rate, column d, and the aggregate distance miles avoided by FCPs on a given year, column e t. Hence, column g t = d f t.

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