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Federal Register / Vol. 86, No. 192 / Thursday, October 7, 2021 / Rules and Regulations CDLIS by performing a query. The Agency also assumes that AAMVA
would not charge SDLAs additional CDLIS-related costs to receive driverspecific violation information pushed to the SDLAs by FMCSA, because CDLIS already provides daily updates of licensing information to the SDLAs.
FMCSA intends that Clearinghouse information would be an additional data element included in the daily transmission. Thus, the Agency finds that SDLAs will not incur transactionspecific CDLIS costs as a result of this rule.
Using the existing CDLIS platform will result in costs to SDLAs for initial system development, and to make the needed upgrades and modifications, as well as ongoing operations and maintenance expenses. In the NPRM, the Agency reviewed four SDLA grant applications submitted in 2017 for IT
system upgrades needed to interface and receive information from the NRCME
database, and used the grant applications as a proxy for the IT
development costs SDLAs would incur using CDLIS to access Clearinghouse information. FMCSA estimated that each SDLAs IT development costs would total approximately $200,000. In preparation for the final rule, FMCSA
reviewed 2020 Commercial Drivers License Program Implementation CDLPI grant applications and found that four States requested funds focused on the Clearinghouse, with an average cost of $300,000. However, some of these applications deal with Clearinghouse issues unrelated to this final rule, and thus FMCSA assumes that $300,000 per SDLA would be an overestimate for costs attributed to using the CDLIS platform.
SDLAs will also have the option of transmitting information from the Clearinghouse to the SDLAs using a web-based services call, which relies on cloud-based technology. The capacity for this alternative would reside within the DOTs Amazon Web Service AWS
cloud. By using the DOT AWS cloud, FMCSA would be able to make efficient updates to the system on an as-needed basis. As explained below, FMCSA
anticipates that the web-based services call IT development cost will average approximately $56,500 per SDLA.
AAMVA indicated it may incur costs for aligning the Clearinghouse information with disqualification data that already exists in CDLIS. FMCSA
will work with AAMVA to determine the necessity and extent of these costs, but for analysis purposes estimates that they would not be greater than $200,000
for development, with an annual operations and maintenance cost of
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$40,000. FMCSA will incur costs of approximately $1 million for development of a web-based services application and approximately $200,000
for annual operations and maintenance costs in years 2 through 10 of the analysis.
In order to implement a web-based services call, FMCSA will develop an interface between the Clearinghouse and the SDLAs. FMCSA envisions that the interface would connect seamlessly to the existing State interface so that when a State employee initiates the CDLIS
driver record check, the State system would simultaneously query the Clearinghouse. FMCSA would provide the application programming interface API code, or other technical specifications, and work with the States to integrate the interface into their existing technology platforms. In developing this interface, FMCSA
would leverage the current FMCSA
web-based services calls, such as Query Central, to reduce development costs wherever possible.
SDLAs using this method will incur costs for initial modification of their systems to interface with the Clearinghouse, and annual operations and maintenance expenses. FMCSA
expects that SDLAs costs to implement the interface specifications would vary based on the characteristics of their individual IT systems. The Agencys IT
staff estimated a representative initial/
upfront cost taking into account that some States currently use a mainframe application and others use an existing web interface. The initial development costs for each method to interface with the Clearinghouse were estimated based on the labor hours it would take a programmer to develop an application for use in a mainframe environment and in a non-mainframe environment.
Developing a web interface in a mainframe environment is estimated to take 1,080 hours. Developing a web interface in a non-mainframe environment is estimated to take 360
hours. These hours were monetized in 2019 dollars using the United States Department of Labor, Bureau of Labor Statistics BLS $41.61 per hour median wage for a computer programmer.29 The hourly wage is adjusted for a 73 percent fringe benefit rate obtained the from the BLS June 2019 Employer Cost of Employee Compensation News Release, 30 and a 15.9 percent overhead
rate based on indirect cost rates provided by States in their 2020 CDLPI
grant applications. The resulting labor cost is $78.53 per hour. At that hourly rate, the cost for a programmer to develop an interface in a non-mainframe environment is estimated at $28,271
360 hours $78.53 per hour and $84,812 1,080 hours $78.53 per hour in a mainframe environment. The average of these two cost estimates results in an initial IT development of $56,500 per SDLA rounded to the nearest hundred.
Because the Agency is allowing SDLAs to choose the method that works best for their particular system and framework, FMCSA continues to estimate initial IT development costs for SDLAs to be $200,000 per SDLA, accounting for both CDLIS costs of likely just below $300,000 and webbased services costs of less than $60,000. Multiplying this cost by the number of SDLAs 51 results in a total of $10.2 million $200,000 51 in SDLA initial/upfront development costs. This one-time cost occurs in the first year of the 10-year analysis period.
The Agency assumes that SDLAs annual operations and maintenance expenses would be equal to 20 percent of the upfront costs, or $40,000
$200,000 20 percent. Multiplying the operations and maintenance expense rate by the number of SDLAs resulted in $2.04 million of annual operations and maintenance expenses $40,000 51
SDLAs. The Agency assumes that SDLAs would incur operations and maintenance expenses annually, beginning in the second year of the 10year analysis period. Operations and maintenance expenses over the 10-year analysis period are estimated at $18.4
million $2.04 million 9 years.
FMCSA estimates that the total undiscounted IT development and operations and maintenance expenses over the 10-year analysis period are $28.6 million $10.2 million IT
development costs + $18.4 million operations and maintenance expenses.
In response to comments from two States, FMCSA includes a recurring cost to manage in-person and phone or email inquiries related to the downgrade procedures. The States did not indicate how long it takes to handle customer service inquiries, but FMCSA estimates that an average of one hour per downgraded license is a conservative
29 This hourly median wage is for the BLSSOC
151251 computer programmer. See https
www.bls.gov/oes/current/oes151251.htm accessed November 2, 2020.
30 BLS, Employer Cost of Employee Compensation 4th Quarter News Release, Table 4employer Costs for Employee Compensation for
private industry workers by occupational and industry group, available at https www.bls.gov/
news.release/archives/ecec_03192020.pdf accessed Nov. 2, 2020. The fringe benefit rate is the ratio of hourly wage for average hourly wage for a private industry worker and the associated hourly benefit rate 73 percent = $25.85/14.

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