Document
An Analysis of the Operational Costs of Trucking (annual report)
American Transportation Research Institute (ATRI)
Overview
ATRI's annual operational-cost study reports fleet-level repair-and-maintenance and downtime cost figures, including a growing share attributable to aftertreatment components.
Repeal relevance: Industry-collected cost data is the fleet-side counterweight to EPA modeled benefit estimates and belongs in any honest cost-benefit reassessment.
Counterargument: ATRI is a trade-research institute, not a federal agency; its figures are industry-collected rather than government-audited.