Four more trucking groups and fleets have requested the FMCSA for a five-year ELD mandate exemption. These four trucking groups and fleets are:
- American Disposal Services (ADS) — a trash hauling and recycling fleet
- Cudd Energy Services (CES) — an oilfield service fleetWe
- The Agricultural Retailers Association (ARA)
- The Association of Energy Service Companies (AESC), which includes well service rig contractors
Let’s discuss each of these exemption requests.
Cudd Energy Services (CES)
Cudd Energy Services (CES) is requesting the exemption that would cover approximately 1,858 trucks and 939 drivers. The requested exemption is for “specially-trained drivers of commercial motor vehicles specially constructed to service oil wells.”
These drivers don’t qualify for the 100 air-mile radius exemption. Therefore, they are required to use compliant electronic logging devices.
CES says that certain oilfield locations have poor cell service, which would prevent drivers from logging into ELDs. Moreover, the company also mentions that it does plan to install equipment that would allow tracking of its trucks when communication capabilities exist, but those units would not be able to qualify as AOBRDs or ELDs.
The FMCSA is seeking comments on the exemption request by CES. Comments can be made until Feb 1, 2018.
The Agricultural Retailers Association (ARA)
The Agricultural Retailers Association (ARA), which relies on trucks to deliver their products and services to farms, requests the ELD exemption for its member companies. They argue that the ELD mandate puts “undue economic and other burdens.”
The group says that its members require additional guidance on the ELD rule. Moreover, the group also adds that ELD manufacturers and vendors don’t offer devices that meet their needs.
The FMCSA is seeking comments on the exemption request by ARA. Comments can be made until Jan 29, 2018.
The Association of Energy Service Companies (AESC)
The Association of Energy Service Companies (AESC) requested the exemption on behalf of well service rig contractors.
These contractors usually qualify for the short-haul exemption but sometimes exceed the short-haul limitation. The group says that without the exemption, these drivers would have to monitor the number of days they exceed the short-haul exemption requirements.
The group also argues that their drivers can spend two to five days parked at a single location and spend very little time on public roads. The AESC mentions that they would continue to maintain paper logs when required.
The FMCSA is seeking comments on the exemption request by AESC. Comments can be made until Feb 1, 2018.
American Disposal Services (ADS)
American Disposal Services (ADS) is requesting the exemption from the ELD mandate as well as from keeping paper logs.
According to the company, it has more than 300 CDL drivers who operate under the multiple-stop rule. On average, the company drivers have between 800 and 1200 stops per day on each route. Moreover, they pick up trash every 22 seconds.
The drivers also operate the 100 air-mile short-haul exemption, but they exceed the 12-hour limit for more than eight days in a 30-day period, which requires them to use compliant electronic logging devices.
The company claims that there is “no ELD that can accurately record driving time when the CMV makes constant short movements with the driver often exiting the vehicle.”
The Motive ELD has no problem with this and can accurately record driving time. ADS drivers can toggle to on duty or, by default, the Motive ELD keeps it as one contiguous driving event.
The FMCSA is seeking comments on the exemption request by ADS. Comments can be made until Feb 1, 2018.
It’s unlikely that the FMCSA would grant these ELD exemptions.
On the other hand, the ELD mandate is in full effect, and non-exempt truckers are required to install electronic logging devices to stay compliant.
If you haven’t installed an ELD, try Motive.