Good afternoon, everyone. This is Daniel Fisher. I'm AAD's Vice President of Government Affairs. Welcome to today's webinar on electronic logging devices. We're pleased to be joined by two officials from the Federal Motor Carrier Safety Administration. I'm not going to prolong this by talking anymore, so I'll go ahead and turn it over to our two presenters. Thank you. Thank you, Daniel. Good afternoon, everyone. This is Daniel Fisher. I'm AAD's Vice President of Government Affairs. Welcome to today's webinar on electronic logging devices. We're pleased to be joined by two officials from the Federal Motor Carrier Safety Administration. I'm not going to prolong this by talking anymore, so I'll go ahead and turn it over to our two presenters. Thank you, Daniel. Good afternoon, everyone. This is Daniel Fisher. I'm AAD's Vice President of Government Affairs. from the Federal Motor Carrier Safety Administration. I'm not going to prolong this by talking anymore, so I'll go ahead and turn it over to our two presenters. But first, I will introduce them. And just a couple reminders, though, before I do, you do have the option to ask questions. I know many of you submitted questions in advance of the webinar, which is great. We appreciate that. And we'll be getting to those questions during the Q&A session. But if you do want to submit questions, you can do so in the box at the bottom left in the chat box, and I will see those, and then I will add those to the questions I'll be asking at the end. But feel free to submit them as we go along, as you have them, and we will get to those questions at the end. Just a reminder, the webinar will be recorded and available for on-demand viewing as soon as it concludes. So I'm pleased to welcome Denise Wagoner. She is a Transportation Specialist with the Federal Motor Carrier Safety Administration's Enforcement Division. Prior to becoming a Transportation Specialist with the FMTSA Enforcement Division, Denise worked as a safety investigator for three years with the Federal Motor Carrier Safety Administration's West Virginia Division. Joining Denise is Danielle Smith, who's also a Transportation Specialist, but with the Commercial Passenger Carrier Division in Washington, D.C., and she also worked as a field investigator in the Tennessee Division for a total of more than 27 years with the Federal Motor Carrier Safety Administration. She served as a subject matter expert for the Electronic Logging Device Rulemaking Team and is now an active member of the Electronic Logging Device Core Implementation Team. So Denise, Danielle, we're pleased to have you, and I'll turn over to Denise, I believe, to start. As I said, if there are any questions, please submit them in the chat box, and if you've already submitted your questions, we will get to those at the end. Denise? Thank you, Daniel. So good afternoon, everyone. As Daniel has already mentioned, my name is Denise Wagoner, and I am a Transportation Specialist with the Federal Motor Carrier Safety Administration's Enforcement Division. I would first like to thank Daniel and the Associated Equipment Distributors Association for allowing the Federal Motor Carrier Safety Administration to present this webinar to its members. Today, my colleague and I, Daniel Smith, will provide information on why the ELD rule was implemented, ELD exemptions, intrastate implementation, Phase 1 of the ELD process, Phase 2 of the process, the ELD checklist, a driver's responsibility, and a carrier's responsibility. The Electronic Logging Device ELD rule was implemented to improve commercial motor vehicle safety and reduce the overall paperwork burden for both motor carriers and drivers by increasing the use of ELDs within the motor carrier industry, which will, in turn, improve compliance with the applicable hours of service rule. So the ELD rule applies to most motor carriers and drivers who are currently required to prepare and retain paper rods to comply with the hours of service regulations under Part 395. However, the ELD rule does allow for limited exemptions to the ELD mandate. As indicated in 49 CFR Section 395.8A1E, drivers who operate using the time card exception, which is also known as the 100 air mile radius for CDL-required operated commercial motor vehicles, and or the 150 air mile radius for CDL-required operated commercial motor vehicles, and or the 150 air mile radius for non-CDL-required operated commercial motor vehicles, are not required to keep rods and, therefore, are not required to use ELDs. Drivers that are required to prepare paper rods for not more than eight days during any revolving 30-day period are also exempt from the ELD mandate. Now, the 30-day period is not restricted to a single month, but applies to any 30-day period. For example, November 15th to December 15th is considered a 30-day period. Also, drivers who conduct drive-away, tow-away operations, when the vehicle is the commodity being delivered or the vehicle being transported, is a motor home, are not required to keep rods and, therefore, are not required to use ELDs. Drivers who conduct drive-away, tow-away operations, when the vehicle being transported, is a motor home or a recreation vehicle trailer, are also exempt from the ELD mandate. In addition, vehicles manufactured before model year 2000 are also exempt from the ELD mandate. The vehicle manufactured model year is generally the manufactured year reflected in the vehicle identification number as recorded on the vehicle registration. If the manufactured model year is of the year 2000 or newer, then the vehicle is subject to the ELD rule. However, there may be cases when the vehicle registration reflects a model year of 2000 or newer, but the engine installed in the vehicle is older than the model year 2000. Now, let's discuss intrastate implementation. Intrastate hours of service rules are very similar to the federal hours of service rules, but there may be some differences. Intrastate drivers should contact their state CMV enforcement authorities for that information. Now, it's very important to note that if a driver or carrier is deemed to be exempt from the ELD mandate by his or her state, he or she will become subject to the ELD mandate if he or she operates a commercial motor vehicle in interstate commerce and does not qualify for any of the ELD or hours of service federal exemptions. Now, interstate commerce is defined as trade, traffic, or transportation in the United States between a place in a state and a place outside of such state, including a place outside of the United States, also between two places in a state through another state or a place outside of the United States, or between two places in a state as part of trade, traffic, or transportation originating or terminating outside of the state or the United States. Now, we'll discuss phase one of the ELD implementation, February 16, 2016 through December 18, 2017. Now, the following is a chart that has been provided to the field to assist them with differentiating the permitted devices. Now, an ALBRD, which is defined in 49 CFR 395.2, as an electric, electronic, or electromechanical or mechanical device capable of recording a driver's duty status information accurately and automatically as required by 49 CFR section 395.15. The device must be integrally synchronized with specific operations of the CMD in which it is installed. Now, at a minimum, the device must record engine use, road speed, miles driven, the date, and time of day. Now, logging software programs and applications, as described in the Federal Register Notice titled, Hours of Service for Commercial Motor Vehicle Drivers, Regulatory Guidance Concerning Records of Duty Status Generated by Logging Software Programs, is defined as logging software programs and applications are not ALBRDs. However, they may be used as an alternative to handwritten RODs. Drivers can manually enter their hours of service information using the application or software program on the device and then manually or electronically sign the RODs at the end of each 24-hour period to certify that all required entries are true and correct. The display and output from these devices must meet the requirements in 49 CFR section 395.8. An ELD is a device or technology that automatically records a driver's driving time and facilitates the accurate recording of the driver's hours of service and meets the technical specifications of the ELD rule. An ELD must be integrally synchronized with the engine of the commercial motor vehicle, CMV. An ELD must be certified and registered with SMCSA. Now, during Phase 1, if the vehicle is equipped with an electronic device and the driver opts to use paper RODs, the driver must declare the official method of how he or she is recording their hours of service to the inspector. The inspector can contact the driver's employer to confirm the method, but the inspector must proceed with the inspection if the inspector cannot get a hold of the employer. The inspector may check the paper RODs against the electronic device and cite any discovered violations. During Phase 1, ELDs will be treated like devices installed with logging software except the form and manner requirement. The ELD rule does not take effect until December 18, 2017. This chart here illustrates the applicable citation per device during Phase 1 of the ELD Implementation Plan. Next, we'll discuss Phase 2 of the ELD Implementation Process. The slated dates are December 18, 2017 through December 16, 2019. So during Phase 2, logging software programs and applications can no longer be used by motor carriers subject to the ELD rule. And that's the difference you'll note between Phase 1 and Phase 2. Logging software programs and applications can no longer be used by motor carriers subject to the ELD rule. Now when purchasing an ELD, please ensure that the ELD is registered on the FMC registration website. And you'll see that registration website right up there on the screen. Now you also want to consider the specific needs of your operation when choosing an ELD. Now, here you'll see a screenshot of the ELD list, and this is a site you want to go to to ensure the vendor or manufacturer is on the list. Now, if the device or ELD solution is not on the list, then it's not an ELD, and you should definitely not purchase it. Now, let's discuss the driver's responsibilities. The driver has a responsibility of maintaining the user's manual, data transfer instruction sheet, the ELD malfunction instruction sheet. They also have a responsibility to supply, to maintain a supply of blank record of duty status graph grids, and any supporting documents in the driver's possession must be provided to the state's official upon request. Now, the drivers must add the following manually, off-duty or off, sleep or birth, on-duty not driving, any annotations, driver's location, commercial motor vehicle power unit number, trailer number, and shipping document number. Now, the motor carrier can add the last three items, but the driver must have the ability to change that date. Now, during the transitioning to ELDs from December 10th through the 17th, 2017, the driver can produce their hours of service via the following methods, paper logs, printout form device installed with the logging software, a printout form, and automatic onboard recording device, if now using an ELD, and the driver may insert missing data into the ELD. These options are also available to drivers that work for multiple employers. The device must be able to transfer data via one of the two options and both methods within each option. So, the first option is a telematics transfer via wireless web service and email method. The second option is a local transfer that must electronically transfer data to an authorized safety official's laptop on demand via a universal serial bus, which is also known as a USB device, and Bluetooth method. Now, if all else fails, if an electronic data transfer cannot be performed, safety officials will verify hours of service compliance via display screen or printout, whichever the device can do. The rule does not address, and I'll say this again, the rule does not address a motor carrier providing a driver's hours of service via fax or email. If an ELD malfunctions, and this could possibly happen, it may happen, so if an ELD malfunctions, a driver must, one, provide written notice to motor carriers within 24 hours, and they should probably also include an electronic message, such as an email and or fleet management system message. Two, the driver should reconstruct the rods for the current 24-hour period and the previous seven days, and three, the driver should continue to manually prepare records of duty status. Now, the motor carrier has eight days from receiving notice of the malfunction to repair, replace, and or service the malfunctioning ELD. Now, during that time, the driver must record their hours of service on a paper log. So, next, you'll hear from Danielle Smith, my colleague, and she will discuss the motor carrier's responsibilities. Okay, thank you, Denise. Hello, everyone. Thank you for joining us today. Denise went over the implementation phases and driver responsibilities, so now let's look at the motor carrier responsibilities. Okay, just like the ELD rule did not change the hours of service rule, the record retention requirements stayed the same as well. The carrier must keep any paper logs that were required to be prepared, maybe during a malfunction or for a driver who no longer met an exception, but infrequent enough to fall below the ELD requirement. If a driver's been using logging software applications, those printouts should be retained as well, and if a driver moves from an AOBRD to an ELD, those printed AOBRD records should be retained. To sum it up, a carrier must retain a driver's record of duty status in whichever form acceptable at the time recorded, and they must be retained for six months. Okay, driver accounts. The motor carrier must establish a driver account for all drivers subject to the ELD use and support personnel who will be responsible for managing ELD data. Keep in mind, account sharing is not allowed. For example, the motor carrier cannot create a single account for multiple persons to use. Let's look at the driver account first. A driver's account is only allowed to record ELD data. It must not permit the driver to make administrative changes, and only one driver account per driver is allowed within the ELD system per motor carrier. The driver account is required to be configured using the driver's first and last name as reflected on the driver's license, and the driver must also have a unique ELD username assigned by the motor carrier for the account. The driver's valid driver's license number and the state or jurisdiction that issued the license. Support personnel accounts. They're not required to be associated with the driver's license number like the driver account, but they must contain the first and last name of the individual as reflected on a government ID. They, too, must have a unique ELD username assigned by the motor carrier, and a support personnel account is only allowed to make administrative changes, access and manage ELD records, or propose edits to a driver's record. It may not record ELD data. Now, for this reason, if you have an ELD support person that also drives, they would have two accounts, one administrative account and one driver account. Now, an exempt driver, that means the driver is exempt from using the ELD that may be installed on a vehicle which he or she is operating. The best example of this would be a 100-air mile radius driver who operates on an occasion their road tractor to make local movements between facilities. That ELD installed on the tractor is required to record all movement of the vehicle. The movement is still captured by the ELD, but is assigned to the exempt driver account rather than the unidentified driver profile. We'll talk about that next. But this relieves the road driver from having to review and decline the unidentified driving on the ELD device, and it also decreases the motor carrier's administrative burden by not having to annotate those records. So, the unidentified driving I just mentioned. The term unidentified driving refers to the non-authenticated operation of an unidentified commercial motor vehicle as soon as the vehicle is in motion if no driver is logged into the ELD. The ELD is required to provide a warning to the driver to pull over and log in. And if this doesn't happen, the ELD records an unidentified driver diagnostic event. Unidentified driving remains on the ELD until the motor carrier and the driver review the record and they are assigned to the true and correct owner. If unidentified driving is not assumed by a driver, the motor carrier must make an annotation explaining why the unidentified driving was not assigned. You know, a reason for this may be the vehicle was driven by a mechanic that sits with a third-party, say, maintenance facility for repairs during, you know, a test drive. So, they would annotate that unidentified, oh, I'm sorry, I'm getting my tongue tied up, that unidentified driving as such. And then the carrier must maintain unidentified driving records for six months, and those records must be provided to the requesting safety official. Okay, talking about a company policy on unidentified driving. You know, first of all, we need to look at unidentified driving prevention. So, the least number of events, the less work we have in front of us. So, first of all, drivers need to know when to log in. When a driver begins his or her shift, log into the ELD. Motor carriers should require drivers to log into the ELD prior to them moving the vehicle, even if it's just a short distance. Even more importantly, especially when split seating, make sure you log out. Driving time is not allowed to be reduced. A driver with driving time recorded to their daily log in error, you know, other than a team operation, can only annotate the error, and this causes confusion for all. It's also suggested to create an exempt driver account to minimize the unidentified driving records. Drivers can decline assigned driving. So, a good business practice for motor carriers is to establish an internal policy in addressing matters such as safety. Unidentified driving can attribute to hours of service violations, and drivers should also note that if they do not accept unidentified driving as prompted by the ELD, and it is later determined that the drive time did, in fact, belong to them, adding the data to their record of duty status could result in hours of service violations. Okay, editing the ELD data. Now, that record of duty status belongs to the driver, and that driver certifies the entries are true and correct. So, for this reason, a carrier can only request edits to a driver's record of duty status. All edits must be annotated and the original data maintained. A driver's record of duty status must be annotated and the original data maintained. All edits must be annotated and the original data maintained. And once again, driving time cannot be shortened. Only in a team operation, driving time may be reassigned to the correct driver. All right, records to be maintained. Now, once again, the record retention requirements stay the same. The motor carrier must maintain a list of users, any unidentified driving records along with the appropriate annotations, original ELD data if edits are made, and any paper logs that were generated. Okay, for ELD malfunctions, Denise discussed about what a driver should do, you know, when you have a malfunction of the ELD, but for the most part, you know, as we said earlier, if the ELD malfunctions, the driver's got to provide that written notice to the motor carrier within 24 hours. So, the motor carrier is required to maintain that documentation as well as the records of duty status required, you know, for the reconstruction and the paper records of duty status required to be made, generated at that time. The motor carrier's got eight days from receiving the notice of the malfunction to repair, replace, and or service the malfunction in ELD. And if a catastrophic event happens, such as every device in the fleet goes down, and this is going to take much more than eight days, within five days of being notified by the driver of the malfunction, a carrier can request an extension to repair through the division office located in their state. And automatic onboard recording devices, as we said, you know, during the grandfather period, you know, we will still see continued use of AOBRDs, and these devices, the AOBRDs, are not subject to the technical specifications in the ELD rule. They are subject to the limited technical specification in Part 395.15. You know, after the compliance date, during the grandfather period, if a carrier expands the size of their fleet, then they must install ELDs. However, if they are just replacing equipment in their fleet, then they may reinstall the AOBRD until the 2019 full compliance date. Okay, this concludes this portion of the presentation. So, if you have questions afterwards, we have an email, mailboxeldatdot.gov, that you may submit your questions to. And then also, on the ELD website, this is where you'll find pretty much any information that you could ever want, all things ELD. If you go to our website, and you'll see the icons at the top scrolling across, you'll click on the paperless log, and you'll click on electronic logging devices. And then once you pull that website up, there's everything that you could ever want to know about the ELD, and there will be multiple tabs over on the left-hand side, from frequently asked questions, to the manufacturers, to our website, to where you can look for a compliant ELD. So, this will be a very useful website for you. Also, there's training and events listed on there. So, if you want more information about ELDs, there's a full webinar on phase one, and there's also another webinar on phase two, as well as a town hall meeting that we had back in May for technical specifications. So, at this time, I'll turn this back over to Daniel and Denise, so we can start the question session. Great. Thank you, Daniel and Denise, for that great presentation. So, I'm going to jump into the questions that were submitted to me via email prior, and then I see there's a couple questions that have popped up in the text box, chat box, and if anyone else has any questions, please put them in there as soon as possible. So, question number one. Are field text drive F550 ram 5500 size trucks of about 19,500 GVW? Most of our travel is less than a hundred mile radius. We do not use logbooks unless we travel across state lines into Nevada. The scales sometimes require logbooks. Do we need to install ELDs, or are we exempt? All right, Daniel. I'll go ahead and take that one. That's a very interesting question. So, based on the information provided, the driver and or carrier is exempt from the ELD mandate under the 150 air mile radius short haul exemption. The exemption states that drivers who operate using the time record exception in accordance with 49 CFR 395.1 are not required to keep rods and therefore are not required to use ELDs. Now, although the Nevada scales may sometimes require logs, FMCSA does not require that a driver and or carrier prepare or maintain logs if they are operating under the 150 air mile radius short haul exemption. So, the answer to that question is no, based on the information provided. Excellent. I think we'll, we like that answer. So, maybe we can keep answering those. We are a construction equipment dealer and our service repair truck fleet consists of approximately 12 vehicles ranging from 7,500 to 73,280 pounds. Only four of the trucks are over 26,000 pounds GVW. We have a non-IFTA MCRT account in Pennsylvania. About 95% of our driving is within the state. The four vehicles over 26,000 pounds GVW also have New York HUT stickers for the rare times we travel out of state. We normally travel within 90 miles of our home base, so logs are not required most of the time, maybe two or three times per month. Our driving scenario is not steady driving. Normally, the tech would drive an hour or so to a job site, then perform repair work for three to five hours, and then drive another hour back home or to a different job site. Given these circumstances, do we need to have ELDs in our vehicles? And if so, in all of them or just those over 26,000 pounds? Okay, another interesting question where the driver and their carrier may be allowed to apply to exemptions. So, based on the information provided, the driver and their carrier is exempt from the ELD mandate under the 100-150 air mile radius short haul exemption in accordance with 49 CFR 395.1. The driver is not required to keep rods and therefore are not required to use ELDs. However, when a driver operates outside of the 100-150 air mile radius of his or her home base, he or she will no longer qualify for the short haul exemption. Okay, so we're going to go into the second exemption. So, during the two or three times a month that the driver does operate outside of the 100-150 air mile radius, the driver will be required to maintain paper logs. However, he or she will be exempt from the ELD mandate based on the eight-day, 30-day period exemption. Now, this exemption states that the driver, that drivers who are required to keep rods for no more than eight days during any 30-day period are exempt from the ELD rule. So, this question is two parts. First, we have to apply the 100-150 air mile radius short haul exemption. However, when that driver operates outside of that radius, then we're going to go into the eight-day, 30-day period and the driver will be exempt as long as they do not require a rod more than eight days out of the 30-day period. All right, well, that sounds like another good answer that we like to hear. Let's go on to the next question. After our service trucks are driven to a job and the driver technician gets out to perform repairs to some equipment, but the truck may remain idling sometimes for several hours if the crane-mounted truck is utilized, since ELDs record engine running time, how would this situation affect our tech and his driving time? How can idling be differentiated from actual driving time? Okay, so, when the duty status is set to driving and the commercial motor vehicle has not been in motion for five consecutive minutes, the ELD must prompt the driver to confirm a continued driving status or enter the proper duty status. So, if the driver does not respond to the ELD prompt within one minute, the ELD must automatically switch the duty status to on duty, not driving. And that time will not be counted towards driving time, but it will affect the 14-hour period. All right. If an ELD is not required on a truck because it drives almost exclusively intrastate within 70 air miles of home base and does not require logs more than one or two times per month, would that truck be required to have an ELD on board should it have occasion to travel out of state a day or two per month? Okay. Again, based on the information provided, the driver and their carrier may be exempt from the ELD mandate based on the 100-150 air mile radius short haul exemption and or the eight-day, 30-day period exemption, if it applies, if it's applicable. But the information provided, I can't give a solid answer. But like I said, the driver may be exempt based on the 100-150 air mile radius or the eight-day, 30-day period exemption. All right. Well, maybe if the questioner who submitted that one would want to clarify in the chat box, we provide a little more information. We can maybe better address that. That would be perfect. Okay. We have a branch located right on the state border. Our short haul service vehicles go back and forth across state lines. They are exempted by the 100-mile short haul exception. Does crossing state lines change this exemption? This is a very straightforward question and a very straightforward answer. The answer is no. Crossing state lines will not change any of the ELD exemptions. Okay. What are differences in the ELD regulations between service trucks less than 26,000 GVW and those above 26,000 GVW or heavier? Okay. So the Federal Motor Carrier Safety Administration ELD rule and its exemptions does not distinguish or specify service trucks. So nor does the rule distinguish or specify any differences between the different weight categories of a commercial motor vehicle. All right. How do state tolerance rules affect Federal Motor Carrier Safety Administration ELD rules? Okay. So state tolerance rules for ELDs do not affect FMCSA ELD rules. Drivers and or chairs that operate in interstate commerce are regulated by the FMCSA rules and regulations. Okay. Now drivers that operate solely intrastate are regulated by the specific state that they operate within. So intrastate hours of service rules are very similar to the Federal rules, but there may be some differences. Intrastate drivers should definitely contact their state CMV enforcement authorities for additional information pertaining to a state's specific rules and regulations that address hours of service and ELD requirements. All right. None of our trucks deliver goods for hire. They are mobile service trucks used to repair equipment. Does this change the ELD requirement? You know what, Daniel? I get this question a lot. So the ELD mandate did not change the FMCSA hours of service rules and regulations. So if a driver operates in interstate commerce, then he or she is subject to the FMCSA hours of service rules and regulations. Hours of service rules and regulations. So therefore, if the driver does not qualify for any of the ELD exemptions, you know, the 100, 150 air mile radius, the 8-day, 30-day, the drive-away, tow-away, the vehicle manufactured before calendar year 2000, then he or she will be subject to the ELD rule. All right. When does the 150 air mile exemption apply versus the 100 air mile exemption? Another great question. So in accordance with 49 CFR 395.1 E1, the 100 air mile radius exception applies to a commercial motor vehicle that requires a commercial driver's license. Okay. Now, in accordance with 49 CFR 395.1 E2, the 150 air mile radius exception applies to a property-carrying commercial motor vehicle that does not require a commercial driver's license. All right. If requested, are agencies such as state DOTs or federal motor companies that require a federal motor carrier safety administration required to give a written opinion on whether a fleet is ELD exempt or not based on our fleet application data? Okay. Another straightforward question. I have a straightforward answer for that. No. The federal motor carrier safety administration is not required to give a written opinion on whether a carrier's fleet is ELD exempt. All right. So let me get to some of the questions here in the text box, which I saw a couple. If I'm not required to have an electronic logging device because I typically stand 100 miles, 150 miles from the shop, non-CDL, but I have to go outside of that 150 miles to a job site, does every day I am gone count against my eight days for the exemption, or is it only days I'm driving that count against that eight days? Danielle, do you want to take that one? Sure. I'll go ahead and take that one. Studying that question a little bit, one of the things I see here by saying you go outside of the radius, maybe not driving versus driving, so is it a possibility this person is riding with someone? So maybe we can address it both ways. Once again, if you are required to prepare a record of duty status today, more than likely you're required to use the ELD once the ELD mandate hits. Denise has discussed that 150, 100, the eight days, 30, et cetera, all of those exemptions. So when I read this, it says does every day I'm gone count against my eight days for the exemption, or is it only the days I'm driving? So during some of these days you're leaving this 150 air mile radius, if you are just riding as a helper with a driver and you have no driving duties, then you're not required to prepare the record of duty status. If you do have the driving duties, at any time during that day, and you're outside that 150 air miles, then you would be required to prepare a record of duty status. So even though those days that you're out of the radius, but you're not driving, those hours still count towards your 60, 70, et cetera, but they're not required to have a record of duty status, so that would not count towards your eight days. Only driving days that you're required to have a record of duty status count towards that 30-day period. Hopefully that addresses that question correctly. All right, well, we have a couple more questions to get to, so if there's any clarification or follow-up from that individual, feel free to submit that and we will get to that. Does each exempt driver need to have an account set up on the ELD in order to account for the mileage accrued during yard moves, or can there be one exempt driver account for this purpose? Mechanics, service, yard moves, et cetera. Okay, the driver account, the exempt account, is a driver account, so only one driver per account. When you set up an exempt driver account, it is a driver account, and so that account must be pre-configured for that exempt status. So if you've got a driver that stays within the 100-air mile radius, for example, then it's going to need to leave the 100-air mile radius, and they're set up as an exempt driver, then you'll have to go back in and pre-configure that for an ELD user account. Once they get back into the 100-air mile radius, you pre-configure it to be an exempt driver account. So you cannot have an exempt driver account for multiple movements amongst the same driver amongst multiple drivers. Now, I notice that you're focusing on yard moves. So, you know, we do not allow any algorithm or any type of geofencing to make changes to a driver's record of duty status. However, if you can make this scenario work into the supervisory approval part portion, and we mentioned the unidentified driving. So if you put a geofence around your yard, and it does meet the definition of a yard where there's not public access, et cetera, and if you do not want the drivers to have to move to log in each time to make a yard movement of this equipment, you can let that go to the unidentified driving, then your back office system can compile all of those movements into that geofence. The supervisor would go through those events and verify that they all did, in fact, occur on that yard and assign those to yard movements and annotate them as such. So you meet all of those requirements, you know, for the unidentified driving, and you've made all those multiple movements a little bit easier to manage. Like I said, you cannot have multiple drivers for an exempt driver account, but that is as long as you've got all of those supervisory elements for reviewing those movements within the yard and then, you know, maybe batch assigning those and annotation of yard movement, that would meet the ELD requirement. The only other problem you're going to have with that is if you try to do that when your road drivers, say, get back onto that vehicle, that unidentified driving is going to stay on that vehicle until it is annotated or assigned to the proper driver. So it's going to be prompted to that driver once they log into that ELD that unidentified driving exists. So that driver is going to have to decline that before, you know, they can continue on. So that's just going to add a little bit more of an administrative process, I guess you would say. But that does give you two different scenarios. So if you don't want to put that burden on the road driver, each person that makes a yard movement should have their own account and should log into that vehicle before they make that movement and then log out. So I hope that answers that question for you. All right. Well, if there's any more clarification, you submit it via the chat. We're starting to get some follow-ups to some of the questions, but I'll start with one that is new before we get to some of the follow-ups. Can you clarify the 14-hour rule? If you're exempt from the ELD requirements, do you need to be following the 14-hour rule? Once again, the ELD did not change the hours of service rule. It only changed the way we record hours of service. So your 11, 14, 60, 70 hour, your 30-minute break, your split sleeper provision, all of that stays the same. So basically what the 14-hour rule is, it's a 14-hour clock. So once you come on duty, you have 14 hours of on-duty and driving before you have to take your 10-hour break again. So the hours of service didn't change. And it doesn't matter if you're exempt from ELD rule or not. You would have to be exempt from the hours of service requirement. All right. And then this is going to be a follow-up to question number two that we answered that was submitted earlier. So as a follow-up question, if we normally operate under the 100-mile exemption but have occasion to drive into a neighboring state that is beyond the 100-mile radius, must we have an ELD installed for that instance, or would a paper log be sufficient? Okay. As pertaining, oh, thank you, Daniel. I'm going to go ahead and follow up to this one. So depending, it depends. A paper log would be sufficient if the driver has not already operated more than eight times in a 30-day period. A paper log would be sufficient. However, if the driver has already met the eight-day 30 and he or she is on his or her ninth day, then a paper log is no longer sufficient and an ELD would be required. Okay. And this is a, okay, so let me, before I get to this next question, let me go back, let's see. Okay, actually, let me go to, let me go to this next question first. So this is in reply to the question a couple of questions ago regarding the 150 miles from the shop, non-CDL. Okay. The situation is that I have mechanics that drive service trucks from time to time. They need to go outside the 150-mile radius and need to complete a logbook. So if he stays at a hotel outside of the 150-mile radius to stay close by a job site for a week, does he need to complete a log for each day driving to the job site from the hotel? If he does, I assume that each day would count against the eight-day exact time. One thing, let me clarify there. In this situation, we've got an interpretation of the hours of service that will benefit you here. A driver that normally reports to a work reporting location, of course, would have that 150-mile radius there. In this scenario, when this mechanic drives to another location outside that 150-mile radius, yes, you are correct in saying that he needs to complete a log for that day. Now, where this is going to come in to benefit you is that new location becomes that driver's new work reporting location. So they may take that 150-mile radius exception from that new work reporting location. So they would log the trip to the work reporting location, and then they would log the trip back to that work reporting location, then they could take that 150-air-mile radius exception again, and then they would have to log that trip back to their other work reporting location, and then they could take that 150-air-mile radius exception there. So you will find that interpretation in the Part 395.1, where it talks about the 150-air-mile radius exceptions for that section. You will find that there, so that will benefit you. All right. What happens if the truck is out of the yard on service at, say, Peterbilt? How do you account for this mileage? Okay, now, as you know, any movement of that commercial motor vehicle is going to be recorded. So that movement will go to the unidentified driving. And because that personnel that came and picked that truck up, or that mechanic that is driving that Peterbilt on, say, a test drive, you would basically annotate those unassigned movement of that vehicle as it being at that third-party facility. And then, of course, you would have the repair bill or the work order, et cetera, to back that up in the event it was questioned. So any unidentified driving that can't be assigned to a driver, which this driver doesn't belong to you, then you would just annotate that accordingly. All right. Oh, I'm sorry. I was just going to clarify. You hear us say the word annotate a lot, and basically that is just a remark. Just like the red and white logs down at the bottom, when you make a duty status change, you write down at the bottom your remarks. So any time you hear us use the word annotate, that's what we're referring to. OK, Daniel, I just wanted to clarify that. No, no. Thank you so much for that. That's very helpful. I don't see any more questions in the chat box, so we will go ahead and wrap up here. First of all, thank you very much to our presenters, Denise Wagner and Danielle Smith. Greatly appreciate this very informative webinar. And then I encourage everyone, if they have any more questions, I'm assuming you can email compliancequestions to ELD at DOT.gov. Is that correct? That's what that's for? And someone at Federal Motor Carrier will get back to them to answer those questions. Is that correct? Yes, Daniel. That's correct. OK. OK. So feel free. It sounds like the federal officials want to have a good dialogue and want to make sure those who are complying are in compliance and those who don't need to comply are clear they don't need to comply. So we look forward to continuing this relationship with Federal Motor Carrier and appreciate everyone joining the webinar, particularly our presenters. Just a reminder that the recording of the webinar will be available shortly. Others in your company can also register and view for free through the LMS. With that, thanks again, everyone, for joining and have a great day. Bye-bye.

webinar

ELD rule

exemptions

driver responsibilities

carrier responsibilities

ELD implementation process

certified ELD

ELD malfunctions

FMCSA website