TRALA To Hold Conference Call October 19 with FMCSA Regarding ELD Mandate

• By: Shannon Davison
• On: 10/10/2017 10:50:07
• In: Legislative Bulletins

TRALA Members, Friends, and Customers -
 
In response to FMCSA's decision to deny most of TRALA's ELD Petition for short-term rental trucks, the agency has agreed to conduct a conference call on October 19 to answer questions from TRALA members about how this decision will impact their businesses and their customers.
 
To recap, FMCSA is going to announce likely later this week that they will grant an exemption for break-downs from the ELD Mandate for only 8 days but will not allow other short-term rental trucks to avoid the mandate.  In the meeting TRALA held with FMCSA's leadership, the agency told TRALA that paper log printouts or downloads for the previous 7 days of hours-of-service records could be used by drivers that then rented a truck.  What this means is that TRALA members' customers can still rent a truck and combine their hours from the previous 7 days with an ELD equipped to the rental truck or a portable system brought by the driver.
 
It is TRALA's understanding that the agency believes this will allow seasonal, over-flow, and other usages to continue but with more paperwork required to the driver.  Because drivers must submit their hours every 13 days, it appears the administrative hurdle for TRALA member customers may be extensive with manual entering of hours to combine their hours before they rented a vehicle and after - using the ELD generated hours from the rental truck company (or a portable system the driver brings) - for their hours except for the previous 7 that took place before the truck was rented.
 
FMCSA is having their expert(s) willing to take questions on this call which will take place on October 19 at 2:00 PM EDT.  The call information is as follows:
 
Call number: 1-866-299-7945
Pass code: 594572#
Date/Time:  Thursday, October 19 at 2:00 PM EDT
 
Because we will have limited time, the agency would like to have as many specific questions presented before the call in writing so that they are prepared and can address them directly to TRALA members.  I would like to ask all of you to submit questions to me by COB on Monday, October 16.
 
This call may represent the best opportunity to receive guidance and clarification from FMCSA so I urge you to participate or have someone in your company take part in this important call.  I should also be frank with all of you in saying that it appears the agency cares little about the difficulty this may pose nor for the technical aspects some ELD manufacturers are dealing with trying to work out the ability to make this as seamless as possible.  The agency's only real concern seems to be that the ELD Mandate is operational and that there is a way - however difficult - for hours to be recorded in a way that requires an ELD as much as possible.  That said, the agency told TRALA if technical concerns or specific situations are presented in which the agency cannot come up with a solution, those may be taken into consideration for a follow-up guidance report and so, again, it is important to send me your specific questions and for you to take part in this call.
 
There will not be a calendar invite sent out for this call given the extensive number of people it will go out to so please mark your calendars now.  I also urge all of you to forward this to anyone that you think would benefit from hearing directly from FMCSA on the issue of short-term rentals. 
 
If you have any questions before October 19, please feel free to contact me anytime at jjacoby@trala.org or at 703-299-9120.
 
Thank you.
 
Jake Jacoby
President & CEO
TRALA