ELD's and pickups,

He's not hauling that car for profit. When you own a Dodge you learn very quickly to always have a backup plan.

 

Obviously. Trucks are registered by the VIN of the chassis, not the engine. Chassis built in 2014 IS a 2014. The rule is model year 2000 and newer.

 

The only exemption to the ELD is for the transport of RV's trailers and fifth wheels. If the driver only does these transport, we are exempt under the FAST act. It restricts the exemption to the transport of such items from the factory to dealer and dealer to factory. If there is any other transport, such as a boat, or such, the exemption is lost to that driver and must install an ELD from that day forward.

 

Have a link for that info?

 

SEC. 5507. ELECTRONIC LOGGING DEVICE REQUIREMENTS.

Section 31137(b) of title 49, United States Code, is amended--

(1) in paragraph (1)(C) by striking `apply to' and inserting `except as provided in paragraph (3), apply to'; and

(2) by adding at the end the following:

`(3) EXCEPTION- A motor carrier, when transporting a motor home or recreation vehicle trailer within the definition of the term `driveaway-towaway operation' (as defined in section 390.5 of title 49, Code of Federal Regulations), may comply with the hours of service requirements by requiring each driver to use--

`(A) a paper record of duty status form; or

`(B) an electronic logging device.'.

The link to the fast act is
http://thomas.loc.gov/cgi-bin/cpquery/? ... TOC_827534

https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/FMCSA-ELD-Final-Rule_12-10-2015.pdf

https://www.fmcsa.dot.gov/faq/what-exce ... evice-rule

What exceptions are allowed by the Electronic Logging Device (ELD) rule?

Drivers who are not required to keep records of duty status (RODS) are not required to use ELDs. In addition, the following drivers are not required to use ELDs, but must maintain paper logs when required:

Drivers who keep RODS no more than 8 days during any 30-day period.
Driveaway-towaway drivers (transporting an empty vehicle for sale, lease, or repair), provided that the vehicle driven is part of the shipment.
Drivers of vehicles manufactured before model year 2000.

Last Updated : December 9, 2015

Our industry is classed driveaway-towaway.
We transport empty vehicles for sale, lease or repair. (provided that the vehicle driven is part of the shipment). In other words, the commodity we haul is part of the shipment.

When you go into the guidance provided by the FMCSA it clearly shows the rules to exempt driveaway and towaway operations.

When you go to fmcsa 390.5 which is part of the pdf discussion you linked, it shows the definition of driveaway and towaway.

Driveaway-towaway operation means an operation in which an empty or unladen motor vehicle with one or more sets of wheels on the surface of the roadway is being transported:

(1) Between vehicle manufacturer's facilities;

(2) Between a vehicle manufacturer and a dealership or purchaser;

(3) Between a dealership, or other entity selling or leasing the vehicle, and a purchaser or lessee;

(4) To a motor carrier's terminal or repair facility for the repair of disabling damage (as defined in § 390.5) following a crash; or

(5) To a motor carrier's terminal or repair facility for repairs associated with the failure of a vehicle component or system; or

(6) By means of a saddle-mount or tow-bar.

From our safety dept.
Driveaway-towaway operation means an operation in which an empty or unladen motor vehicle with one or more sets of wheels on the surface of the roadway is being transported:

(1) Between vehicle manufacturer's facilities;
(2) Between a vehicle manufacturer and a dealership or purchaser;
(3) Between a dealership, or other entity selling or leasing the vehicle, and a purchaser or lessee;
(4) To a motor carrier's terminal or repair facility for the repair of disabling damage (as defined in § 390.5) following a crash; or
(5) To a motor carrier's terminal or repair facility for repairs associated with the failure of a vehicle component or system; or
(6) By means of a saddle-mount or tow-bar.

(note the restriction, "with one or more sets of wheels on the surface of the roadway" will eliminate any means of transport where no wheels of the cargo touch the roadway)

 

Yeah, I didn't finish my thought up there^. Were I was headed with that thought was that if they're required in trucks with motors that may not have ECMs, someone will have a some sort of compliant device which would work with the dually crowd.

 

Compliance with the dually crowd will not be a challenge, all of the engine connectivity data is available on the smaller trucks, it just uses a different format, OBDII instead of the J1908 bus. I'm sure there is an adapter available for most devices and companies like Continential, makers of VDO RoadLog, have their devices in light trucks around the globe already. I know from experience JJ Keller's devices are compatible with light trucks, one of my clients from my consulting firm uses them in everything from their road tractors and dump trucks to their foreman and mechanic trucks which are mostly Silverado 3500 gas jobs.

The crowd that is having a hard time accepting this is the towing and emergency road service industry. I have been invited to speak on the topic at three towing trade shows next year to educate them on this. Most towers today have a hard time maintaining compliance with paper logs, they also misunderstand the emergency service exemption and how it effects their 10 hour breaks, once electronic logging is mandated they will be in a lot of trouble. The towing industry lobbied, unsuccessfully, for an exemption from the mandate.

 

I bet a lot of them will simply refuse to travel more than 100 mi from terminal