ELD Exception For City Driver

I have question, We have local trucks and Some separate US fleet with ELDs only installed in US trucks. My question is that sometimes we use these trucks for local deliveries when our city truck is down or all city trucks are booked. Now in this case we are using city driver in US truck with ELD installed but the driver is not assigned log in ID. What should we do have driver carry letter from the company that he's not trained nor he is required to use log book since for local work we don't travel more then 100kms on any given day. Would the letter work for MTO if driver is ever pulled over. If the letter is sufficient then how would you write it does anyone has used the letter if yes please share it. Thanks in advance

 

So did you issue city drivers authorization letter from company stating for MTO that city driver is exempt from using the ELD.

 

So you are allocating the extra miles per day for US trucks as Personal Conveyance miles to have the extra miles accounted for on the trucks that run US and used in city with ELDs

 

All my US trucks have IRP plates not US plates I was talking with Peoplenet rep as per him all the Miles on the trucks with ELDs in them must be accounted for to be legal in USA from now on. That's we have decided to give the city drivers a authorization letter to run under paper log and we are now accounting those miles truck ran in Canada as personal miles.