TCA supports federal laws and regulations requiring the use of
electronic logging devices (ELD) for documenting compliance with hours
of service (HOS) rules. In developing such a law or regulation, TCA
believes the following issues should be addressed:
ELDs requirements should be based on the minimal, functional, and
performance specifications necessary to accurately record and report HOS
compliance and assure reliability and utility of operation.
Except for HOS compliance data, statutory protections should be
afforded to motor carriers pertaining to the control, ownership, and
admissibility/discoverability of data generated and derived from ELDs,
and to assure the privacy rights of drivers.
Drivers shall be responsible for operating ELDs in full compliance with all applicable regulations.
Any ELD regulation must address the operational diversity of
the trucking industry, continue existing exceptions to the record of
duty status, and consider additional exemptions that balance compliance
and the evolving industry diversity.
Motor carriers using compliant ELDs should be relieved of the
burden of retaining supporting documents for verification of driving
Any ELD mandate, if instituted, should be made simultaneously
applicable to all vehicles of the affected population of motor carriers.
It should avoid any implementation inequities identified and take
measures to eliminate them.
Tax incentives should be pursued as a means to facilitate adoption of ELD systems.