Taking a position on ELDs

by Mike Millian

Despite Mother Nature’s best attempts to trick us, it is spring, and summer is closer at hand than we realize. And after a long and cold winter, who isn’t excited about that? The PMTC, its members, and the entire private trucking community are always looking forward to the beginning of summer for another reason as well: it means it’s once again time for what many consider to be the best educational and networking value in the trucking industry.

Mark the dates of June 17-18 in your calendar, and be sure to head towards King City to attend the PMTC Annual Conference at Kingsbridge Conference Centre. As part of our conference this year, we have seven educational seminars, the PMTC- Huron Services Hall of Fame inductions for professional drivers, the PMTC-MEE Fleet Safety Awards, the PMTC-3M Fleet Graphics Awards, two exhibitors showcases, networking outbreak sessions, plus the Volvo Scotch and Truck Showcase Reception, which is another added networking opportunity, and a chance to see some new trucks on display. A full conference agenda can be found on pg. 38w. You can register at www.pmtc.ca.

Our position on ELDs

Recently Canada’s Transport Minister Lisa Raitt, came out in the press of being in favour of electronic logging devices. The PMTC has responded, and is also in favour of the concept of ELDs, with the assurance that certain safeguards and standards are in place.

The PMTC and its members feel paper logs are an old and outdated way of tracking driving hours. We also acknowledge that logging in this manner allows a driver an opportunity to more easily falsify their records, and consequently this may allow unscrupulous operators to extend their day beyond the legal limits of the hours-of-service rules. While ELDs will never completely eliminate abuse of HoS regulations, their implementation will make it easier to verify compliance, and make it much less likely that an operator will be able to skirt the rules. 

In our view, a mandated ELD requirement, properly implemented and enforced, will level the playing field for all operators, and will help to remove unsafe and non-compliant operators from the roadways. While PMTC does support the concept of mandatory ELD implementation, a number of key issues must be addressed and covered off in any mandated requirement.

Canada/US harmonization: the economy of the two countries are undeniably linked, and many operations operate on both sides of the border, we must ensure our two countries work together and ensure ELDs are mandated and harmonized across our two great nations. We must ensure the ELD regulations in both countries closely mirror each other, and we need to ensure that the same technology and systems will be legal to operate on both sides, as having to purchase two separate systems would be too onerous, and unrealistic.

Privacy and enforcement: We need to ensure enforcement across the two countries is consistent. If officers in some jurisdictions refuse to accept the e-log technology, and require logs to be reproduced on paper, the gains and efficiencies intended by the policy will not be fully recognized, and will lead to significant frustration by drivers and operators alike. We must also ensure that ELDs are used solely for the purpose of gathering hours-of-service compliance. Privacy of personal and competitive information must be protected.

Costs: There will be an undeniable cost associated with ELDs. We need to ensure that any implementation policy has a reasonable phase in, grandfather period, to allow companies and owner operator’s time to research and install the proper system for them. PMTC suggests a two- to three-year period. We believe incentives should be provided to help reduce the financial burden to installing the systems, in the form of tax grants, rebates or credits. As many carriers have already installed the systems in the past, a rebate of some sort should be offered to companies who can verify the costs they have already invested to voluntarily go to ELDs prior to the regulations.

In the long term, we do believe a payback period will be realised through increased compliance, better utilization of driver hours, and a reduction in the driver’s time required to complete their logs, however these up-front costs still need to be taken into consideration in any implementation policy.

Technology: Many carriers have already invested in ELDs, and many suppliers have robust platforms already that should be investigated to ensure that existing technologies will comply with the ELD regulations, (we acknowledge a great deal of this leg work has already been completed) thus avoiding companies that have already made a significant investment having to replace or upgrade systems currently in use. If existing technologies need to be replaced or upgraded, the same two- or three-year grandfather period should be used for the phase-in period, as well as incentives to perform the upgrade, similar to what is being suggested earlier in this document in the costs statement.

In closing, the PMTC is in favour of the concept of mandatory ELDs, however we must ensure the regulations are harmonized across Canada and the US, and the areas of concern raised in this letter are captured and addressed.

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Mike Millian is president of the Private Motor Truck Council of Canada, the only national association that represents the views and interests of the private fleet industry. He can be reached at trucks@pmtc.ca.


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