Repeal ELD Mandate through Regulatory Review Docket ID: DOT-OST-2017-0069-1442 #RepealELDs

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On November 20, 2017, the Small Business in Transportation Coalition ("SBTC"), an industry trade group, petitioned  Federal Motor Carrier Safety Administration ("FMCSA") to reconsider the Electronic Logging Device ("ELD") Rule as a good candidate for repeal in response to an October 2, 2017 Notification of Regulatory Review (and request for comments to be submitted by December 1, 2017) issued by the USDOT under Docket ID: DOT-OST-2017-0069-1442. SBTC requested an emergency stay on the December 18, 2017 ELD rule effective date.

On December 18, 2017, the ELD rule went into effect and the request for a stay went unanswered.

On January 5, 2018, FMCSA denied SBTC's request for reconsideration as "untimely" and kicked back the exemption application suggesting it must conform to a rule that applies to exemption applications submitted by individual motor carriers.

On February 1, 2018, SBTC petitioned for reconsideration of that denial pointing out the request was a timely comment under the USDOT's regulatory review notice and supplemented its request for an exemption from the ELD Rule for all owner operators and companies with less than 50 employees.

On April 1, 2018, motor carriers not compliant with the ELD rule will be put out of service.

I support the SBTC's efforts to repeal the ELD rule in its entirety.

In the event the rule is not repealed, I support the SBTC's exemption application.