Yesterday was Day One of Roadcheck 2018. Law Enforcement's focus this year is on ELDs and HOS enforcement. However, yesterday was also the opening day of the comment period for SBTC's ELD Exemption Application. 28 people immediately commented overwhelmingly in support. Please step up and file your own comment in support. CALL TO ACTION: It is time to comment in support of SBTC's ELD Exemption application... The FMCSA has published the SBTC's ELD Exemption application. Here is the FMCSA notice and invitation for public comment. Click this link... https://www.regulations.gov/docket?D=FMCSA-2018-0180 Then click "Comment Now" to file your comment in support. When commenting, here are the bullet points we recommend you address (you may cut and paste these into your comment if you agree): *The ELD Rule is not a stand-alone safety regulation per se; that is, it is meaningless unless it is attached to the actual relevant safety regulation: the hours of service rule. If the requested exemption is granted, the hours of service regulation still remains in full force and effect and drivers are still required to comply. At issue, is simply the mechanism to track hours of service compliance. Paper record of duty status (RODS) remain the tool to show drivers' compliance and have sufficed as a mechanism to ensure public safety since the 1930s. Mandating ELDs is therefore excessive and more extensive than necessary to ensure compliance. *The FMCSA ELD rule did not take into account the impact on the smallest operators, especially owner-operators. It lumped one man carriers into the same category as carriers with annual revenues of $28.5 million. The burden on the smallest businesses is proportionally higher to the mega carriers who can more easily absorb the increased costs. This has an anti-competitive effect not considered by FMCSA. The rule is therefore contrary to the national transportation policy codified at 49 USC 13101 in which Congress directed national transportation policy ensure fair competition. *While MAP-21 mandated that vehicles be equipped with ELDs it did not specifically direct FMCSA to create a rule to eliminate the use of paper RODS. The exemption would enable small carriers to elect either RODS or ELDs as a matter of choice. *Implementation of ELDs has disrupted the supply chain in that many drivers have left the industry, causing a capacity crunch and a temporary increase in rates due to increased freight volumes and market forces as a matter of supply and demand, costs that are ultimately borne by the American consumer in terms of increased prices for goods. *FMCSA must under 49 USC 13541 grant the exemption if there is evidence that ELDs are not necessary to carry out the transportation policy of 49 USC 13101, not needed to protect shippers from the abuse of market power and is in the public interest. *FMCSA has arbitrarily granted exemptions to certain applicants suggesting it is already aware that continued use of RODS is a mechanism that will ensure public safety. *The US Government regularly exempts the smallest businesses from regulations to lessen the burden on these businesses including but not limited to COBRA, FMLA, Affordable Care Act, and OSHA regulations. Thank you. --SBTC Task Force on ELDs & HOS