- Trash hauling and recycling fleet American Disposal Services (ADS)
- Oilfield service fleet Cudd Energy Services (CES)
- Agricultural Retailers Association (ARA)
- Association of Energy Service Companies (AESC), which includes well service rig contractors
ADS is also requesting an exemption from keeping paper logs. The garbage collection company operates under the multiple-stop rule, it says, as well as the 100 air-mile short-haul exemption. Its drivers, however, exceed the 12-hour limit more than eight times in a 30-day period, requiring the use of ELDs.
Each route for ADS drivers has between 800 and 1,200 stops per day, and the drivers pick up trash at a home every 22 seconds, on average. ADS says there is “no ELD that can accurately record driving time when the CMV makes constant short movements with the driver often exiting the vehicle.”
CES is requesting an exemption for its “specially-trained drivers of commercial motor vehicles specially constructed to service oil wells.” The company says it plans to install equipment that would enable tracking of its trucks when communication capabilities exist, but these units would not meet AOBRD or ELD standards. CES adds that poor cell service in certain oilfield locations and prohibitions of cell phones and electronic equipment while on job sites would prevent drivers from logging into ELDs.
ARA is requesting an exemption for its member companies from the mandate, arguing the mandate places “undue economic and other burdens.” ARA relies on trucks to deliver their products and services to farms. The group says its members need additional information and guidance on the ELD rule, and adds that ELD vendors and manufacturers don’t offer devices that meet their needs.
AESC’s exemption request is on behalf of well service rig contractors, who typically operate under the short-haul exemption but sometimes exceed the requirements of the exemption.
Without an exemption from the ELD mandate, AESC says, these drivers would have to monitor the number of days they exceed the requirements of the short-haul exemption. Contractors would also have to purchase ELDs, train drivers on them and monitor compliance, the group says. The group says these drivers spend little time on public roads and can spend between two and five days parked at a single location.