The ELD mandate is structured so that those using AOBRD’s today may continue using them until 12/19. As we know, there is a big difference between AOBRD’s and “Letter of the Law” ELD’s.

Most noticeable is the operational variances permitted with AOBRD’s. “Letter of the Law” ELD’s have a speed threshold of a maximum of 5mph. Once the truck moves the mandated ELD goes to “On Duty Not Driving” as in preforming a yard move. Once the preset speed threshold has been reached the ELD changes to “Driving” from the moment the truck first moved.

To require any carrier to operate with a “Letter of the Law” ELD while others may game current variances provided by AOBRD’s is unjust as it gives those utilizing AOBRD’s an unfair advantage.

I will always stand behind an exemption for Independents.
An Independent is a single truck owner who operates the equipment they own under their own operating authority.
It stands to reason that the true Independents have no need to monitor themselves.
I believe they will be scrutinized if they choose not to use an ELD and that alone should, would or could be enough for them to fall in line with the rest.

So far as pushing wages up, ELD’s only do so by decreasing capacity in the short term.
Capacity is easily added as there are no labor cost associated to Employee Drivers who are preforming the Job Duties of Waiting and Manning their work stations.
The regs clearly give control of an Employee OTR Drivers TIME to the carrier. These Drivers are REQUIRED to operate in compliance of the law while manning their work stations anywhere USA for days, weeks and months at a time.

For any worker to devote 24hrs a day to an employer based on the assumption that the employer will provide work is asinine!
We are governed by the Clock not the amount of pieces we may produce.

The ELD project is totally screwed up because a government agency has permitted private industry to take control.
No, we needed a bidding process in place so that a single contractor would have control much like the military purchasing new jet fighters.

I should be able to place a card (Tacho Card as used in England) or my drivers license into any ELD and be able to operate.
A microchip on the card would hold all of the Drivers pertinent information so that it is readily available to the Driver, the carrier and law enforcement by placing the card into a reader with printing capabilities.

We Drivers need ELD’s if we are to ever be able to operate at our true value.

ELD’s will minimize Black Market working hours thus giving us a true value.
Bootleg auto parts from abroad have decreased the value of the real products produced here in the states.
Bootleg whiskey and cigarettes decrease the value of the real deal.

Our available working hours are no different.
The regulations provide us with a degree of financial security by limiting production thus giving our production value.
When the middle east cuts oil production the price of crude increases. When they flood the market with crude the price of a barrel decreases.
For Drivers to ignorantly side with the carrier associations in their quest for us to have More Available Working Hours or Flexibility is for Us to lock ourselves into Low Paying Jobs!

Average Annual Earnings of a Truckload Driver:
1980 @ $25,287 would be $74,687 in 2016
2000 @ $41,446 would be $58,757 in 2016
2016 is at $41,340 which is $106 less than 2000!!!
AND WE ARE STEADILY GOING DOWNHILL!!!

Efficiency for the carriers is having an available truck in every marketplace. They can afford this by paying piece work wages. There are no labor cost associated with an idle truck even though the Employee Driver is following the directions of the employer!

In the real world, Time Is Money.
In our world, “If the wheels aren’t turning”.
My TIME has Value and So Does Yours.

60 in 7 has been amended to allow 70 in 8 decreasing our value on an hourly basis.
70 in 8 has been legally transformed into 90+ in 8 thus reducing our value even more.
Now we may legally log “Off Duty” while waiting, preforming a job duty, at the docks. Again, this floods the market with available working hours that decreases our value.

I have no problems with the current HOS and neither should you!
The problem is that WE Can’t Afford to Operate Under the Current HOS!!!

I have problems with those who seek less regulation instead of insisting that Employee Drivers be paid a fair and decent wage for the TIME they devote to the JOB!

I have problems with Drivers who complain about the very regs that protects them and their loved ones as crying about the FMCSA is taking the easy way out.
Are you afraid you might be fired if you stood together and did something about the MONEY???

Blowing a Lot of Hot Air has done NOTHING to maintain our VALUE!!
This is exactly what the ATA, TCA and other carrier associations want us to do so that they may maintain a CHEAP DRIVERS POOL!!!!

Quality Comes At A Price but We Allow Ourselves to be sold at a Flea Market???

Pat Hockaday (JoJo)