Konexial appreciates the opportunity to comment on the proposed exemption to the ELD regulations for short-term truck rentals, FMCSA-2016-0428. We are a member of the Truck Rental & Leasing Association (TRALA) and an active stakeholder within the trucking industry. Konexial agrees with TRALA’s request for a pragmatic solution to short-term truck rentals within the ELD regulations, and we see the requested exemption as a reasonable exception for short term rental agreements.
However, we are concerned that an exemption on 30-day rentals could lead to a loophole that could be used to circumvent the intent of the ELD regulation. To avoid abuse of the 30-day rental exemption, we suggest limits will need to be promulgated on back-to-back short term Rentals.
Konexial would also like to be on record to encourage the administrator to focus on public safety, and the costs involved for small and independent carriers. Thanks to the flexibility of the ELD regulation, low-cost ELD solutions based on BYOD smartphones are available for small carriers, and some of these solutions are easily installed by the driver. We feel that driver installable ELDs would be a desirable option for the rental market, as well as help to solve the potential for a loophole.
Konexial believes that the ELD regulation is critical in improving the visibility of assets, and enabling a free market to eliminate waste in the form of empty miles and deadheading. Eliminating this waste will reduce emissions and improve the profitability of carriers. Thank you for allowing us to voice our comments. We look forward to being an active partner with FMCSA and a responsible stakeholder in this critical industry. To contact Konexial, or to learn more about our FMCSA compliant ELD, My20, visit our website.