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ELD’S: THE LATEST INFORMATION ON IMPLEMENTATION AND IMPACT

Presented November 21, 2017

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SPEAKERS

JASON RESNICKWESTERN GROWERS VICE PRESIDENT

AND GENERAL COUNSELBIO

JASON CRAIGDIRECTOR OF GOVERNMENT AFFAIRS

C.H. ROBINSONBIO

LUKE GOWDYGENERAL MANAGER, SOURCING

C.H. ROBINSONBIO

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SUPPLY AND DEMAND: DRIVERS

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CARRIER MARKET UTILIZATION

~20% truck capacity lost during

recession1

~ 15% fewer trucks today than in

2007

2010 rise came against great

elasticity1

Today’s low elasticity is a

disruption consideration

Sept. 98.3%Truck utilization 2000-2017

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ELD’S

Timeline:Implementation is required by December 18, 2017,

but…no out of service orders until April 2018

11/20/17: FMCSA announced that the agency will

issue a 90-day delay from ELD mandate for

agricultural products to be defined in a forthcoming

Federal Register notice.

Potential Delays:Judicial

• OOIDA Lawsuit was denied in November 2016

• Final legal challenged denied by U.S. Supreme

Court

Legislative

• Babin amendment lost a floor vote 246-173 as

part of end of year government budget

Administrative

• FMCSA nominee Ray Martinez had his hearing

Oct 31 and passed out of committee

• Will the new boss pump the brakes on?

• Technical details around “harmonious data

transfer” to law enforcement

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ELD’S

Exemptions:

• Trucks older than 1999

– Engine does not have secure connection

• 100 air miles exempt IF working <12 hrs/day

• Drivers working fewer than 8 days out of 31

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ELD’S

Cost and Complexity to Implement:• Smartphone apps can be compliant

– Costs as low as $50 for hardware and $15/month

• Easy to buy at truck stops

• Navigation units even have ELD’s built in

Fleet Management System VS ELD:• FMS are much more than just an ELD

• Costs for FMS can be $1000+ per truck

– Examples are Peoplenet and Omnitracs

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ELD’S

How many HOS violations are there?

• 2016 CVSA roadcheck data placed 2.52% of all inspected drivers out

of service for HOS and False Log violations

– For comparison, 12.4% of vehicles were placed out of service

during the surprise brake check in May 2016

• 2017 FMCSA Pocket Guide to Truck Statistics cites 3.3 million

roadside inspections conducted in 2016 and a maximum of 13.4%

of violations related to logbook violations.

– Only 20,223 violations were written for driving more than 11

hours (0.6% of all stops)

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HOURS OF SERVICE OVERVIEW

• No more than a 14 hour work day

• No more than 11 hours of driving from the start of drive time

• 30 minute rest break within the first 8 hours after start of drive

time

• 10 hour rest per day

• 60 hour On Duty limit for 7 days or 70 hour On Duty limit for 8

days is the weekly clock

• 34 hour restart required after weekly clock is met

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ELD’S

One Day Transit Impact

• Paper logs are documented in 15 minute

increments

– Change of duty triggers change in

status

• ELD measure in 1 minute increments

• Driver’s complain of losing “flexibility”

– This means drivers legally have 15+

minutes per day they can be flexible

with paper logs

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RESOURCES

• FMCSA Driver’s Guide to HOS

• FMCSA List of Self Reported Complaint ELDs

• FMCSA ELD FAQ page

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ELD’S

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ELD’S

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ELD’S

Wild Card is Fear

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Freight Characteristics

Multi-day transit

Multiple picks / drops

Variable loading locations

Dwell time

Tight matrices / Just in Time

ELD Challenges

Many variables

Different loading priorities

Shifting freight origin

On duty hours spent not driving

Pressure to perform (KPI’s)

What can you do about all of this??

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QUESTIONS?

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THANK YOU!

Jason CraigDirector of Government Affairs

Jason.Craig@chrobinson.com

Luke GowdyGeneral Manager, Sourcing, C.H.

Robinson

Luke.Gowdy@chrobinson.com

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