Luxury Coach & Transportation

August 2018

Magazine for the professional limousine, charter and tour industry.

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LUXURY COACH & TRANSPORTATION AUGUST 2018 45 install, generally." Finally, how easy is it to use? "Anybody who's done a tech- nology implementation with a group of chauffeurs knows there are definitely challenges in getting everyone onboard using the program properly. It's no different with ELDs. ere's a learning curve with it and a decent amount of man- agement and follow-up time to be implemented." Keep Affiliate Work In Mind Luxury transportation companies often have many events where they help affiliates in other cities. "When the Super Bowl was here in Phoenix, a bunch of companies came from Los Angeles," Guinn said. "We even had some who came from New Mexico. ey spent the better part of five days here. One thing to realize with this exemption is that on the day of travel, these companies traveled more than 100 air-miles. But every day they worked in Phoenix, they were able to actually use the exact same exemption simply by changing their home terminal. So, whatever their partner's address was, that became their home terminal. During the entire Super Bowl, nobody traveled more than 100 air-miles. So you can take advantage of things like this in your opera- tion to allow you to not have to worry about maintaining your exemptions." Hours of service violations continue to be the number one violation companies get written up for during audits. If you sit down with your auditor and explain you use the time clock exemption, they will only scan for those 12 hours or 100 air-miles. "So if you're located in Austin, Texas, your auditor comes in and he's going to look at your trip sheets for a driver. ey're all going to look for anything that [indicates] possibly going up to Dallas or going across to Louisiana or something like that. ey'll single those days out or they'll look for anything that goes more than a 12-hour work day where the driver came in and then their last trip ended outside of 12 hours," Guinn said. For more information, watch the full-length webinar at — you must qualify at least 22 times out of every 30 days. e exemption follows the driver. So some of your drivers could be exempted while others are not. If you have a few chauffeurs who do over the road trips primarily for you, every vehicle that chauffeur touches would need an ELD. So, if you restrict them to one bus or maybe one bus and one van, you can just put ELDs in those vehicles. You don't need the ELDs if they drive a bus, sedan, and SUV as well. You would need it in the bus, but not in the sedans and SUVs. With creative scheduling and paying attention, you can limit the cost exposure for your company. I Need ELDs. Now What? If you do need to buy ELDs, there are some points to con- sider. e first is compliance. To register with the FMCSA, you just have to tell them your program is compliant. ere's no test or formal certification pro- cess. You simply sign a certified agreement stating you've read the requirements and your program adheres to them. Most ELDs are designed for trucking companies which have different rules than passenger carriers. ese may be great for trucking companies, but they may not work with mixed lead or passenger carriers. Another factor is price. "I'm see- ing ELDs everywhere from $15 a month to $75 a month, but they generally do the same things," Przybylski said. "Some units are plug-and-play, and others require hardwiring into the vehicle. ere are upsides and downsides to both. Of course, the plug-and-play ones can be unplugged by the chauffeurs. e hardwire ones you have to pay someone to The biggest thing from the DOT perspective is if you don't have it recorded and written down, it doesn't count. So all the policies have to be written out and you have to have the things to go with them. — Chris Przybylski With creative scheduling and paying attention, you can limit the cost exposure for your company, said Chris Przybylski of Limo and Bus Compliance. PROS Creates an electronic log Gives you more flexibility in scheduling You don't have to worry about losing track of the amount of time a driver works Automates some of the duty status changes CONS Cost (hardware cost and a monthly subscription fee) Administrative burden Training Possibility of outages PROS AND CONS OF ELDS

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