Luxury Coach & Transportation

March 2019

Magazine for the professional limousine, charter and tour industry.

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Page 26 of 62

ELDs Will Lasso You Into Compliance MOTORCOACH: REGUL ATIONS The regulatory noose is tightening in the final stage of requirements in documenting your driving time, driver hours, and trip data. By Tom Holden, LCT contributing writer A TLANTIC CITY, N.J. — Just when you thought you knew and heard it all about elec- tronic logging devices (ELDs), there are still more questions to digest on this sweeping new federal mandate that applies to most ground transportation services. To keep it simple, I will revisit the topic based on our panel discussion during the LCT-NLA Show East in No- vember 2018. Our panel included Mike McDonal from Saucon Technologies and Richard Malchow from J.J. Keller & Associates, a compliance consultancy, and me as the moderator. Here are some key questions we addressed: Is my limousine, minibus, or coach a CMV? Can I be interstate if I never leave the state? What are the hours of service limits for pas- senger carriers? According to Federal Motor Car- rier Safety Administration (FMCSA), a passenger vehicle carrying nine to 15 people including the driver is con- sidered a commercial motor vehicle (CMV) defined in Title 49 CFR 390.5 Definitions. is would include eight to 10 passenger stretch limousines (120- in.) and vans. So all limo companies and van ser- vices running commercial vehicles fall under the guidelines of the FMSCA: 1. Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight of 4,536 kg (10,001 pounds) or more, whichever is greater; or 2. Is designed or used to transport more than eight passengers (includ- ing the driver) for compensation; or 3. Is designed or used to transport more than 15 passengers, including the driver, and is not used to trans- port passengers for compensation. Nos. 2 and 3 should read regardless of compensation. Also, remember if you purchase/rent a van or minibus and you remove a seat or seats, the regulation reverts to what the origi- nal manufacturer built with those vehicle specs. Interstate / Same State: You are consid- ered doing interstate work if you pick up at an airport or a port for a cruise ship or even a train station. You are furthering the transportation of that person. For example, if you are hired to pick up a group of eight or more passengers flying into your airport, and you are taking them to a business or a hotel for meetings and later return- ing them to the airport, then the laws consider that interstate commerce. Hours of Service Limits: Here is where you really need to pay attention and think. is may vary from an intrastate perspective if you are only intrastate. But for interstate, the limits are found in Section 395.5 for passenger carrying vehicles and it's 15 hours on duty and that clock can be paused by off-duty time. Within that 15 hours, 10 hours of driving is allowed. But to reset either one of those hours of service clocks, the driver must be off-duty for eight con- 2 2 WWW.LCTMAG.COM LUXURY COACH & TRANSPORTATION MARCH 2019 Keith Johnson and operator Tom Holden of the consulting firm Bus Advisors. ou l ce

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