Electronic Logging Device Letter Requested From FMCSA

As reported in May, several RV transport companies have been told by the highway patrol in multiple states that an electronic logging device (ELD) is required for the return trip after a unit has been delivered to a dealership. Although Thomas Yager, of the Federal Motor Carrier Safety Administration (FMCSA), assured the RV industry that transporters returning empty back to the origin of the RV transport trip fall under the exemption from the ELD requirement, RV transporters continue to be examined and taken out of service for not having an ELD.

The 2015 FAST Act highway bill provision exempting commercial vehicles involved in RV driveaway/towaway operations for motor homes and travel trailers from the requirement to utilize an electronic logging device is clearly intended to cover the return trip. To address the issue of states misinterpreting the provision, or otherwise not being aware of the new provision, the RV Industry Association has asked FMCSA to provide an interpretation letter for the provision.

The interpretation letter will make it clear that RV transporters do not need an ELD on either the trip between manufacturer and dealer or on the return trip back to the manufacturer. When received, this letter will be provided to the RV Industry Association’s transporter members, so their drivers can provide it to state highway patrols when questioned.

If any transporter continues to have problems with audits or notices of violations relating to this ELD issue, please contact Mike Ochs at 571-665-5860 or mochs@rvia.org.