Canadian Trucking Alliance Electronic Logging Devices (ELDs) The Road Ahead

Transcription

1 Canadian Trucking Alliance Electronic Logging Devices (ELDs) The Road Ahead October 2015 Workshop Series Vancouver, Calgary, Edmonton, Winnipeg, Halifax, Regina, Toronto

2 Agenda Current Industry Uptake Current Regulatory Status Work To Date on Canadian ELD Rule Draft Technical Standard ELD Cost-Benefit Analysis Next Steps for Canada Outstanding Issues: Technical Standard ELD Enforcement Policy Supply Chain Accountability Legislation/Regulation

3 Voluntary Current Industry Uptake Majority of fleets some communications 80,000 full FMS (Canada) based on three suppliers CTA survey: 86% of FMS equipped units have ELD capabilities; 67% trucks using ELDs for HOS compliance 170,000 LOG/ELD units (Canada); 120,000 (Canada-US) Transitional issues include Training of drivers & learning curves Training of operations staff (company project, not just driver); Shipper awareness

4 Current Regulatory Status Initial concerns over failure to produce log book/print from ELDs addressed (for most part) CTA has supported universal mandate (for all trucks where paper log book currently required) since 2005 FMCSA to introduce final rule 4Q 2015 (for all trucks where paper log book currently required, not applied to short haul (100 mi radius)) Will come into force sunset of grandfathering for legacy ELD s (ABORD s) Canada's federal Minister of Transport announced commitment to universal mandate in March 2015 Interprovincial vs Intraprovincial: Ontario only province so far to declare political support Other provinces silent or favour voluntary use

5 Work to Date on Canadian ELD Rule Canada about 24 months behind US Only work to date CCMTA Draft Technical Standard Directive from Council of Deputies Completed 2013; waiting on US final rule Transport Canada Cost-Benefit Analysis Currently a draft is complete and being reviewed by provincial governments Expected to show positive net benefit November meeting of governments to determine next steps

6 Draft Technical Standard Key inclusions Technical performance based standard (multiple suppliers) Does not have to mirror US spec s, but cannot conflict Consistent with existing HOS regulations (no over above) Cell network communications not required Must be synchronized with engine ECM View ELD outside of cab Key exclusions to date Yard miles Grandfathering for existing equipment Certification

7 ELD Cost-Benefit Industry Elimination of form/manner/log not current violations by at least 2/3 s Reduction in OOS HOS violations by 40% or more Drivers save minutes per cycle or more Daily savings from not completing log book of 5-20 minutes or more Transparency throughout carrier operations (planners, safety, operations) Level playing field Government Drivers with serious HOS violations 45% more likely to be involved in an accident than compliant drivers (90% for 2 or more violations) Reduction in man-hours spent reviewing logbooks at roadside and audit

8 Next Steps for Canada Concurrent policy work needs to start NOW Already way behind US A lot of work to be done: 1. Address outstanding issues in technical standard and finalize 2. Develop ELD enforcement policy for Canada 3. Develop policy on supply chain accountability and awareness 4. Draft/enact legislation and regulations: Interprovincial (federal); Intra-provincial (provinces) Your input is essential

9 Outstanding Issues: Technical Standard Yard mile What is a reasonable distance or max speed? Needs to be on duty Device certification Necessary but how should it be done? Grandfathering provisions for existing equipment Is four years sufficient? Should there be different grandfathering for hardware and software?

10 ELD Enforcement Policy Modification or Status Quo for On-Road and Audit Components What is current situation, do we even need to address? Does expected spike in violations need time to correct with sunsets? Adverse conditions/unforeseen events Not congestion but highway closures? Other? Roadside enforcement Educational enforcement? Review of extreme punitive OOS conditions?

11 Supply Chain Accountability Shipper Responsibility What should be level of shipper responsibility? Should other supply chain regulators get involved? Coercion and Harassment Considerations Penalties? Whistleblower protection? Proper vetting of complaints?

12 Need to act Legislation/Regulation Federal government (CTA) and all provinces (Provincial Associations) Long process in Canada (CCMTA) Federal and provincial undertakings (Carriers) Can we tolerate different rules for inter vs intra carriers?

13 Questions 13