RDS ELD Exemption Comments Requested

Following Sam Farruggio's lead, we have applied to be exempted from RODS

charting where our local drivers exceed 12 hours of on-duty time in a day 

(of course, they would still remain within the legal limit). The basis for our exemption is

that our contractors have installed advanced telematics in their trucks and are supplying

much more robust reporting and visibility than ELDs require. This is next generation. 

It would be helpful for interested parties to post favorable comments and it

would be great if you could do so on the FMCSA comments link below:

The web portal is

https://www.regulations.gov/document?D=FMCSA-2017-0175-0002