ELD Exemptions Explained: Understanding the 100/150 Air Mile Exemption

Christa Krajewski

JULY 18, 2017 – As the deadline for the Electronic Logging Device (ELD) mandate approaches, there is still a considerable amount of confusion surrounding who exactly will be exempt from installing the devices into their Commercial Motor Vehicles (CMVs). We’ve covered many of these exemptions in the past, but there’s still a big one that deserves some attention: the 100/150 air mile exemptions. If you meet the criteria for either of these exemptions, you aren’t required to follow federal hours of service regulations – and therefore won’t be required to have an ELD.

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Demystifying the 100/150 Air Mile Exemptions

If you are a short-haul, interstate carrier that operates within either 100 or 150 air miles of your work location, you may be exempt from the ELD mandate. To qualify, you must meet all of the following criteria.

If you are a CDL driver, you:

  • Must operate solely within a 100 air-mile radius*
  • Must be completely off-duty within 12 hours
  • Must report back to the same work location every day
  • Must have at least 10 consecutive hours off-duty between each shift.

If you are a non-CDL driver, you:

  • Must operate solely within a 150 air-mile radius*
  • Must not drive through any state that requires a CDL for the type of vehicle being operated
  • Must report back to the same work location every day
  • Must not drive after the 14th hour of coming on duty 5 days in a period of 7 consecutive days
  • Must not drive after the 16th hour of coming on duty 2 days in a period of 7 consecutive days

Drivers are currently required to fill out a paper log if any one of the criteria listed above is not met. For example: a CDL driver gets a job that will bring in a lot of cash, but he has to travel 300 air miles to deliver the load. He is required to maintain a paper log for the duration of the trip.

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Other ELD Exemptions

If the 100/150 air mile exemptions don’t apply to you, there are currently three other major ELD exemptions, as determined by the FMCSA. They include:

  1. Drivers who keep logs for no more than 8 days during a 30-day period. Many drivers infrequently travel over the 100/150 air mile radius. Take the example given above of the CDL driver who goes over 100 air miles one time. Even though he has to keep a paper log for that trip, he does not have to purchase an ELD provided that the situation rarely occurs…specifically, no more than 8 days in any 30-day period.
  2. Driveaway-towaway operators who meet one of two specific criteria: either  the vehicle being driven is the commodity being delivered OR the driver is transporting a motor home or recreational vehicle trailer with one or more sets of wheels are on the roadway.
  3. Drivers of vehicles with a model year  (or engine year) of 1999 or earlier. These vehicles are exempt simply because some do not have the ports required to connect an ELD. There has been some confusion about model vs. manufacture year, but the FMCSA has been clear: it’s the model year of the vehicle or it’s engine that they’ll use to determine compliance. So if you have a 2005 truck with a 1999 engine installed (for example), you wouldn’t need an ELD.

Hopefully, this has helped answered some common questions regarding ELDs. Please be sure to let us know by leaving any comments or questions below!

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396 thoughts on “ELD Exemptions Explained: Understanding the 100/150 Air Mile Exemption”

        1. Hi Aaron, Not that I’m aware of. You might be able to create a mobile-friendly version using a spreadsheet app, however.

  1. Hello if my company is based out of North Dakota and we use the 100 air mile but I decide to send my trucks to Wyoming and work for a month where they will report back to the same location every day do I need to run ELDs

    1. Hi Richard,You’ll need to keep logs on the trip from ND to WY, but as long as you’re following the 100 air mile radius rule once you’re there, you can use that for the rest of the month. There is an ELD exemption that allows you to keep paper logs as long as you’re not doing so more than 8 times in a 30 day period. As long as you’re only running logs on those trips to and from ND, you won’t need an ELD. Paper logs will be fine.

      Hope that helps!

  2. Hello, our base is in St louis mo but our driver starts from Terre haute Indiana every day and our dedicated run is 129 miles away and he returns to Terre haute Indiana every day . 5 days aweek . Can we be exempt from the ELD ? From Billy

      1. Hi Lindsey,
        What if my commercial driver does not cross state lines and drives the same 129 miles away then drives 129 miles back to base. Will he or she be required to use an ELD or is a paper log ok? They will also be doing this for more than 8 days in a rolling 30 day period.

        1. Hi Michael, It depends on the laws of the state where you work. If the state requires intrastate ELDs, you’ll be required to use one, otherwise you’d need to keep paper logs. Based on your daily mileage you wouldn’t qualify for the air mile exemption unless you’re a non-CDL driver.

    1. Hi Randall, only if you are running under an agricultural exemption. Otherwise, you’ll need to log all of your hours worked.

  3. Sorry if this is a repeated question: if air miles exclusion applies…. am I not required to take a 30 min break within 8 hours of drive time? I short haul cdl-B and make 4 stops avg per day. The 30 min break rule sometimes rankles me.

  4. Hi, my question is if the guys fall under the less than 8 days logging, how do they make a backlog if they are logging for that one particular day that requires the log?

    1. Hi Melissa, My understanding is that a backlog isn’t needed. As long as there is a record of time sheets that show a history of hours worked, that should be enough.

  5. Hello,

    We have 3 company trucks, 2 of which rarely go out (the owners trucks) and 1 which I have a driver in and goes out daily but only local – within 100 miles of the yard. Occasionally we send our driver over the 100 mile range but he would fall in the “no more than 8 days in a 30 day period”. So I feel pretty confident for the time being that we are exempt. I have heard that the CHP is going to or is currently requiring you have a letter from the FMCSA showing that you are exempt. Is this true and if so how do you get one? Also, if not true, how do you prove that you fall in the 8 day category of exemption?

  6. I have a small passenger carrying fleet. My drivers are all part time and most have other jobs. Most of my drivers claim the 100 mile exemption as they don’t drive commercially for their other jobs. One driver does drive commercially and past 100 air miles for his other job, so he keeps logs. Do I need ELDs in my fleet if my vehicles never go past 100 airmiles?

    1. Hi Kevin, Only your drivers who keep logs would need to have an ELD in their truck. As long as your other drivers are exempt under the 100 air mile radius rule, they can keep paper time records – an ELD would be optional for them (they can choose to use them instead of time records).

  7. we are a small carrier
    we have 10 trucks
    5 operate locally within 100 miles
    5 go out of 100 miles
    can 5 have eld and 5 not

  8. Can the 150 air mile exemption be used for a CDL driver that only drives a class 4 (<26,000 lbs) truck? In other words, do the HOS rules take the type of vehicle into account or are they automatically excluded from this provision irregardless of the vehicle because they have a valid CDL?

    1. Hello, Yes, a CDL driver can use the exemption, provided he/she is driving a truck that doesn’t require a CDL. It’s the type of truck that matters – not the license class.

    1. Hi Christi, Unless you meet one of the short-haul exemptions, you’d need to use an ELD. Otherwise, you can record your hours worked on a paper time record.

  9. Our main yard is in Newark, CA, I am based out of the San Bernardino CA yard. I drive under the 100 mile local rule. Every couple of months the main office has me come up to Newark for 4 to 5 days at busy times. Does the days that I am up in Newark count as days against the 8 in 30. Or is just the day driving up and the day driving back

    1. Hi Gene, As long as you’re using the 100 air mile radius exemption on the days you’re operating out of Newark, only the days driving up and back will count.

    2. Hello i am self employed nd have a CDL and travel less then 100 miles during work hours. Do i need to use my ELD?

  10. I bought an under cdl mechanics truck in Minnesota and have to fly out and drive it back to Rhode Island. Once there it won’t leave the state again. Do I need to have an Eld to drive it back?

    1. Hi Jared, No, there is an ELD exemption that allows you to keep paper logs for up to 8 days in any 30 day period. Since that trip should only take a few days, you can keep paper logs.

      1. Similar situation we have trucks that are sold and have already been stripped of our company equipment (ELDs). Can we use this exemption to move the truck to another state where the truck is sold? I’ve been told elsewhere that IF the truck doesn’t have an ELD in it, you can’t use this exemption, unless of course you are exempt for other reasons.

  11. I drive a bobtail truck and do local pick ups twice a week that only take me 4-5 hours that need to be delivered next day over the 100 mile radius. Do I have to use the ELD only for the long hauls?

    1. Hi Juan, You’d need to use an ELD on any day that you aren’t staying within the 100 air mile radius and meeting all the conditions of the exemption, as outlined above. If you’re only making the trip 8 times or fewer in any 30 day period, you’d be exempt from the ELD mandate and could keep paper logs instead.

  12. Our company drivers are all non commercial drivers (Class C) because our fleet consists of service trucks with the occasional hauling with a trailer. Therefore they don’t need a CDL (Class A). These drivers clock in and out for each day worked. They don’t cross any state lines and stay within 100 mile radius from our locations. I was told we are exempt from the ELD rules and since they clock in and out for work using a time keeping device, they don’t need a paper log. Is this still true?

    1. Hi Diane, As long as they’re keeping track of their hours worked, I believe that’s correct. There isn’t any formal time sheet that local drivers need to fill out.

  13. Hi Lindsey,

    Can you explain the last two parts of this non CDL exemption? The 14th and 16th hour parts. I am a little confused what they are meaning by this.

    Thanks, Kevin

    If you are a non-CDL driver, you:

    Must operate solely within a 150 air-mile radius*
    Must not drive through any state that requires a CDL for the type of vehicle being operated
    Must report back to the same work location every day
    Must not drive after the 14th hour of coming on duty in a period of 7 consecutive days
    Must not drive after the 16th hour of coming on duty in a period of 2 consecutive days

    1. Hi Kevin, It is a little confusing. There is a non-CDL short-haul exemption that allows you to extend your 14 hour window by two hours once a week (or twice a week if you took a 34 hour restart). To take the 150 air mile exemption, you must adhere to the 14-hour work day at least 5 out of every 7 days. The 16-hour short haul exemption can only be used twice during this time. There’s more information in this document that you might find helpful: https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Drivers Guide to HOS 2015_508.pdf

          1. II’m trying to get information about elogs I’m a local truck driver and my boss asked me if I could take a load to Dallas, TX from Memphis, TN where I work local and the truck doesn’t have ELOGS so my question is do I have to have a ELOGS device in the truck before I can make the run or can I run paper logs for this one trip??

          2. Hi Kevin, If it’s just a single trip then you can run paper. The FMCSA has an exemption that allows drivers to use paper logs provided they aren’t doing so more than 8 days out of any 30 day period.

  14. I work at a place where mostly I do NOT drive a commercial vehicle. However, I DO have a CDL and very rarely DO drive a CDL vehicle. Do the driving hours and time off time stay the same for me in this exemption? FYI I am a chauffeur and drive passengers.

    Paul

    1. Hi Paul, If you drive a commercial motor vehicle and transport either property or passengers, you must adhere to the FMCSA’s hours of service limits and track your time when driving. It wouldn’t apply on days/weeks that you aren’t driving, however.

  15. I run a paper log under the 8 trips / 30 day rule. I leave between 6 & 7 P.M., drive for 5 hours, then take my 8 hour split sleeper time, then load somewhere between 6-8 A.M. and drive home. Even though mileage and time equal 1 trip is this going to count as 2 trips because it crosses 2 days?

  16. On trucks that are pre ELD, or ELD exempt. Will these trucks ever have to comply with the FMCA. What I mean is if truck is exempt will it stay exempt at least in the foreseeable future?

  17. Does this ELD log apply to mobile crane company’s ? We very seldom go out of a 100 mile radius from our home base.

  18. Hello We run a family business that now consists of only 1 owner operator truck. My brother Ric 2005 Mack … We are Ontario based but go into various states in US …. We are over .100/150 miles trips….
    Question Is…. Do we need him to Run the ELD logs with only running one (1) truck?
    He has been running it…but with many problems…. and over the weekend at a truck show, he was told that because of only running one truck he does NOT have to run the ELD logs…. paper logs are fine.
    I have researched and could not find that tidbit.
    Could you help me out please.
    Thank you
    Gloria for brother Ric.

  19. Is it ok if your starting and ending location starts at your house? Say the truck is station at your house, and your time starts and ends when your home.

  20. Hi Lindsey,
    If I meet all the 100 miles exempt rules, how many consecutive days may I work? Is there a reset involved?
    Thanks

  21. We will soon have a truck that is driven Monday, Wednesday and Friday over 100 miles by driver 1 using the ELD installed in the truck. My second driver drives Tuesday and Thursday (same truck) but never travels past 100 miles round trip (local).How do we record the second driver if he is not required to run ELD and plans to use paper..I don’t want the ELD to show a violation every second day when the second driver is not entered. Thanks

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