Should a Fleet Install AOBRDs with a Migration Path to ELD?
Stephen G. Eick
Just over a year ago the Federal Motor Carrier Safety Administration (FMCSA) published the final electronic logging device rule – or ELD mandate – on December 10, 2015. The ELD mandate contains a new set of regulations, § 395.20, that define a new class of device called an Electronic Logging Device. The new regulations require all fleets to implement certified ELDs to record a driver’s Record of Duty Status (RODS) for compliance with their Hours of Service (HOS) requirements. Motor carriers have until December 18, 2017 to implement certified ELDs. In addition, there is a grandfather clause that provides the motor carriers with an additional two years to comply.
It’s been over a year since the ELD mandate was released and, as of today, sixteen vendors have certified ELD solutions on FMCSA’s website. But what is interesting is that none of the traditional AOBRD vendors have released ELD solutions and they do not appear on FMCSA’s website. Why is this? What is going on?
AOBRDs Are Obsolete
AOBRDs are based on 1988 regulations – that is a 28 year old standard — which is an eternity in the technology business. Do you remember wired telephones, acoustically coupled modems, and MS-DOS? The year 1988 predates the Internet — back then it was the Arpanet. Why would an ELD vendor ask a customer to buy obsolete technology? Answer: It’s a marketing push.
The Marketing Pitch by AOBRD Vendors
There seems to be a marketing push by AOBRD vendors to encourage fleet operators to deploy AOBRDs, particularly those who do not have ELD certified solutions. They encourage customers to deploy the soon-to-be-obsolete AOBRDs with the promise that with a forthcoming software upgrade the obsolete hardware technology will be transitioned to ELDs. Be skeptical of these claims. It may not work as there have been significant improvements in device and engine technology in the intervening decades.
At VisTracks we make a white-label ELD software product. Our ELD is re-sold by many vendors to different segments of the market. Vistracks supports the latest hardware and software technology. Just in the last two weeks we have been approached by three different companies, one of whom is a large public company, whose internal ELD development programs were failing. The typical conversation goes something like this
“We’re months behind and we won’t be able to complete this in time. We would like to take a look at “OEMing” your solution …”
The problem is that implementing an ELD to meet § 395.20 is much, much more difficult than implementing an AOBRD to meeting § 395.15. The ELD mandate was 517 pages but the regulations for § 395.15 are just a few pages long. Some of the AOBRD vendors who are promising ELD solutions will be unable to deliver their promised upgrade. Here are the sorts of things that will go wrong for them:
1) Development Efforts Might Not Succeed
Writing ELD software is much harder than writing AOBRD software. There are several things that make it difficult:
- ELD Regulations are very dense
- HOS Driving rules are complex
- “Syncing” is hard
- Maintaining integral synchronization requires new hardware
- Running background tasks is tricky
2) Existing Hardware Device May Not Work
One of the new requirements is that the ELD be integrally synchronized with the vehicle engine control module (ECM) to automatically capture engine power status, vehicle motion status, miles driven, and engine hours. The previous requirement was that the AOBRD be “integrally synchronized” but did not define this term.
The way this is implemented is that the AOBRD and ELD vendors attach a device to the vehicle bus to capture the required data items. The problem for the older AOBRD solutions is that the data items required for ELD and ELD integral synchronization are much more complex than what was required for AOBRD. Thus, their approach to integral synchronization is unlikely to work. At a practical level, this means is that fleet operators are being asked to install an AOBRD devices now, then perform a 2nd install when the new ELD-compatible vehicle bus device is available. Why pay twice?
3) The Migration Path Might Not Work
One of the claims by AOBRD vendors is that they will provide a migration path to ELD compliance. It’s easy to say this on your marketing literature but it may not be possible to implement. Here are the things that can go wrong:
- Their software team might not be able to complete their development
- Existing AOBRD hardware may not be compatible with the new ELD regulations
- The “migration” might really be an expensive retrofit and re-install
- The new ELD software might fail
Some of the well-established AOBRD vendors are struggling with the transition from technology and regulations developed in the late 1980’s to the latest generation of technology and ELDs based on § 395.20. There are many ways that they can fail in this transition. Fleet managers should be very careful about deploying obsolete technology with the promise that it will be upgraded. A much better approach is to deploy the most recent generation of technology now that already meets the new standards. This approach is less expensive, and more reliable.