2 ELD-Specific Duty Statuses Yard Moves: Understanding ELD Mandate Rules As most in the trucking industry know by now, the federal ELD mandate rules create two separate special driving categories called “authorized personal use” of a commercial motor vehicle (CMV), and “yard moves.” Use of these driving categories is both authorized and regulated under the ELD rules, but their use is not required. “AUTHORIZED PERSONAL USE” OF A A yard could be limited by a trucking company to its own terminals COMMERCIAL MOTOR VEHICLE (CMV) or company facilities. Or, a yard could be expanded beyond that AND “YARD MOVES” to include: ► a customer’s yard; These two categories provide some needed flexibility by allowing ► a receiver’s facility; “authorized personal use” of a CMV to be electronically recorded ► a maritime terminal; as off-duty time on line 1, when that category is allowed by a ► a rail ramp; company and selected by one of its drivers. And, the “yard moves” ► a drop yard; or, category is authorized by the rules to be electronically recorded as ► any other similar location or facility on-duty, not driving time on line 4. No matter how each trucking company defines a yard, and uses It’s clear that much of the industry will use these categories the “yard moves” category, a critical item to address with drivers is because they are both common and central to how the industry that they must remember to select and unselect the “yard moves” operates. And, while the discussion (perhaps even debate) will category on the ELD for it to properly record the driving time on a likely continue about just what is “authorized personal use” (more yard as on-duty, not driving time. commonly called “personal conveyance”), the question over what constitutes a “yard” under the ELD rules was answered by FMCSA. And, the answer might not be what you expected. SO, WHAT IS A “YARD”? During the rulemaking process, FMCSA considered but then chose not to provide a definition of a “yard.” And, importantly, in follow up questions to FMCSA, the agency chose not to provide any thoughts or guidance on the term “yard”. Wait…what? It probably bears repeating and emphasizing—FMCSA chose not to define or provide any guidance on the term “yard” for the purposes of the “yard moves” driving category. So, without a federal definition or guidance, trucking companies have the opportunity to define a “yard” for their own operations, and they should also consider providing instructions and training to their drivers on whether, where and when they may select and use the “yard moves” driving category. 7