Mike grew up on a beef farm in rural Southwestern Ontario in Huron County. Mike began his career in the Trucking Industry in 1990 at the age of 18, spending three years working for a local carrier Hauling Livestock and bulk agriculture products. At the age of 21 Mike went to work for a long Haul Refrigerated and general freight carrier and spent 5 years hauling all sorts of freight in all 48 US Mainland States and 6 Canadian Provinces. The Carrier then opened a Certified Driver Training School in 1998 and Mike came off the road and become one of the Schools first Certified Driver Trainers. In 2000 Mike Transitioned into Safety and Compliance for the Fleet, while still working part time as a Trainer for the School. In 2002 Mike moved over to a Private Fleet and became the Safety, Compliance, Maintenance and Training manger for the Hensall District Co-operative’s Commercial Trucking Fleet. Mike spent the next 12.5 years with Hensall and oversaw the Fleets as it grew from 40 Trucks in 2002 to over 140 in 2015. In January of 2015 Mike moved into the Trucking Association business and was named the President of the Private Motor Truck Council of Canada, where he remains in his current role.

Recently Canada’s Transport Minister, the Honourable Lisa Raitt, came out in the press of being in favour of Electronic Logging Devices. The PMTC has responded, and is also in favour of the concept of ELD’s, with the assurance that certain safeguards and standards are in place.
The PMTC and its members are of the view that paper logs are an old and out dated way of tracking driving hours in today’s day and pmtc logotimes. We also acknowledge that logging in this manner allows a driver and operator an opportunity to more easily falsify their records, and consequently this may allow unscrupulous operators to extend their day beyond the legal limits of the Hours of service rules. While ELD’s will never completely eliminate abuse of Hours of Service Regulations, their implementation will make it easier to verify compliance, and make it much less likely that an operator will be able to skirt the rules. In our view, a mandated ELD requirement, properly implemented and enforced, will level the playing field for all CMV operators, and will help to remove unsafe and non-compliant operators from the road ways. While PMTC does support the concept of mandatory ELD implementation, a number of key issues must be addressed and covered off in any mandated requirement

US-Canada Harmonization
As the economy of the two countries are undeniably linked, and many operations operate on both sides of the border, we must ensure our two countries work together and ensure ELD’s are mandated and harmonized across our two great nations. We must ensure the ELD regulations in both countries closely mirror each other, and we need to ensure that the same technology and systems will be legal to operate on both sides, as having to purchase two separate systems would be too onerous, and unrealistic.

Privacy and Enforcement
We need to ensure enforcement across the two countries is consistent. If officers in some jurisdictions refuse to accept the e-log technology, and require logs to be reproduced on paper, the gains and efficiencies intended by the policy will not be fully recognized, and will lead to significant frustration by drivers and operators alike. Officers in all jurisdictions must be fully educated on the systems and the regulations, and it must be clearly understood what their requirements are when enforcing the policies for ELD usage.
We must also ensure that ELD’s are used solely for the purpose of gathering Hours of service compliance. Privacy of personal and competitive information must be protected.

Costs-Grandfather-Phase in period
There will be an undeniable cost associated with ELD’s. We need to ensure that any implementation policy has a reasonable phase in, grandfather period, to allow companies and owner operator’s time to research and install the proper system for them. PMTC suggests a 2 to 3 year period. We believe incentives should be provided to help reduce the financial burden to installing the systems, in the form of tax grants, rebates or credits. As many carriers have already installed the systems in the past, a rebate of some sort should be offered to companies who can verify the costs they have already invested to voluntarily go to ELD’s prior to the regulations.
In the long term, we do believe a payback period will be realized through increased compliance, better utilization of driver hours, and a reduction in the driver’s time required to complete their logs, however these up-front costs still need to be taken into consideration in any implementation policy.

Technology
Many carriers have already invested in ELD’s, and many suppliers have robust platforms already that should be investigated to ensure that existing technologies will comply with the ELD regulations, (we acknowledge a great deal of this leg work has already been completed) thus avoiding companies that have already made a significant investment having to replace or upgrade systems currently in use. If existing technologies need to be replaced or upgraded, the same 2 or 3 year grandfather period should be used for the phase in period, as well as incentives to perform the upgrade, similar to what is being suggested earlier in this document in the costs statement.

In closing, the PMTC is in favour of the concept of mandatory ELD’s, however we must ensure the regulations are harmonized across

Mike Millian
Mike Millian

Canada and the US, and the areas of concern raised in this letter are captured and addressed

About the Author

“Mike has 25 years’ of wide ranging experience in the trucking industry, performing such duties as a livestock and grain hauler for 3
years, followed by 5 years of long haul across North America hauling refrigerated and general freight. Mike was also a full time certified driver trainer for 2 years, and then transitioned into Safety and Compliance for 2 years, and then spent over 12 years as a Fleet manager for a Private Fleet. Mike is now the President of the Private Motor Truck Council of Canada, Canada’s only National Association that represents the views and interest of today’s Private Fleets.” Mike can be reached at trucks@pmtc.ca

Mike grew up on a beef farm in rural Southwestern Ontario in Huron County. Mike began his career in the Trucking Industry in 1990 at the age of 18, spending three years working for a local carrier Hauling Livestock and bulk agriculture products. At the age of 21 Mike went to work for a long Haul Refrigerated and general freight carrier and spent 5 years hauling all sorts of freight in all 48 US Mainland States and 6 Canadian Provinces. The Carrier then opened a Certified Driver Training School in 1998 and Mike came off the road and become one of the Schools first Certified Driver Trainers. In 2000 Mike Transitioned into Safety and Compliance for the Fleet, while still working part time as a Trainer for the School. In 2002 Mike moved over to a Private Fleet and became the Safety, Compliance, Maintenance and Training manger for the Hensall District Co-operative’s Commercial Trucking Fleet. Mike spent the next 12.5 years with Hensall and oversaw the Fleets as it grew from 40 Trucks in 2002 to over 140 in 2015. In January of 2015 Mike moved into the Trucking Association business and was named the President of the Private Motor Truck Council of Canada, where he remains in his current role.