ironpony
Professional Pot-Stirrer
Part 395 is the legal basis for the ELD (ABORD), it's required use and technical specification. The FMCSA only specifies a format to maintain the "Geo-Location" in relation to specified municipalities, data precision in reference to automatic collection of latitude and longitude, and decreases that precision during personal use of the vehicle. Nowhere does it specify the use of GPS - that is left up to the vendor of the ELD. The precision of the mandatory recorded data is fairly generic +/- 0.5 miles. The data used to generate the required geo-location data is not required to be stored, and would typically be thrown away during the conversion to the required format at the discretion of the ELD vendor.
If I were coding it, I'd call a subroutine that returned a GPS location to a specific scratch register in volatile memory, and then would send the converted geo-location string to whatever subroutine that called for its creation. That scratch memory location would be over written by the next call to the GPS location subroutine, and would never exist in memory any longer than that. It wouldn't be saved during a shutdown process. The use of GPS is a matter of convenience, not a dark conspiracy.
If BSM is going to complain about being tracked, they need to convince Congress that there is no public interest to regulate the industry through the use of logbooks. The requirement to maintain a "Record of Duty Status" implies providing a location where said duty status changes occurred, or there is little point in specifying limits to drivers on-duty time. Or... go after the individual ELD vendors for their design choices.
Further, the government has a legitimate interest in minimizing the cost of ensuring compliance of commercial drivers to applicable federal and state regulations. I'm sure that both Congress and the Executive Branch (DOT, FMCSA, etc) can reasonably argue that automating compliance to 395 is in the public financial interest in reducing the cost of government.
I'm sure I recall @Hammer166 going through this exercise some time ago when everyone was freaking out about being "tracked" before the BSM yayhoos got "woke." Here's what the government specifies...
395.8 Whenever you change duty status, the location is to be provided. Last I checked, a location in reference to the nearest town is recorded.
395.26 Lists data automatically recorded by an ELD, item:
(3) CMV geographic location information;
...in accordance with the requirements contained in appendix A to subpart B of this part.
Definition:
3.1.4. Geo-Location
Geo-location is the conversion of a position measurement in latitude/longitude coordinates into a description of the distance and direction to a recognizable nearby location name. Geo-location information is used on an ELD's display or printout.
4.3.1.6. CMV Position
(a) An ELD must determine automatically the position of the CMV in standard latitude/longitude coordinates with the accuracy and availability requirements of this section.
(b) The ELD must obtain and record this information without allowing any external input or interference from a motor carrier, driver, or any other person.
(c) CMV position measurement must be accurate to ±0.5 mile of absolute position of the CMV when an ELD measures a valid latitude/longitude coordinate value.
(d) Position information must be obtained in or converted to standard signed latitude and longitude values and must be expressed as decimal degrees to hundreds of a degree precision (i.e., a decimal point and two decimal places).
(e) Measurement accuracy combined with the reporting precision requirement implies that position reporting accuracy will be on the order of ±1mile of absolute position of the CMV during the course of a CMV's commercial operation.
(f) During periods of a driver's indication of personal use of the CMV, the measurement reporting precision requirement is reduced to tenths of a degree (i.e., a decimal point and single decimal place) as further specified in section 4.7.3 of this appendix.
(g) An ELD must be able to acquire a valid position measurement at least once every 5 miles of driving; however, the ELD records CMV location information only during ELD events as specified in section 4.5.1 of this appendix.
4.4.2. Geo-Location Conversions
(a) For each change in duty status, the ELD must convert automatically captured vehicle position in latitude/longitude coordinates into geo-location information, indicating approximate distance and direction to an identifiable location corresponding to the name of a nearby city, town, or village, with a State abbreviation.
(b) Geo-location information must be derived from a database that contains all cities, towns, and villages with a population of 5,000 or greater and listed in ANSI INCITS 446-2008 (R2013) (incorporated by reference, see §395.38).
(c) An ELD's viewable outputs (such as printouts or display) must feature geo-location information as place names in text format.
4.6.1.4. Positioning Compliance Monitoring
(a) An ELD must continually monitor the availability of valid position measurements meeting the listed accuracy requirements in section 4.3.1.6 of this appendix and must track the distance and elapsed time from the last valid measurement point.
(b) ELD records requiring location information must use the last valid position measurement and include the latitude/longitude coordinates and distance traveled, in miles, since the last valid position measurement.
(c) An ELD must monitor elapsed time during periods when the ELD fails to acquire a valid position measurement within 5 miles of the CMV's movement. When such elapsed time exceeds a cumulative 60 minutes over a 24 hour period, the ELD must set and record a positioning compliance malfunction.
(d) If a new ELD event must be recorded at an instance when the ELD had failed to acquire a valid position measurement within the most recent elapsed 5 miles of driving, but the ELD has not yet set a positioning compliance malfunction, the ELD must record the character “X” in both the latitude and longitude fields, unless location is entered manually by the driver, in which case it must log the character “M” instead. Under the circumstances listed in this paragraph, if the ELD event is due to a change in duty status for the driver, the ELD must prompt the driver to enter location manually in accordance with section 4.3.2.7 of this appendix. If the driver does not enter the location information and the vehicle is in motion, the ELD must record a missing required data element data diagnostic event for the driver.
(e) If a new ELD event must be recorded at an instance when the ELD has set a positioning compliance malfunction, the ELD must record the character “E” in both the latitude and longitude fields regardless of whether the driver is prompted and manually enters location information.
Data Element Descriptions
7.9. Distance Since Last Valid Coordinates
Description: Distance in whole miles traveled since the last valid latitude, longitude pair the ELD measured with the required accuracy.
Purpose: Provides ability to keep track of location for recorded events in cases of temporary position measurement outage.
Source: ELD internal calculations.
Used in: ELD events; ELD outputs.
Data Type: Kept track of by the ELD based on position measurement validity.
Data Range: An integer value between 0 and 6; If the distance traveled since the last valid coordinate measurement exceeds 6 miles, the ELD must enter the value as 6.
Data Length: 1 character.
Data Format: <Distance Since Last Valid Coordinates> as in <C>.
Disposition: Mandatory.
Examples: [0], [1], [5], [6].
7.29. Geo-Location
Description: A descriptive indicator of the CMV position in terms of a distance and direction to a recognizable location derived from a GNIS database at a minimum containing all cities, towns and villages with a population of 5,000 or greater.
Purpose: Provide recognizable location information on a display or printout to users of the ELD.
Source: ELD internal calculations as specified in section 4.4.2 of this appendix.
Used in: ELD display or printout.
Data Type: Identified from the underlying latitude/longitude coordinates by the ELD.
Data Range: Contains four segments in one text field; a recognizable location driven from GNIS database containing—at a minimum—all cities, towns and villages with a population of 5,000 in text format containing a location name and the State abbreviation, distance from this location and direction from this location.
Data Length: Minimum: 5; Maximum: 60 characters.
Data Format: <Distance from {identified} Geo-location> <'mi
> <Direction from {identified} Geo-location> <' > <State Abbreviation {of identified} Geo Location> <' > <Place name of {identified} Geo-location> where:
<Distance from {identified} Geo-location> must either be <{blank}> or <C> or <CC> where the up-to two character number specifies absolute distance between identified geo-location and event location;
<Direction from {identified} Geo-location> must either be <{blank}> or <C> or <CC> or <CCC>, must represent direction of event location with respect to the identified geo-location, and must take a value listed on Table 10 of this appendix;<State Abbreviation {of identified} Geo Location> must take values listed on Table 5; <Place name of {identified} Geo-location> must be the text description of the identified reference location;
Overall length of the “Geo-location” parameter must not be longer than 60 characters long.
Disposition: Mandatory.
Examples: [2mi ESE IL Darien], [1mi SE TX Dallas], [11mi NNW IN West Lafayette].
[IMG alt="eCFR graphic er16de15.015.gif"]https://www.ecfr.gov/graphics/er16de15.015.gif[/IMG]
[URL='https://www.ecfr.gov/graphics/pdfs/er16de15.015.pdf']View or download PDF[/URL]
[SIZE=6][B]7.31. Latitude[/B][/SIZE]
Description: An angular distance in degrees north and south of the equator.
Purpose: In combination with the variable “Longitude”, this parameter stamps records requiring a position attribute with a reference point on the face of the earth.
Source: ELD's position measurement.
Used in: ELD events; ELD outputs.
Data Type: Latitude and Longitude must be automatically captured by the ELD.
Data Range: X, M, E or −90.00 to 90.00 in decimal degrees (two decimal point resolution) in records using conventional positioning precision; −90.0 to 90.0 in decimal degrees (single decimal point resolution) in records using reduced positioning precision when allowed; latitudes north of the equator must be specified by the absence of a minus sign (−) preceding the digits designating degrees; latitudes south of the Equator must be designated by a minus sign (−) preceding the digits designating degrees.
Data Length: 1, or 3 to 6 characters.
Data Format: <C> or First character: [<'-'> or <{blank}>]; then [<C> or <CC>]; then <'.'>; then [<C> or <CC>].
Disposition: Mandatory.
Examples: [X], [M], [E], [−15.68], [38.89], [5.07], [−6.11], [−15.7], [38.9], [5.1], [−6.1].
[SIZE=6][B]7.33. Longitude[/B][/SIZE]
Description: An angular distance in degrees measured on a circle of reference with respect to the zero (or prime) meridian; The prime meridian runs through Greenwich, England.
Purpose: In combination with the variable “Latitude”, this parameter stamps records requiring a position attribute with a reference point on the face of the earth.
Source: ELD's position measurement.
Used in: ELD events; ELD outputs.
Data Type: Latitude and Longitude must be automatically captured by the ELD.
Data Range: X, M, E or −179.99 to 180.00 in decimal degrees (two decimal point resolution) in records using conventional positioning precision; −179.9 to 180.0 in decimal degrees (single decimal point resolution) in records using reduced positioning precision when allowed; longitudes east of the prime meridian must be specified by the absence of a minus sign (−) preceding the digits designating degrees of longitude; longitudes west of the prime meridian must be designated by minus sign (−) preceding the digits designating degrees.
Data Length: 1, or 3 to 7 characters.
Data Format: <C> or First character: [<-'> or <{blank}>]; then [<C>, <CC> or <CCC>]; then <`.'>; then [<C> or <CC>].Disposition: Mandatory.
Examples: [X], [M], [E], [−157.81], [−77.03], [9.05], [−0.15], [−157.8], [−77.0], [9.1], [−0.2].
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