The FMCSA’s has passed their final rulemaking on electronic logging devices which puts new emphasis on how to maintain records from onboard recording devices that use GPS or similar technology.
That’s a good thing. Fleets just need to make sure their efforts don’t stop short.
In lieu of logbooks, you’re required to keep six months of GPS records for hours-of-service compliance.
However, in order to comply with record keeping requirements under IFTA (International Fuel Tax Agreement), you need to be able to produce individual trip reports and original GPS data—every GPS “ping” or reading—to support your distance calculations going back four years—five and a half if the audit includes IRP (International Registration Plan).
An Opportunity To Improve Your Fleet’s GPS Records
The ELD mandate is an opportunity for fleets to improve their overall approach to managing GPS records not only for HOS but for distance-based fleet tax compliance as well.
For starters, remember that a GPS device doesn’t calculate distance. It only reads satellite signals and records where a vehicle is (or where a device is) based on latitude, longitude, date, and time (some systems also gather an odometer reading).
You need software—a routing program or transportation management system—to make the distance calculation.
This hardware/software combination is generally reliable but it’s not perfect.
GPS hardware can fail or not be reactivated after it’s been serviced, and poor antenna placement can be a problem. There are places where GPS signals naturally degrade, like in a canyon or among buildings. Weather can interfere with GPS signals.
When it comes to software, every vendor has its own proprietary way of using GPS data to determine your truck’s location and the distance it travels. There is no standard algorithm to translate GPS data into points on a map. Given the same information, one program can show your truck on a side road while another can put it on a main highway.
You know this. So do auditors.
That’s why IFTA auditors do not accept distance summaries generated by routing or fleet management software as proof of distance traveled.
They want access to the raw GPS data so they can verify for themselves whether your distance reports are correct. Yet despite vehicle tracking technology being as common as it is, auditors are encountering more fleet administrators who believe that simply “having GPS” is enough to satisfy the requirements for IFTA.
So let’s review those requirements and what steps you can take to make sure you meet them in the event of an audit:
1. IFTA requires licensees to preserve all records used to create quarterly tax returns and/or annual tax returns for four years from the tax return due date or filing date, whichever is later. IRP requires fleets to preserve records for three years after the close of the registration year. If you also use GPS data for IRP licensing, you are now keeping it for five years.
2. In addition to the information required on your individual trip reports, an auditor may ask to see GPS data for the vehicle to which the records pertain; the date and time of each GPS ping; the location (lat-long) of each reading; and the calculated distance between GPS readings. Make sure you know where this data is kept, for how long, and what it’s going to take to get access to it.
Ask Yourself The Tough Questions About Your GPS Records
So now you have to ask yourself some serious questions.
1. When missing GPS points leave gaps in your distance calculations, can you provide the records necessary to close those gaps and support your claim? All of those paper-based records you’d love to do away with—driver logbooks, trip sheets, dispatch records, fuel receipts—will come in handy when you need to close gaps in GPS data and recreate missing portions of trips.
2. If you operate a heavy truck with IFTA credentials, you’re required to report all distance that vehicle travels. “Report all distance” means all distance, including miles inside and outside your home jurisdiction; loaded, empty, dead-head, and bobtail miles; personal travel; and even non-taxable miles. That’s a lot of pings. Where is your GPS data kept and for how long? Do you keep it or is it with a vendor? If so, what’s it going to take to get access to it?
Right now, rules about distance records produced by vehicle-tracking systems vary depending on the jurisdiction. Make sure the method you use (meaning manual trip records or GPS data) will satisfy whatever jurisdiction would be auditing you.
Saying you “have GPS” isn’t enough to satisfy an auditor. As you pour over the new ELD rules, take time to review how your fleet management electronic records across all areas of compliance, beginning with IFTA and IRP.