CCS Transportation HOS Exemption Request: Yard Moves on Public Roads

FMCSA published a notice asking for public comment on CCS Transportation’s application for an HOS exemption.

Here’s the core of what CCS is requesting: - Drivers making short moves between two CCS facilities - Using local public roadways just to connect the properties - Logged on the ELD as on-duty (not driving) yard moves, instead of normal driving time

FMCSA hasn’t approved or denied anything yet. The notice simply opens the door for comments and lays out that the agency will review the application, safety data, and feedback before making a decision.

What matters for the rest of the industry is the principle: under what conditions, if any, can a brief public-road move be treated more like a yard move than a road trip under HOS?

Most fleets have some version of this problem. You might: - Shuttle trailers between two yards a mile apart - Move equipment between a shop and a storage lot - Use a short stretch of city street to get from one side of a big plant to another

Right now, if it’s on a public roadway, inspectors generally expect it to be logged as driving time. Yard-move status is typically limited to private property.

If FMCSA eventually approves anything like what CCS is asking, it could: - Clarify when short public-road hops between your own facilities may be treated like yard moves - Change how some fleets structure local campus-style operations - Influence how ELD providers set up yard-move options and geo-fencing

From an insurance angle, we look at how you control these tight, low-speed moves. A lot of fender-benders, mirror strikes, and backing claims happen on these short trips in and out of yards, especially if drivers mentally treat them as “off the clock” or not real road time. How you log it tends to reflect how seriously your team takes it.

The distance may be short, but the liability is real. On these connecting road segments you’re still mixing with the public, cyclists, parked cars, and tight intersections.

If FMCSA were to allow some of these moves to be logged as yard moves, it wouldn’t change your responsibility to operate safely. Claims departments and plaintiff attorneys don’t care what ELD status you used when something goes wrong.

What we tell our clients: treat every public-road move like a full road move from a safety standpoint, even if the mileage is tiny. That means: - Clear procedures: when a move is allowed, who authorizes it, and what route is used - Low-speed policies: enforce speed limits on and off your property - Training: make sure drivers understand that “short” doesn’t mean “informal”

Underwriters look at your loss runs and ask, “Where are the dings coming from?” A rash of yard or short-hop claims between facilities can hurt you at renewal just as much as a highway rear-end, especially if it looks like a pattern of loose supervision.

Even before FMCSA decides on the CCS request, it’s a good time to tighten up your documentation around these kinds of moves.

Useful items to pull together:

- **Written policy for yard and campus moves** Spell out when drivers can use yard-move status, when it must be logged as driving, and how public-road segments are handled.

- **Facility maps and routes** Simple diagrams showing where your yards sit relative to each other, the exact public-road stretch between them, and the designated route drivers must use.

- **ELD configuration notes** How yard-move status is enabled, who can toggle it, and any geo-fencing or restrictions you’ve set up. This helps during inspections, audits, and renewal discussions.

- **Incident logs for yard and transfer moves** Track minor hits, near-misses, and property damage. When we review these with carriers, we often find a small routing or visibility fix that saves multiple claims a year.

If you ever consider your own exemption request or have to explain your practices to an inspector, insurer, or auditor, this paper trail makes a big difference.

Regulatory changes around HOS and yard moves tend to ripple into insurance, even if slowly. As this CCS exemption works its way through FMCSA’s process, it’s worth a conversation with your agent.

Topics to cover: - How your current log practices for yard and campus moves could look in a DOT audit - Whether your auto liability and physical damage claims show a pattern around yards or short transfers - How your safety manual and driver files reflect your real-world procedures for these moves - What kind of documentation underwriters like to see when you have multiple facilities in the same town

Every carrier’s situation is different. Final coverage, pricing, and terms will always depend on underwriting, filings, your drivers, cargo, state laws, and each insurance company’s appetite. But being proactive on this kind of operational detail usually puts you in a better position when renewals and safety reviews come around.