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Hours of service

The 150 air-mile exemption: short-haul conditions, records and a worked week

By the Off Duty Not Driving Rewards teamOctober 20267 min read

In this article:
  1. What the short-haul exemption exempts, and what it doesn't
  2. What "150 air miles" means
  3. The 14-hour short-haul condition
  4. What records the carrier must keep
  5. What changed in 2020
  6. What happens on a day a driver goes over
  7. A worked week
  8. Non-CDL short-haul and the 16-hour exception compared
  9. Is the short-haul radius 100 or 150 air miles?
  10. Common short-haul mistakes
  11. Next steps

The 150 air-mile exemption frees qualifying short-haul drivers from keeping a log or using an ELD. As of October 2026, 49 CFR 395.1(e)(1) applies when a driver stays within 150 air miles of the normal work reporting location, is back and released within 14 consecutive hours, and gets 10 hours off between shifts. The carrier keeps time records instead.

The four conditions at a glance (property and passenger carriers):

#ConditionRule
1Operates within a 150 air-mile radius (172.6 statute miles) of the normal work reporting location395.1(e)(1)(i)
2Returns to the work reporting location and is released from work within 14 consecutive hours (driver-salespersons excepted)395.1(e)(1)(ii)
3At least 10 consecutive hours off separating each 14 hours on duty (8 hours for passenger-carrying drivers)395.1(e)(1)(iii)
4The carrier keeps accurate time records for 6 months395.1(e)(1)(iv)

All four must be true on the day. Miss one and the exemption doesn't apply to that day. The rule is final and in force as of October 2026, in the current eCFR text of 49 CFR 395.1.

What the short-haul exemption exempts, and what it doesn't

A driver who meets all four conditions "is exempt from the requirements of §§ 395.8 and 395.11." In plain terms:

Exempt fromStill applies
Records of duty status, including the ELD requirement (395.8)10 consecutive hours off before driving (395.3(a)(1))
Supporting documents (395.11)11 hours of driving (395.3(a)(3)(i))
The 30-minute break, which excepts "drivers who qualify for either of the short-haul exceptions" (395.3(a)(3)(ii))60 hours in 7 days or 70 hours in 8 days (395.3(b))

So the short-haul exception is a paperwork exemption. It doesn't add hours. FMCSA's ELD FAQ confirms the ELD side: operations exempt from 395.8 "are exempt from the ELD rule." The other ways to skip an ELD are in our ELD exemptions guide.

What "150 air miles" means

The radius is measured from the normal work reporting location, which the next paragraph of the rule describes as "the location where the driver reports to and is released from work" (395.1(e)(2)(ii)). The rule itself converts the distance: 150 air miles is 172.6 statute miles.

Two practical points follow:

  • It's a radius, not a route length. A driver can cover far more than 150 road miles in a day and still qualify, as long as no stop is more than 150 air miles out.
  • It's measured from one place. A driver who starts at one terminal and is released at another is not returning to the work reporting location, so condition 2 fails.

The 14-hour short-haul condition

The 14-hour short-haul test is about release, not driving. The driver must return to the work reporting location "and is released from work within 14 consecutive hours." The clock runs from coming on duty, through breaks, until release. A driver who comes on at 5:00 a.m. must be released by 7:00 p.m.

The 11-hour driving limit still sits inside that day. The 14 hours here is the short-haul condition. It is not a new 14-hour rule. For the pilot programs that are sometimes reported as a "new" 14-hour rule, see our post on the new 14-hour rule for truck drivers.

What records the carrier must keep

Instead of logs, the carrier "maintains and retains for a period of 6 months accurate and true time records showing" (395.1(e)(1)(iv)):

  1. The time the driver reports for duty each day;
  2. The total number of hours the driver is on duty each day;
  3. The time the driver is released from duty each day; and
  4. The total time for the preceding 7 days, under 395.8(j)(2), for drivers used for the first time or intermittently.

For item 4, 395.8(j)(2) requires a signed statement from the driver giving total time on duty in the preceding 7 days and when the driver was last relieved from duty. A time-clock system, a dispatch log or a timesheet can hold items 1 to 3, as long as the record is accurate and kept 6 months.

What changed in 2020

The 2020 hours of service final rule, effective September 29, 2020, widened this exemption (85 FR 33396):

Before Sept. 29, 2020Since Sept. 29, 2020
Radius100 air miles150 air miles
Maximum duty day12 hours14 hours
Driving limit11 hours (property)11 hours (property), unchanged

The rule's preamble describes the change as extending the workday "from 12 to 14 hours" and the distance "from 100 air-miles to 150 air-miles" (85 FR 33404). Older guides that still say "100 air-mile exemption" describe the pre-2020 rule.

What happens on a day a driver goes over

On a day when any condition fails, 395.1(e)(1) doesn't apply, so 395.8 does: the driver needs a record of duty status for that day. Because the break exception covers only drivers who "qualify" for short-haul, the 30-minute break rule applies that day too.

Whether that record can be on paper depends on how often it happens. FMCSA said in the 2020 rule that drivers who occasionally exceed the short-haul limits "can already drive within a 14-hour window for up to 8 days in any 30-consecutive day period without ELDs, provided they utilize paper RODS, or for more than 8 days in any 30-day consecutive period with an ELD" (85 FR 33412).

A worked week

Illustration only. A property-carrying CDL driver reports to the same yard each day. The carrier does not run trucks every day of the week, so the 60-hour/7-day limit applies. The driver was off duty the weekend before.

DayOn dutyReleasedFarthest pointQualifies?Why
Mon6:00 a.m.5:30 p.m. (11.5 h)120 air milesYesAll four conditions met
Tue6:00 a.m.7:00 p.m. (13 h)140 air milesYesReleased inside 14 hours; 11 h off before Wed
Wed6:00 a.m.8:30 p.m. (14.5 h)90 air milesNoReleased after 14 hours. RODS needed for Wed, the 30-minute break applies, and no driving after 8:00 p.m. (395.3(a)(2))
Thu7:00 a.m.6:00 p.m. (11 h)160 air milesNoBeyond 150 air miles. RODS needed for Thu
Fri6:00 a.m.2:00 p.m. (8 h)110 air milesYesBack inside all conditions

Three checks on this week:

  • The 10-hour gap. Wednesday's release at 8:30 p.m. means the earliest legal start Thursday is 6:30 a.m. A 6:00 a.m. start would break 395.3(a)(1), so the dispatcher moved Thursday to 7:00.
  • The weekly limit. On duty totals 11.5 + 13 + 14.5 + 11 + 8 = 58 hours for the 7 days ending Friday, under 60. The short-haul exemption doesn't change that limit. Our 34-hour restart guide explains how the 60/70 clock resets.
  • The 8-of-30 count. Two RODS days this week. If this driver needs RODS on more than 8 days in any 30-day period, the carrier needs an ELD for those days.

Non-CDL short-haul and the 16-hour exception compared

Two neighboring provisions get confused with the 150 air-mile exemption. All three are in 395.1 and in force as of October 2026.

150 air-mile, 395.1(e)(1)Non-CDL short-haul, 395.1(e)(2)16-hour exception, 395.1(o)
WhoAny CDL or non-CDL driver who meets the conditionsDrivers of property CMVs that don't require a CDLProperty-carrying drivers
Radius150 air miles150 air milesNone stated
Daily limitReleased within 14 hoursNo driving after the 14th hour on 5 days, or the 16th hour on 2 days, of any 7Released within 16 hours, once in 6 consecutive days unless after a 34-hour restart
Return each dayYes, to the work reporting locationYes, to the normal work reporting locationYes, and released there for the previous 5 duty tours
Logs and ELDExempt from 395.8 and 395.11Exempt from 395.3(a)(2), 395.8 and 395.11Not exempt: logs still required
Can combine withNot statedCan't use (e)(1), the split sleeper berth or (o)Not stated

Is the short-haul radius 100 or 150 air miles?

For the short-haul exemption it is 150 air miles, as of October 2026. The 100 figure still appears in other parts of 395.1, which is one reason guides disagree. Each radius below belongs to a different provision with its own conditions (49 CFR 395.1):

ProvisionRadiusMeasured from
Short-haul, 395.1(e)(1)150 air milesThe normal work reporting location
Non-CDL short-haul, 395.1(e)(2)150 air milesThe normal work reporting location
Agricultural operations, 395.1(k)150 air milesThe source of the commodity, the farm-supply distribution point, or the livestock's final destination
Retail store deliveries, December 10-25, 395.1(f)100 air milesThe driver's work-reporting location
Motion picture production sites, 395.1(p)100 air milesThe normal work-reporting location

A driver can meet one of these and not another. Check the paragraph that matches the work.

Common short-haul mistakes

  • Starting the next shift too soon. The 10-hour gap applies even on exempt days.
  • Measuring road miles. The test is air miles from the work reporting location.
  • No time records. Without the four records kept 6 months, the exemption can't be shown at an audit.
  • Ignoring the 60/70 limit. Exempt drivers still have weekly limits.
  • No plan for over-limit days. Keep paper logs in the truck, and count RODS days against 8 in any 30.

Next steps

Check each local route against the 150 air-mile radius, set dispatch to release inside 14 hours with 10 off between shifts, and keep the four time records for 6 months.

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