Key Takeaways
- For FMCSA Hours of Service purposes, 150 air miles equals 172.6 statute miles. The distance is a straight-line radius from the driver’s normal work reporting location, not the number of road miles traveled.
- Staying inside the radius is only one condition of the short-haul exception. The driver must also return to the normal work reporting location and be released within the applicable time limit.
- A driver who qualifies for the short-haul exception generally uses the motor carrier’s time records instead of a daily record of duty status (RODS).
- If a driver fails any short-haul condition, the driver must prepare a RODS for that day. Whether an ELD is required depends on how often the driver needs a RODS and whether another ELD exception applies.
- Property-carrying, passenger-carrying, and certain non-CDL property-carrying operations have different limits. Carriers should apply the provision that fits the driver and operation.
Short Answer: 150 Air Miles Is 172.6 Statute Miles
An air mile is a nautical mile. One air mile equals approximately 1.1508 statute miles, so 150 air miles equals about 172.6 statute miles.
That conversion does not create a 172.6-mile driving allowance. Under the federal short-haul rules, the radius is measured in a straight line from the driver’s normal work reporting location. Roads, detours, traffic, and the route’s total mileage do not change the boundary.
| Measurement | Equivalent | How it is used |
|---|---|---|
| 1 air mile | About 1.1508 statute miles | Nautical-mile measurement used in the regulation |
| 150 air miles | About 172.6 statute miles | Straight-line radius from the normal work reporting location |
| Road miles | Varies by route | Does not define the federal short-haul radius |
What Is the 150-Air-Mile Short-Haul Exception?
The short-haul exception in 49 CFR § 395.1(e) changes how qualifying drivers document their Hours of Service. It does not remove the underlying driving, on-duty, or off-duty limits.
For the common property-carrying provision in § 395.1(e)(1), a driver must meet all of these conditions:
- Operate within a 150-air-mile radius of the normal work reporting location.
- Return to that location and be released from work within 14 consecutive hours.
- Have at least 10 consecutive hours off duty between qualifying shifts.
- Stay within the applicable driving limit, which is generally 11 hours for a property-carrying driver after 10 consecutive hours off duty.
- Have the motor carrier maintain the required time records.
A driver must satisfy every applicable condition for the exception. Being inside the radius by itself is not enough.
Property-Carrying and Passenger-Carrying Limits Are Different
The regulation includes different driving and rest limits for property-carrying and passenger-carrying drivers. Both may use the 150-air-mile provision when all applicable conditions are met, but their limits should not be treated as interchangeable.
| Requirement | Property-carrying driver | Passenger-carrying driver |
|---|---|---|
| Radius | 150 air miles | 150 air miles |
| Return and release | Within 14 consecutive hours | Within 14 consecutive hours |
| Required off-duty period | At least 10 consecutive hours | At least 8 consecutive hours |
| Typical maximum driving time | 11 hours after 10 consecutive hours off duty | 10 hours after 8 consecutive hours off duty |
| Primary record when all short-haul conditions are met | Carrier time record | Carrier time record |
The FMCSA Hours of Service summary provides a practical overview of the property- and passenger-carrying limits.
What Records Does a Qualifying Short-Haul Driver Use?
When the short-haul exception applies, the motor carrier keeps an accurate time record rather than requiring the driver to prepare a daily RODS. The carrier’s records must show:
- The time the driver reports for duty each day.
- The total number of hours the driver is on duty each day.
- The time the driver is released from duty each day.
- The total time on duty during the preceding seven days for a driver used for the first time or used intermittently.
The carrier must retain these time records for six months. A basic payroll total is not automatically enough; the record must contain the information required by the regulation.
Because no daily RODS is required on a fully qualifying short-haul day, an ELD is generally not required for that day. The carrier still needs a dependable process for capturing and retaining the required time data.
When Does a Short-Haul Driver Need a Log or ELD?
A driver must prepare a RODS for any day when one or more short-haul conditions are not met. Common triggers include traveling outside the 150-air-mile radius, returning after the applicable work period, or not returning to the normal work reporting location.
The need to prepare a RODS does not automatically mean the driver must use an ELD every time. FMCSA allows a limited exception for drivers who are required to prepare RODS on no more than eight days within any rolling 30-day period. Those drivers must still complete the required RODS on those days, but they may use paper logs or another permitted method. A driver who exceeds that threshold generally needs an ELD unless another specific exception applies.
For a focused explanation of the threshold, see What Is the 8-Day Paper Log Rule? FMCSA also addresses this distinction in its ELD FAQ for short-haul drivers.
A Practical Decision Path
- Did the driver meet every applicable short-haul condition? If yes, the carrier uses the required time record and the driver does not prepare a RODS for that day.
- If not, did the driver prepare RODS on no more than eight days in the current rolling 30-day period? If yes, the limited ELD exception may apply, but a compliant RODS is still required.
- Did the driver exceed eight RODS days in the rolling 30-day period? If yes, an ELD is generally required unless another exception applies.
Drivers and dispatchers should track the rolling 30-day count before assigning an occasional longer trip. The count does not reset at the beginning of a calendar month.
How to Measure the 150-Air-Mile Radius
Start with the driver’s normal work reporting location, then map a 172.6-statute-mile straight-line radius around it. Every point where the driver operates must remain inside that circle for the radius condition to be met.
A route can cover more than 172.6 road miles during the day and still remain inside the radius if all stops and travel stay within the circle. Conversely, a destination that is fewer than 172.6 road miles away could still fall outside the circle depending on geography and the route.
Useful planning practices include:
- Use a mapping tool that supports radius or straight-line distance, not just turn-by-turn mileage.
- Confirm the correct normal work reporting location for the driver.
- Check every scheduled stop, pickup, delivery, and detour point.
- Allow dispatchers to flag a route that may cross the boundary before the driver leaves.
- Keep a documented process for recording exceptions and tracking RODS days.
Common Short-Haul Scenarios
| Scenario | Likely recordkeeping result |
|---|---|
| The driver stays within the radius, returns to the normal reporting location, is released within the applicable limit, and meets the other conditions. | Carrier time record; no daily RODS for that qualifying day. |
| The driver stays within the radius but is released after the applicable work-period limit. | The short-haul exception does not apply for that day; a RODS is required. |
| One delivery point is outside the radius. | The short-haul exception does not apply for that day; a RODS is required. |
| The driver needs RODS on seven days in a rolling 30-day period. | The limited ELD exception may apply, but RODS are still required on those days. |
| The driver needs RODS on nine days in a rolling 30-day period. | An ELD is generally required unless another specific exception applies. |
Special Rule for Certain Non-CDL Property-Carrying Drivers
Section 395.1(e)(2) contains a separate short-haul provision for certain drivers of property-carrying commercial motor vehicles who do not require a commercial driver’s license. It uses the same 150-air-mile concept but includes different conditions, including limited use of a 16-hour return-to-reporting-location window.
Carriers should not apply that provision simply because a vehicle is locally operated. They should first confirm the vehicle, driver, and operation meet the provision’s specific eligibility requirements, then apply its frequency and recordkeeping conditions.
Common Compliance Mistakes
- Treating 150 air miles as 150 road miles. The regulatory radius is approximately 172.6 statute miles measured in a straight line.
- Assuming radius alone creates the exception. Return, release, rest, driving-time, and recordkeeping conditions also matter.
- Calling short-haul status an ELD exemption for every trip. A driver who fails a short-haul condition needs a RODS, and repeated RODS use may trigger the ELD requirement.
- Counting eight RODS days by calendar month. The test uses a rolling 30-day period.
- Using the property-carrying limits for passenger operations. The driving and off-duty limits differ.
- Keeping incomplete time records. Carriers need the required report, release, and total on-duty information and must retain it for six months.
Short-Haul Compliance Checklist
- Confirm the driver’s normal work reporting location.
- Map the 150-air-mile radius as 172.6 statute miles in a straight line.
- Verify every stop remains within the radius.
- Apply the correct property-carrying, passenger-carrying, or non-CDL provision.
- Track report time, release time, and total on-duty time.
- Confirm the driver returns and is released within the applicable limit.
- Track every day a RODS is required within the rolling 30-day window.
- Use an ELD when required and document any exception the carrier relies on.
- Retain short-haul time records for at least six months.
For a broader look at the boundary between local operations and electronic logging, read How Many Miles Can You Run Without an ELD?
The Bottom Line
For federal Hours of Service purposes, 150 air miles means a 172.6-statute-mile straight-line radius from the driver’s normal work reporting location. A driver qualifies for short-haul recordkeeping only when the radius and every other applicable condition are met.
The simplest compliance system separates three questions: Did the driver qualify for short-haul time records today? If not, was a RODS completed? And does the driver’s rolling 30-day RODS count require an ELD? That distinction helps carriers plan routes, document exceptions, and avoid treating local mileage as a blanket exemption.
Geosavi provides fleet visibility and reporting tools that can help carriers monitor operating boundaries and driver activity. Contact Geosavi to discuss a workflow for your fleet.