What Is the 100 Air-Mile Radius Rule? A Guide to the Federal Short-Haul Exception

The “100 air-mile radius rule” is often used as shorthand for a federal short-haul exemption from certain driver logbook requirements. However, the current federal short-haul exception generally uses a 150 air-mile radius, not 100. Eligible commercial drivers may avoid keeping a record of duty status and, in qualifying cases, using an electronic logging device (ELD). They still must follow applicable hours-of-service limits and keep accurate time records.

What the 100 Air-Mile Radius Rule Means

People searching for the 100 air-mile radius rule are usually asking whether a commercial driver can work without completing a daily logbook. The relevant federal provision is the short-haul exception in 49 CFR 395.1(e). For most eligible property-carrying and passenger-carrying drivers, the federal limit is a 150 air-mile radius around the driver’s normal work-reporting location.

That distinction matters. A driver who travels 120 air miles from the reporting location may qualify if all other conditions are met. A driver who travels beyond 150 air miles generally cannot use this particular short-haul exception for that work period. A company should not treat “100 air miles” as the current federal limit without checking whether a specific state rule, company policy, contract, or other special provision applies.

The exception changes certain recordkeeping requirements; it does not erase hours-of-service rules. Drivers must still comply with applicable limits on driving time, duty periods, breaks, and off-duty rest. Employers must still maintain required records and ensure drivers are not scheduled in a way that violates federal rules.

How the 150 Air-Mile Short-Haul Exception Works

The exception is available only when the driver and employer meet all relevant conditions in the federal regulation. The main requirements differ slightly depending on whether the driver operates a property-carrying or passenger-carrying commercial motor vehicle.

Property-carrying drivers

Under 49 CFR 395.1(e)(1), a property-carrying driver may qualify for the short-haul exception when the driver:

• Operates within a 150 air-mile radius of the location where the driver reports for duty and is normally released from duty.
• Returns to that reporting location and is released within 14 consecutive hours after coming on duty.
• Has at least 10 consecutive hours off duty separating qualifying work periods.
• Works for an employer that keeps the required time records.

The exception also has a limit on driving time. A property-carrying driver remains subject to the applicable 11-hour driving limit after the required off-duty period. The short-haul provision does not allow a driver to drive longer simply because the driver does not have to prepare a standard daily log.

Passenger-carrying drivers

Under 49 CFR 395.1(e)(2), a passenger-carrying driver may use a similar short-haul exception when the driver stays within a 150 air-mile radius, returns to the normal reporting location, and is released within 14 consecutive hours. The driver must have at least eight consecutive hours off duty between qualifying work periods. Passenger-carrying drivers remain subject to the applicable driving-time limits, including the 10-hour driving limit after eight consecutive hours off duty.

The passenger and property rules are not interchangeable. A carrier should identify which hours-of-service category applies to the vehicle and operation before relying on the exception. Other provisions may affect a particular operation, and the regulation should be checked for the exact circumstances.

What an Air-Mile Radius Measures

An air-mile radius is a straight-line distance from a fixed point, not the distance traveled along roads. One air mile is a nautical mile, equal to approximately 1.15 statute miles. Therefore, a 150 air-mile radius is roughly 172.6 statute miles in a straight line.

The measurement is made from the driver’s normal work-reporting location, not from the vehicle’s route, the edge of a city, or a moving point along the trip. A route may cover more than 172.6 road miles while remaining inside the radius if it curves within the boundary. Conversely, a relatively short road route could cross the boundary if it travels directly away from the reporting location.

Because road mileage is not the test, dispatchers should not determine eligibility solely from a trip odometer or mapping app’s route-mile total. A carrier can use dispatch maps or other reliable tools to check the geographic boundary, but it should document the location used and have a process for spotting trips that approach or cross the limit.

What Records Are Still Required?

A qualifying driver generally does not have to prepare a standard record of duty status (RODS) for that workday under the short-haul exception. Instead, the employer must keep time records for the required period. For property-carrying drivers, those records generally include the time the driver reports for duty, the total hours on duty, the time the driver is released, and the total time for the preceding seven days when applicable. Passenger-carrier records have corresponding requirements under the regulation.

These records are important even when a driver never exceeds the radius. They allow the employer and enforcement officials to check whether the driver’s work period and rest comply with the rules. A carrier should preserve accurate, consistent time records and make them available as required by law.

When a driver fails to meet the exception’s conditions, a standard RODS may be required for the relevant work. For example, a driver who goes outside the radius or cannot return and be released within the permitted period should not assume that the short-haul recordkeeping treatment still applies. The employer should determine the appropriate documentation and compliance steps based on the operation and applicable regulation.

Does the Rule Exempt Drivers From ELDs?

Drivers who are not required to prepare RODS under a valid short-haul exception generally do not need an ELD for that qualifying work. An ELD is primarily used to record hours-of-service data that would otherwise be documented in a RODS. If the driver must keep a RODS, the ELD requirements may apply unless a separate exemption or exception covers the operation.

This does not mean that a driver is automatically exempt from an ELD whenever a trip is local. The driver must meet the short-haul conditions, including the radius, return, release, and rest requirements. A separate ELD exception may also apply in some situations, but that is a different rule with its own criteria.

Employers should account for mixed workweeks. A driver may qualify for the short-haul exception on some days and need a RODS on other days. Under the federal short-haul provision, a driver who uses the exception may be required to prepare a RODS on a day when the driver does not meet its conditions. Carriers should have clear procedures for recording and reviewing those days rather than relying on a broad “local driver” label.

When a Driver May Not Qualify

Being home every night or driving locally does not, by itself, qualify a driver. Common reasons the exception may not apply include:

• The vehicle travels outside the applicable 150 air-mile radius.
• The driver does not return to the normal reporting location.
• The driver is not released within the required 14-hour period.
• The driver does not receive the required consecutive off-duty time.
• The employer does not keep the required time records.
• The driver’s work falls under a different hours-of-service category or is subject to a separate rule.

Temporary changes to a work location can create questions about what counts as the normal reporting location. The applicable regulation refers to the location where the driver reports and is normally released. Employers should not casually designate a different point for each trip simply to keep a driver within the radius. Unclear or changing reporting arrangements should be reviewed with a qualified compliance professional or counsel.

Federal Rules and State Intrastate Operations

Federal hours-of-service rules generally apply to interstate commercial motor vehicle operations. A driver operating only within one state may be subject to that state’s intrastate rules, which can differ from federal requirements. Some states adopt federal standards; others may have distinct provisions or exemptions for particular operations.

Consequently, a driver operating entirely within a state should check the state department of transportation or other responsible agency. A federal 150 air-mile exception does not automatically settle what applies to every intrastate trip. The type of vehicle, cargo, operation, and applicable state law can all matter.

There are also other federal exceptions—for example, certain agricultural or emergency operations—that have separate eligibility tests. Those exceptions should not be confused with the short-haul provision. A carrier should verify the exact rule rather than assume that a different mileage exemption applies because the work is local or seasonal.

Practical Compliance Checklist

A straightforward review can help a carrier determine whether a driver may use the short-haul exception on a given workday:

1. Confirm the operation: Identify whether the driver is subject to property-carrying or passenger-carrying hours-of-service rules.
2. Set the correct reference point: Confirm the driver’s normal reporting and release location.
3. Check the geographic limit: Verify that the driver remains within the applicable 150 air-mile radius.
4. Review the duty period: Confirm the driver returns and is released within 14 consecutive hours.
5. Verify prior rest: Check that the driver received the required consecutive off-duty period—10 hours for property-carrying operations or eight hours for passenger-carrying operations.
6. Maintain time records: Record the required reporting, on-duty, release, and related information.
7. Plan for exceptions: Establish a process for days when a driver crosses the boundary or otherwise fails to qualify.

This checklist is a compliance aid, not a replacement for the regulation. Employers should also train dispatchers and drivers to report changes promptly, especially when traffic, weather, customer delays, or an unplanned assignment could push a trip outside the exception’s limits.

Key Takeaway: The Current Federal Limit Is Usually 150 Air Miles

The phrase “100 air-mile radius rule” remains common in searches and workplace conversations, but the federal short-haul exception most people mean generally allows a 150 air-mile radius. Eligible drivers can avoid a standard daily logbook and, when they are not required to keep a RODS, may not need an ELD for that qualifying work. They must still meet the applicable radius, duty-period, return, rest, and recordkeeping requirements.

For the governing language, consult the current text of 49 CFR 395.1(e) and the relevant hours-of-service provisions in 49 CFR Part 395. State rules may also apply to intrastate operations.