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SEASON TWO

SEASON TWO: EPISODE ONE

THE AOBRD PHASEOUT: IS YOUR FLEET PREPARED?

Every business manager knows that, when you have institutionalized an operational technology, moving to a new system can feel like an impossible task. And the stakes increase when outside forces put a time constraint on that change. Some of the trucking businesses most forward-thinking managers provide a good example. Their tech? The driver-logging software known as AOBRDs. And, now, they have until December 2019 to migrate to new Electronic Logging Device (ELD) platforms. In this episode of RoadSigns, host Seth Clevenger maps the great tech migration from AOBRDS to ELDS and asks, “What will trucking's business leaders need to make the transition in time?”

FEATURED GUESTS

Fred brings 25 years of commercial vehicle law enforcement and government relations experience to Zonar where leads compliance related product development to meet the needs of customers today and tomorrow. Fred is a member of the American Trucking Association (ATA) Safety Policy Committee, Association of Equipment Management Professionals Safety Committee, Truck Renting and Leasing Association's Government Relations Committee and Equipment Technology Advisory Council.

Tom Bray is a Transportation Consultant in the Editorial Resources area at J. J. Keller & Associates, Inc. He specializes in motor carrier safety and operations management. He has authored whitepapers and presented webinars on a number of key transportation subjects. He is also a frequent speaker at transport safety seminars and conferences on topics such as hours of service, vehicle maintenance, cargo security, and driver fatigue. Prior to joining J. J. Keller, Tom worked in the trucking industry for 22 years, with responsibility for DOT compliance, policy development, driver human resources, driver training, training program development, CDL testing, claims management, and accident and injury prevention. 

Fred Fakkema

Tom Bray 

EP. 1

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Episode Transcript

Roadsigns S2E1.mp3

From Transport Topics in Washington D.C. This is RoadSigns. Here is your host Seth Clevenger.

Thank you for listening to RoadSigns the podcast series from Transport Topics that explores the trends and technologies that will shape the future of trucking. In this episode we're going to take a close look at an important deadline that is quickly approaching for much of the trucking industry. We all remember the mass adoption of electronic logging devices at the end of 2017 and into early 2018 as the federal ELD mandate went into effect. But that wasn't the end of this technology transition. Many fleets continue to use electronic logging systems categorized as an AOBRD, automatic onboard recording devices that pre-date the ELD rule. The regulation allowed early adopters that had already installed AOBRDs to keep using them for two years past the yearly implementation date. But that exemption will expire on December 16th of 2019. So between now and then the many fleets that are still using AOBRD technology must migrate to ELD but how can fleet managers successfully navigate this technology transition? And how will it change their operations? We'll set out to answer those questions in this episode. In most cases fleets will be able to update their devices to ELDs through a software update with no hardware changes. But the bigger adjustment may be adapting their operations and policies to reflect the new ruleset. To help us better understand the minutiae of this transition and how fleets can prepare for it, we're going to bring in two experts who are at the frontlines of this issue. Later in the program we're going to speak with Tom Bray, a transportation consultant at J.J. Keller & Associates who specializes in fleet safety and operations. But first I'm excited to welcome Fred Fakkema, Vice President of Compliance at Zonar, a provider of electronic logging devices and telematics systems for commercial trucks. Thanks for joining the program Fred.

Fred Fakkema: Thanks for having us. Always a privilege to work with each other. So fleets that are still running AOBRD and their trucks have until December 16th of this year to update their systems to fully fledged ELD.

Seth Clevenger: So Fred just how big of a transition will this be for the trucking industry?

Fred: I think most in the industry believe that it's going to be really big. We as owners saw a large surge of AOBRD purchases at the end of 2017. So between that and legacy users I think it's a significant number that needs to make the transition some are actually waiting until the very end like they did in 2017. So waiting as long as they can. But I really think it's going to be a big disruptor for the industry.

Seth Clevenger: Okay. And what about your case with Zonar? You know what percentage of your customers are running AOBRDs versus those who have already moved to the ELD software?

Fred:  Yeah with that big surge we saw at the end of 2017 we're actually at about 80 percent of our customers using AOBRD. Most wanted to stay on and use that ability to be less restrictive. But our goal is to have everybody transitioned over by the end of October of this year.

Seth: So Fred before we dive deeper into this I'd like to ask you to quickly explain the differences between running an AOBRD versus an ELD. In both cases you're using electronic driver logs but the software of course is designed around different rules. So how do those differences really play out in the real world trucking operations?

Fred: Well the biggest difference is the communication aspect for the data transfer so now rather than like a AOBRD you're just sent in an email or a fax to enforcement with your log you actually have to transmit the data to enforcement through a telematics approach which is web services based or email or through a local mechanism which is Bluetooth or USB. The other requirement is being synchronized with the ECM or the engine control module and you have to record engine status vehicle motion miles driven in engine hours and then you add those automatic entries that take place at 60 minutes or when engines on and off in the beginning and end of personal commands and yard moves and everybody knows about the great graph having to be displayed or printed as well at roadside. And then the really difficult thing for some carriers is the unassigned driving times because anytime you have a movement of that truck you have a driving event. And so if the person is not logged in then you have to account for that and identify driving. And the challenge really between AOBRD data to ELD is some of the automatic duty status changes with ELD, you don't have any. Not only is the on-duty not driving one it's that truck starts to move within that five miles an hour it automatically puts the driver into drive.

That's one of the only automatic duty changes that there is other than when it's not in motion for five consecutive minutes. And the driver hasn't responded to ELD or required to prompt them for a minute and then it changes the men to on duty not driving so there's those changes so in the real world it's all about what happens at the roadside and really at an audit.

Drivers really need to know how to utilize the device. I mean when the rule is made it was specifically designed for the driver to own their logs. Somewhat like it is with paper but now it's by the second rather than by the 15 minute interval. So they need to know how to operate the ELD and how to transfer that data and really interact with the device more so than they do with an AOBRD and then audit. Now our focus so they can be done electronically so the carrier and the inspector really have that data at their fingertips. So the importance of reports on the back end is really emphasized and key reports are unidentified driving report the malfunctions hours of service violation reports and odometer jump reports and then of course you have your personal conveyance and yard move reports. All those are really important for the back end to maintain compliance through the hours of service requirements.

Seth: OK. So certainly some differences around the rules and ultimately right now with AOBRD there's a certain level of flexibility that will be a little bit different under ELD right.

Fred: Yeah for sure it's going to be a real change for the drivers.

Seth: Now let's talk about what fleets will actually need to do to convert their AOBRDs into ELDs. Now for the most part this is going to be software updates maybe even over the air software updates right? How will this work?

Fred:  Yeah correct. The updates are pretty much done over the air meaning like if you have a mobile phone you get those notifications from your provider that you need to update and you say yes and then once it does you have to log back in and boom you're ready to roll again. It'll be the same thing from AOBRD to ELD that over the air update will occur the drivers will need to re log in and then they'll be ready to go on the ELD software. But it's really about planning if the carriers haven't talked to their provider they need to have that transition plan and drivers need to know when it's actually taking place. So they're not caught without their seven days of logs because there's a big difference between AOBRD logs and ELD logs.

Seth: Sure. And yeah, just you know speaking with many of the vendors out there, many of the ELD vendors it does seem that most of the more recent generations of AOBRDs will just need that software update. Much like your mobile phone. But for some of the older systems you know the ones that have kind of aged out for the most part know there may be some cases I hear where a hardware update would be necessary. Fred, what's your sense of how common that will be across the industry?

Fred: I think it's those legacy systems. You know AOBRD started in 1988. So there's still some of those systems out there but it's not as prevalent as we would think. I think a lot of the vendors have made efforts to replace that hardware because of the times of technology changing. And so I think most of your updates will be over the air.

Seth:  Okay. And Fred as you described there's certainly a lot more to this transition than just updating your technology and updating your software. So maybe just take us through some of the key operational changes fleets will need to make as they make this migration to ELDs.

Fred: Yeah there's operational and policy changes that need to occur and need to really do reviews especially highlighting editing how drivers and dispatchers can manage that personal conveyance. What's your policy on that and adhering to those policies and yard moves as well. There's different things that happen in the yard whether it's a wash person or a mechanic or another driver moving the vehicle once it moves you have that that drive event. So having a policy on that and then unassigned driving is gonna be one of the biggest key that take place as well. For the carrier. But obviously with all this training is the key to understanding the differences between both systems ensuring the drivers are adequately trained and what to expect once they start using that ELD and then knowing that you're pre 2000 are exempt. So are you going to use alternative sources to install any ELD or are you going to run paper and how is that going to impact your operation as well.

Seth:  Sure. I mean training certainly seems to be one of the key threads I hear about this and certainly drivers but also back office right?

Fred: Absolutely yes.

Seth: So we mentioned this December 16th deadline. How soon do you think that fleets that are running AOBRD should begin working on this transition to ELD software?

Fred: Well the discussions really should be happening now and you should be planning to start that transition or set a timeframe and so you can prepare that training with your drivers with your dispatchers and understanding what needs to take place. And if you do need to replace your hardware now you're bringing in a vehicle to do the replacement maybe you need to change vendors or you want to change vendors.

Now is the time to start doing that planning because ELDs, as you know, offers more than just compliance hours of service rules. It's an investment within the business operation itself as well certainly.

Seth: Now today of course the nation's truck fleet is operating with a mix of AOBRDs and ELDs out there at the same time and that does make it pretty complex for roadside inspections. And Fred you have a background in law enforcement yourself. So I do want to get your take on this. What do you think that the AOBRD phaseout will mean for enforcement. Is this going to make things easier?

Fred: Yeah I think it make it a lot easier for enforcement one of the biggest pain points in this and from AOBRD to ELD is at the roadside. And it's really the driver not indicating that they're utilizing an AOBRD and then when they say he'll be the enforcement guy trying to treat it as an EOD when it's not. So you can't do the data transfer so there's a lot of confusion that has taken place around that.

I remember enforcement wasn't really up to speed on electronic logs and in fact a lot of them really didn't want to mess with electronic logs. But now they have to. And so as a get used to it I think it will be a lot easier that all of them will be an ELD. The challenge for enforcement is there's a lot of different vendors there's a lot of devices out there and knowing what to look for and how to prepare for that is going to make it a lot easier at roadside.

Seth:  And as we discuss this transition from AOBRD to ELD the industry is also going to have to deal with this move toward 4G and 5G and the sunsetting of older wireless networks. So you see these two factors essentially coming together to force potential hardware changes down the line for some of the fleets that are using older hardware.

Fred: Yeah we saw it from 2G to 3G. You know there is the G.P.S. products set that had to make that upgrade and there's a lot of disruption that took place during that timeframe. So I think it will be the same thing as we move from 3G to 4G and 5G our tablet support 4G and LTE. And with the new addition of RV-4, there's no concern on our end. But carriers really need to ask that question to their vendors are they still operating on under the 3G. Are they prepared for 4G? If not what is that transition and how will that take place. Because again just like this transition is I think it will be a disruptor and for the industry during that period of time so certainly a lot to manage from onboard technology perspective in the years ahead here.

Seth:  But before I let you go Fred is there any other advice you'd give the fleets that still need to make the switch to ELD what should they really keep in mind as they move through this transition in the coming months?

Fred: Well know that the date's not going to change so you need to be prepared have a transition plan you know work with your vendors to know what that plan is and then train the drivers the drivers need to know how to operate the device and interact with the device. And I'll make it that much easier at roadside and then what we tell our customers really is to annotate annotate, annotate, I mean mistakes are going to happen with electronic logs it's just going to happen but if you annotate that mistake and you can show that roadside it makes everything that much easier. And we always forget down the road. So during an audit you have that annotation as well there to reflect on. So it's gonna be an interesting time especially when December rolls around and we see what happens. But I you know have that partnership with your vendor and get it done right.

Seth: Yeah. Never a dull moment in the trucking industry is always something that's on the horizon. This is the one that's coming up on us pretty quickly here.

Fred: The technology industry is always changing.

Seth: No doubt about that. So Fred thank you so much for sharing your insights here. You know like I said you're right on the front lines of this and I have been following this very closely so we really appreciate your insight. Thanks for taking time to chat with us.

Fred: All right. Thank you very much.

Seth: Next on road signs we're pleased to welcome Tom Bray a transportation consultant at J.J. Keller & Associates specializing in motor carrier safety and operations management. Thanks for joining the program Tom.

Tom Bray: Glad to be here.

Seth: As I think most of our listeners will already know J.J. Keller is really focused on helping fleets comply with government regulations such as hours of service. The company's been a longtime supplier of paper logbooks for drivers but you've also been offering an electronic logging system for a number of years as well. So I'm eager to hear your thoughts on this migration from AOBRD to ELD. So Tom, what's your sense of how significant this transition will be for the trucking industry and is this going to be a challenge?

Tom: Yeah it's going to be a pretty significant change because it's going to involve hours of service a technology based system and a third party. You know like the carriers vendor so it's going to be significant. Just by virtue of the fact that involves hours of service alone, plus you add in those other factors it is going to be significant.

Seth: So we've already gone through a couple key milestones related to ELD. You know first we had the implementation date back in December of 2017 then the beginning of hours of service criteria in April 2018 for those core operating without logs. So how do you think that the AOBRD phase out coming this December and 2019 will compare with those previous ELD related deadlines?

Tom: Well the big hurdle for a lot of companies was making the switch from paper to electronic logs. But a lot of companies made that jump voluntarily years ago so for a lot of companies it wasn't a big deal. Where it was a big deal was the companies that waited until the end of 2017 to make the jump. Those are the ones that had a steep learning curve. They had to go through all at once and a lot of cases they didn't even know what they didn't know. And they had when they had really had no idea who even sold devices or how to vet or work with a vendor. Basically they didn't have a good plan for implementing. And you know this time around it's going to be an upgrade to an existing system so it's going to be easier but it's not going to be easy because there's a lot of things involved in this. You know that the change will impact all sections of the company from the drivers to dispatchers to maintenance. You know it's going to involve hours of service as I mentioned early which automatically is going to make it a big challenge. You know the drivers have to learn new habits even if they're using AOBRDs there's new habits involved that they need to learn when they switch into and easily the back office personnel are going to have to learn a new system. You're going to have to develop new policies and procedures for dealing with the system and the data that it's creating you're not used to seeing there's training that's going to be involved. You know there's drive performance tracking so that's just to name a few of the functions that are going to be involved. So in a way it's going to be similar to what happened last December where there's going to be a lot of things that are going to have to take place but it should be a little easier because the bigger hurdle is that jump from paper to electronic.

Seth: Yeah and they've already done that. We'll dive into more those details. But I'm curious what percentage of your e log customers are JJ Keller or running on the AOBRD system right now. And what percentage are already on ELDs.

Tom: Right now we have about 60 percent of our customers are still using AOBRD or only about 40 percent or less than 40 percent are using the ELD at this time. There's a lot of reasons for that. They're familiar with the AOBRD system. Otherwise they're using a system they're familiar with they want to hang on to as long as they can. And they're familiar with those rules. They know what the drivers need to do on the road. They know what they need to do in the back office. There's also the fact that you know a lot of them don't want to be on the cutting edge of this. You know they're seeing what's going on with other carriers that switched to ELD and they're just kind of waiting for everything to settle down and then the different habits in the industry that need to be developed to be out there and perfected before they make the jump.

Seth: Sure. And that's the advantage of being an early adopter. And in the case of AOBRD. So let's talk about the process when it's time to flip the switch to ELD. How will you convert yours into ELDs you know from a technology standpoint is this just a software update and what will fleets need to do when they're ready to make that migration?

Tom: For a system like ours it's basically just an over the air update. You know the technology part simple. The carrier just needs let us know that they're ready to make the switch and the update will be pushed out. What will happen to the drivers is they logout one night as an AOBRD. And then next morning they'll log in as an ELD. The technology part of it's really fairly simple, same with the back office to log out one night as an AOBRD system. Next morning as an ELD system however it’s the people part of it that's going to make this tough you know switching from and they'll be ready to appeal the lies I mentioned earlier touches basically everyone or the carrier so you need to get the people ready for the change. One thing a lot of companies learned from the last deadline was that anything related to hours of service and technology is not as simple as plugging it in. I want to switch you know getting the fleet ready as in planning on how to make the change you know working with your vendor to roll out training and create some in-house experts and having a vendor that can help you with the change. It's all going to be important when it comes to actually making that change. And then like a go circle back to the beginning the technology is actually the easy part right.

Seth: So let's talk more about the real challenge which is the training and operational changes that you're discussing. What are the biggest changes that you'll see as you switch from AOBRD to ELD? Say for the driver or dispatchers standpoint and the manager.

Tom: Yeah I'll start off with the drivers, the drivers are going to see a big change right away. The first time they go to log in when a driver uses an ELD part of the log in process is they're going to be offered any unassigned driving time that's on that device that's going to be a new thing for them and to help with the entire operating operation of the system. Gonna need to understand they need to grab that on the same time when it's offered to them if it's theirs. Of course it's not there's they shouldn't take it. That's the other thing. They need to know so right away from login it's going to be different for them. Nothing's going to change as anytime the vehicle hits five miles an hour it's going to be considering that time is drive time from there on and that's a change from AOBRDs. The rules were a lot different in so long as what you had set up was reasonable as far as speed or distance to make that driving decision it was pretty much allowed but ELDs have that hard and fast five mile an hour determination for driving. So that's going to surprise some drivers. Another big issue the drivers aren't gonna be used to seeing this ties into the back office directly or are the edit rates that are going to be given to a driver. Drivers can go in and edit pretty much anything except driving time and automatic data captures so you know a time they were on duty or off duty they go back in and change it. So there's a lot there and drivers need to understand what is a legitimate you know edit and what's not legitimate. Others when are you creating a false log if you go in and change that. So they need to understand that they also need to understand when they make an edit the who, what, where, and winds up automatically gonna be captured but they need to put in an explanation they need to clearly explain why you they can't put something in there. I made an error. They need to detail what happened. You know I forgot to log in I neglected to log out. Whatever the case may be just a why that it's necessary needs to be attached in there. Now in the back office doesn't edit what's going to happen the driver is going to see that come through the edit will come to the driver for approval.

Tom: So the drivers need to understand what that process is all about what they need to do as a driver I need to check that it make sure it's a corrected it in other words it's fixing a mistake that I made. And then recertify and resubmit that log so drivers need to understand that whole process that's involved and carriers need to understand their end of it so they know when they can go in and should go in and make it make an edit and then push it to the driver for approval. Now a big thing for drivers is gonna be the roadside inspection process that's going to be completely different if they have an AOBRD they just showed the display to the officer. Others a simple instruction card that explains how to get the information displayed on the screen that he needs to present the officer as well. And that's pretty much it. If the officer wants a hard copy the records the driver or their company have 48 hours to somehow get them to the officer. When the driver is using ELD the driver has to be able to not only display the records for the officer. They have to be able to transfer them to him as well which means using either telematics which is a web service or email specific e-mail system or a local transfer method which is USB or a Bluetooth to directly transfer those records to the officer. That's something the drivers have never done before. So that's it's something you really need to the drivers really need to thoroughly understand as a roadside inspection for drivers a high stress situation you don't want your driver stumbling through it hoping everything comes out well. So they've really got to be prepared for that part of it. And the other thing is that after less duty change in the day the driver needs to certify the log is correct and certify it. And that's just part of the daily functions they need to get used to doing with an ELD. So there's this it's just the driver part of it has got all those changes to it. You know as far as the back office goes one big change that blindsided a lot of carriers is when you have any of these systems you have to deal with unassigned driving times in the system. The system will have one specific bucket if you want to call it one specific account that all of the unassigned driving time the drivers aren't accepting comes into with the carrier has to do that as they have to go in with it on a safe driving time and either assign it to the correct driver or attach an explanation to it about why it couldn't be assigned to a driver. An example would be a driver doing a road test we hadn't hired yet. Something along those lines or a mechanic moving the vehicle around the yard. Something along some good explanation about why that unassigned couldn't be assigned, carriers not on top of that right from the get go that piles up fast. So they've got to really be ready for that. The other thing was that on a sign they need to pay attention to that because that's one of the most common ways drivers falsify with an electronic logging system in general is just to drive when not logged in. So for that reason you also need to be keeping track of that on assigned time and the other thing company is be aware of as you can't have generic accounts or ghost accounts, you can't have your maintenance account you can't have your road test the count that a lot of the AOBRD systems have each account in there has to be assigned to an individual and all of the driver codes need to have a drivers license assigned to it. So that kind of some of the things that carriers do now with AOBRDs using those generic or ghost accounts to deal with the unassigned driving time go away when you switch to an ELD system and that's something that you need to be prepared for as well. And last but not least in your maintenance group is going to need to be ready for this, because they'll be ready. They kind of hook into the system a grab fairly simple data streams with an AOBRD system. Real easy with an ELD, it's got to connect directly into the database and pull data directly from the ECM. So if that ECM has been corrupted somebody went in and reset parameters re flashed it did whatever they did you know goofed around with it somehow or if it's just over time has developed some glitches when you hook in ELD to it. It may not work and kind of the way you figure out that's what you got going on is you want to ELD to the vehicle it doesn't work you unplug it you plug another one in that one doesn't work. Well now we found the problem the problems with the vehicle. More than likely you have an ECM issue that you can need to address to your maintenance department. So even they're gonna get involved in this when it comes to those connectivity issues. So there is a lot there that they're going to experience as they try to migrate from AOBRDs the ELDs.

Seth: Yeah as you pointed out there's just a lot of detail a lot of fine points on little changes and fleet managers are really going to have a lot to unpack and make sure that they're the drivers and back office are aware of as they go through this process. So I do want to ask you also about the need for companies in some cases to update the policies and procedures to reflect the ELD rules language. You know think about editing driver logs and how that's different with ELDs for example. Is this a good time for fleets to really just go through all their policies and pursuit procedures and make those in alignment with the ELD rule?

Tom: Yeah you're pretty much going to have to do that because of the different things that come into play there's a vertical special driving categories that a driver using an ELD can have access to. There's the edit rights when is it a legitimate edit, when’s it not.

Tom: And if your policies don't address those issues it's going to create some problems for you. So yeah you're pretty much going to have to look through the hours of service policies and procedures that you have in place you know start to finish and make those align with the ELD system in other words what's this doing what can drivers be doing that they shouldn't be doing because that's what you want to look at. When you're developing policies and procedures so there's a lot there as far as your policies and procedures that need reviewed and updated here again if you already have AOBRDs you've probably got some of that stuff in there you probably address you know common ways drivers falsify with electronic logs it's just a matter you have to bring that up to date to match the ELD system versus the AOBRD system.

Seth: Sure. And you know if you're fleet running an AOBRD system, still I mean you're really looking at a mid-December deadline of this year to make this change. So what's your advice on the timing for that transition should those fleets already be trying to get a jump on this early or do you have a little bit of time to plan it out. What's your recommendation for how soon they should really jump on this?

Tom: Well this is a big change like we've been talking so it's something you want to actually use a change management approach towards where you can take time you know you're gonna want to start by getting with your vendor, you know they should be able to provide you with common problems answers how long it's going to take. Do what they should have some experience with the changeover and they should have some procedures that you know can help you get started as far as the planning phase of it goes. So that's kind of like step one. You know the next thing you need to look at is OK, now we've decided we're going to work with this vendor we're happy with what they have in place or you know maybe switch vendor or whatever you decide vendor wise in the planning phase. Now we need to start looking at when do we want to do this and how do we want to do it. So you know you've got to get things developed like how are we going to institute this for  back office people how are we going to develop our own super users. In other words work with the vendor to get some people in-house trained up to being experts with the system. So you've got those things to work through. And then you've got the training of the drivers and the dispatchers that have to use it day to day every day. And then you've got the actual mechanical change to make in other words the physical or over the air changed to make to get the new systems in. So yeah it's going to be a significant period of time. So you the sooner you get started the better you can always get the planning phase done, get everything set up get ready to go and then decide OK we're going to do it as of this date. So once you get that legwork done up front and it kind of becomes your decision on when you want to get the actual change done, you've got the policies in place you've got the training plan you've got your vendor situation straightened out you've worked with your vendor to get everything ironed out and have them provide what they can provide for you. So that's all done then it's just a matter of deciding OK. As of this date we're going to go. The one thing I'll mention is make sure to do it early because kind of like what happened last December that’s going to be in December 2017 right. There's going be a bandwidth issue that's going to develop the closer you get to the deadline. So you know if you're looking at rolling out third into third quarter third or fourth quarter you're going to be rolling it out at a time when you can actually kind of just roll into it work with it vendor support will be available. The closer in that deadline you wait till so if you wait till the end of fourth quarter you might be running into problems when you need your vendor help you there's gonna be so many people asking for their help right.

Seth: Oh and before we let you go Tom, I just wanna ask if there's any other final recommendations you might have that you like to share with the many fleets out there that still do need to go through this process and migrate their technology to the oldies.

Seth: Yeah like I just kind of went over start planning early and work with your vendor or the rear ally on this. They're the one that can help you with it. And don't underestimate what's gonna be involved. There's gonna be a lot involved so be ready for it.

Seth: All right well we hope the industry at large takes your advice and we have a smooth transition. We'll be watching it closely.