First off, I would like to congratulate 10-4 Magazine for taking over the Truckin’ for Kids Show & Drags, which has been a Southern California staple for 40 years. NorthAmerican Transportation Association (NTA) will be a major sponsor for this annual show. We look forward to seeing you all at this fun charity event in 2022. Now, on to our matters at hand for this month – let’s talk about the Unified Carrier Registration.
The Unified Carrier Registration (UCR) enrollment period for 2022 is open from October 1, 2021, through December 31, 2021. As registration becomes top of mind for many carriers, now is a good time to review some of the most frequently asked questions about the UCR. Let’s begin with who must register. All interstate carriers operating commercial motor vehicles (CMVs) under the following categories are subject to the UCR: property carriers (both for-hire and private); for-hire passenger carriers; freight forwarders; brokers; and leasing companies that lease vehicles (but not drivers) to interstate carriers or freight forwarders.
Under the UCR, a CMV is defined as a self-propelled vehicle used primarily to transport passengers or cargo, if the vehicle: 1) has a gross vehicle weight rating or gross vehicle weight of at least 10,001 pounds, whichever is greater, or when connected to trailing equipment has a gross combination weight rating or gross combination weight of at least 10,001 pounds, whichever is greater; 2) carries placarded amounts of hazardous materials, regardless of the vehicle’s weight; or 3) is designed to carry more than 10 passengers, including the driver. Note: carriers based in Canada or Mexico with trucks operating in the United States are also required to register under the UCR.
The next question you need to answer is, “Are we an interstate or intrastate carrier?” It seems fairly straightforward, right? Interstate transportation involves a vehicle crossing borders and operating in two or more jurisdictions, and a truck that never leaves a state would seem to be operating intrastate. Surprisingly, this is not always true. The Federal Motor Carrier Safety Administration (FMCSA) provides the definition of interstate transportation in 49 CFR 390.5.
Determining whether you are an interstate or intrastate carrier begins with this definition: Interstate commerce means trade, traffic, or transportation in the United States: 1) between a place in a state and a place outside of that state (including a place outside of the United States); 2) between two places in a state through another state or a place outside of the United States; or 3) between two places in a state as part of trade, traffic, or transportation originating or terminating outside the state or the United States.
The first two parts of this definition are clear – a vehicle crossing a border means interstate commerce. It is the third part of the definition that complicates things – interstate commerce involves more than just the physical vehicle crossing a state boundary. When either the vehicle, its passengers, or cargo cross a state boundary, or there is intent to cross a state boundary, the carrier is considered an interstate carrier, even though the CMVs it operates never cross a border. For purposes of the UCR program, an interstate carrier is defined under the terms laid out by FMCSA.
The UCR Plan is part of a federally mandated program where states collect fees from carriers and other entities based on the number of qualifying CMVs in their fleets. A yearly registration and fee payment is required. Here are how the fees break down: If you have 0-2 CMVs in your fleet your fee is $59; if you have 3-5 CMVs in your fleet your fee is $176; if you have 6-20 CMVs in your fleet your fee is $351; if you have 21-100 CMVs in your fleet your fee is $1,224; if you have 101-1,000 CMVs in your fleet your fee is $5,835; and if you have 1,001 or more CMVs in your fleet your fee is $56,977.
When determining the total count of CMVs in your fleet, only power units are counted – trailers by themselves are not to be considered when determining the fleet size. Under the UCR program, a fleet size is determined by the number of vehicles the UCR registrant declared it owns or operates on the last Form MCS-150 it filed with the FMCSA, or the number of vehicles the UCR registrant owned or operated during the 12-month span ending on June 30 of the previous year for which the UCR fee is being determined.
It is up to you to decide which method to use but choose carefully. Since the MCS-150 must be filed only every two years, the total vehicle count could be different under the two methods listed. For example, if you are required to update your MCS-150 every even year (2020, 2022, 2024, etc.), and the last time you updated in 2020 you had a fleet size of 5 vehicles, but during calendar year 2021 your fleet grew to 15 vehicles, you have now moved into a different fee bracket, and using the 2020 MCS-150 count would no longer be accurate. Note: a CMV is considered to be interstate if it operates – even only once a year – in interstate commerce and must be included in the fleet count.
So, how do you register? Carriers must register each year under the UCR Plan, and registration information and e-filing are available for all motor carriers on the UCR website (www.ucr.gov). You can also choose to use a third-party permitting service to help manage your UCR compliance. There are many reputable third-party administrators who can manage the registration, just be sure you understand the terms and conditions to which you are agreeing when choosing one of these third-party partners. Some services have an automatic renewal and fee process which could lead to underpayment or overpayment based on changes to your fleet size.
J.J. Keller offers a UCR management service, so whether you’re setting up your initial UCR registration or need help with your renewal, J.J. Keller will ensure your information is accurate and your UCR renewal gets completed on time. J.J. Keller is an endorsed Service Provider of the NorthAmerican Transportation Association (NTA), so if you have any further questions or concerns, feel free to call us at (800) 805-0040 or visit our website (www.ntassoc.com) today.