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General Notice on Trucking

USDOT NUMBER AND THE UCR

When the federal UCR (Unified Carrier Registration) debuted in 2007, it swept up many contractors, exempt-for-hire and private carriers—including farmers—in its registration and payment requirements. A pre-requisite of the UCR is registration for the USDOT Number. The requirement is triggered by the “interstate commerce” nature of most farm-to- market deliveries.

1.      Do these rules apply to Farmers?
Yes, if commercial trucks, contractors, and farmers operate a commercial vehicle in interstate commerce. There is no farmer exemption from the UCR or USDOT Number.

2.      What are these programs for?
The UCR is a fee collection system. The fees associated with the Unified Carrier Registration (UCR) are used by states to enforce “safety” (Motor Carrier Safety Regulations) and “fitness” (insurance) regulations. The USDOT Number is a federal identification system. The registration of carriers (under the USDOT Number program) and the marking of vehicles allows enforcement agencies to track all vehicles operated by an individual carrier in order to establish the safety record for the carrier’s entire fleet.

3.      Does my insurance carrier need to provide proof of insurance?
If you have applied for hire status (to haul others’ property), or if you haul hazardous materials, your insurance carrier needs to show financial responsibility. Contact your agent for assistance. Most private carriers don’t require proof of insurance. If in doubt, contact the FMCSA.

4.      Who is subject to the UCR and USDOT Number?
Regulated for-hire motor carriers and unregulated private and exempt carriers, as well as brokers, freight forwarders, and leasing companies who operate commercial vehicles in interstate commerce are all required to register and pay fees.

5.      How do I figure out if I have to register my operation under either program?
You are required to register if your operation includes at least one vehicle that meets both of the following two conditions (A & B):
         A.     It must be a “commercial vehicle”.
That has nothing to do with for-hire hauling. Instead, it is generally based on the vehicle’s size. Virtually every farm truck and truck/trailer combination is considered a “commercial vehicle.” For purposes of the UCR and the USDOT Number registration, a commercial vehicle is one vehicle or a combination of vehicles that is operated in commerce (includes farming) and has a gross vehicle weight rating (GVWR) of at least 10,001 pounds or, in the case of a passenger vehicle, is one built to carry 9 or more persons (for hire) or 16 or more persons (not for hire), including the driver. It also includes a vehicle that transports hazardous materials in a quantity that requires the vehicle to be placarded.
          B.     It must be used in “interstate commerce”.
Federal regulations define interstate commerce as follows [49CFR390.5]:
Interstate commerce means trade, traffic, or transportation in the United States—
                  1)      Between a place in a State and a place outside of such State (including a place outside of the United States);
                  2)      Between two places in a State through another State. If you need a USDOT Number, you will also need the UCR. A pre-requisite of the UCR is registration for the USDOT Number. Today, the vast majority of Idaho farmers find their farm trucking operations subject to both USDOT and UCR registrations. The requirement is triggered by the “interstate commerce” nature of most farm-to- market deliveries. This document will help sort out the conditions for, and the process of, registration.
                  3)      Between two places in a State as part of trade, traffic, or transportation originating or terminating outside the State or the United States.

Farming, construction and trucking is commerce (you’re trying to make a buck), so that part is easy. The more difficult distinction is whether the truck is operated in “interstate commerce.” Your operation can be considered trucking in “interstate commerce” in either of two ways. Crossing the state line is clearly an interstate move. However, traveling point-to-point within the State of Idaho is also considered interstate commerce if the load you’re hauling is part of an interstate shipment (generally, cargo that originates in one state and is ultimately destined for another state or country.)

6.      I don’t really have a commercial truck, just a “farm”-plated truck.
In this case, the term "commercial" has nothing to do with the license plate or “for-hire” hauling. For purposes of the UCR and the USDOT Number, a farm truck is considered “commercial” generally based on its size. If it is over 10,000 pounds GVWR or a combination vehicle (truck & trailer) with a GCWR over 10,000 pounds, it’s commercial. A “farm” license plate does not determine the commercial or non-commercial status.

7.      Does the UCR replace the USDOT Number?
No. The UCR is in addition to the USDOT Number registration. The USDOT Number is an identification system. The UCR is a fee collection system. But they both use the identical trigger mechanism, so if you need one registration, you’ll also need the other.

8.      How is the number of vehicles counted?
Count only the power units, not the trailers. Typically, use the number of commercial vehicles operated in interstate commerce in the 12-month period ending June 30 of the prior year or the number entered on form MCS-150 when first applying for the USDOT Number.

9.      How do I register for the USDOT Number?
New applicants must register for the USDOT Number using the Unified Registration System (URS) website (https://www.fmcsa.dot.gov/registration.) For first-time applicants there is a one-time up-front charge of $300 to apply for the USDOT Number. You are required to use Form MCSR-1, which will be provided as part of the online process.

10.   I’m just getting started in interstate hauling, what can I expect under the UCR and USDOT Number programs?
Motor carriers who are new entrants into interstate commerce should register under both the UCR and the USDOT Number programs before they begin operations in interstate commerce. Under a Congressional requirement stemming from the 9/11 terrorist incident, first-time applicants for a USDOT Number from the federal government will undergo a new-entrant safety assurance audit within 12 months of their application. All first-time carrier applicants for a USDOT Number will be automatically enrolled in the FMCSA New Entrant Safety Assurance Program. This program requires new entrants to pass a safety audit and maintain acceptable roadside safety performance over an initial 12-month period before they are given permanent registration status. [FMCSA]

11.   How to display the USDOT Number [390.21]
The following information must be displayed on both sides of each power unit (not trailers) operated by the carrier:
         •        The legal name, or a single trade name, of the business entity that owns or controls the motor carrier operation. (Match that used on Form MCSR-1.)
         •        The motor carrier identification number issued by the FMCSA, preceded by the letters “USDOT”.
         •        In letters that contrast with background and are legible from 50 feet in daylight.
         •        May be painted on or included on an attached sign.
         •        City, state and address are optional

Biennial Update of USDOT Number
Every holder of a USDOT Number must update their information every two years by filing form MCS-150—even if there have been no changes. If the next-to-the-last digit in your assigned number is even, then file in even numbered years; if odd, file in odd-numbered years. The last digit of your assigned number will dictate the month: 1=January; 2=February; 3=March; 4=April; 5=May; 6=June; 7=July; 8=August; 9=September; and 0=October. FMCSA will send a reminder in advance. There can be a penalty for failing to complete that update. Form MCS-150 may be used only to update the USDOT Number, not for initial registration.

More Information

        •        USDOT Number
                  o   To determine whether the USDOT Number is required of you, visit: http://www.fmcsa.dot.gov/registration/do-i-needusdot-number
                  o   More information about the USDOT Number is available by calling 1-800-832-5660 or on the USDOT website at http://www.fmcsa.dot.gov/forms/forms.htm
Registration can be completed instantly online. Paper-based registration is available, but can take three weeks to complete:
Federal Motor Carrier Safety Admin.
3250 Executive Park Drive Springfield, IL 62615
Phone: 217-492-4608 or 800-832-5660

Portions of this information are used with permission from the Illinois Farm Bureau.