Extend the UCR Comment Period

This Editorial appears in the Sept. 14 print edition of Transport Topics. Click here to subscribe today.

At the very least, the Federal Motor Carrier Safety Administration needs to provide the freight transportation industry sufficient time to respond to its proposal to fix the clearly broken Unified Carrier Registration agreement.

As we’ve already said, the proposal — which would force carriers to pay enormous fee increases to operate their equipment — is a bad idea. And FMCSA’s plan to limit the comment period on its proposal to 15 days is absolutely unacceptable.

Last week, five industry groups, led by American Trucking Associations, formally asked FMCSA to extend the comment period to up to 60 days, to allow more parties to respond.



Otherwise, FMCSA’s comment period will expire on Friday, Sept. 18, just days after most parties first heard about the skyrocketing fee plan.

UCR was designed to be an equitable successor to the much-maligned Single State Registration System, under which truck registration fees were divided among states to compensate them for fleets’ using their roads.

Since SSRS was funded exclusively by the for-hire trucking industry, UCR was designed to spread the load to others — namely private fleets and freight brokers — to provide sufficient funds to the states by sharing the burden among more road users.

In practice, however, many states have failed to make sure that the new companies covered by UCR actually paid their fees. And since the UCR legislation required that the money provided to the states not fall below SSRS’ levels, FMCSA has to find a way to dig up the missing cash.

The agency has chosen to require unreasonable fee increases to the very fleets that have been obeying the rules and paying their fees, rather than demanding that states increase their efforts to collect fees that are due to the program.

Under the FMCSA proposal, UCR fees for the smallest fleets would rise to $87 a year from $39, while those fees for the largest fleets would balloon to $83,412 from $37,500.

In their letter to FMCSA the groups — ATA, the Transportation Intermediaries Association, the Owner-Operator Independent Drivers Association, Wal-Mart Stores Inc. and the National Private Truck Council — said the brief comment period “will serve to preclude many motor carriers and allied businesses, especially smaller ones, from submitting comments.”

Comment periods are designed to provide an opportunity for those affected by proposed rules to respond. We hope FMCSA sees the wisdom in extending the period to provide a reasonable window for fleets and shippers to express their reactions to this proposal.