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  • Avery Vise

FMCSA plays it loose on URS facts

On July 20, the Federal Motor Carrier Safety Administration once again postponed full deployment of the Unified Registration System. In announcing second delay in the program -- the full URS originally was supposed to take effect Oct. 23, 2015, but was postponed until Sept. 30 of this year -- FMCSA took several liberties. That's a bit surprising because the very brief news announcement on the agency's website runs fewer than 150 words.

For starters, FMCSA has shown itself a bit mathematically challenged with item's headline: "FMCSA Announces Three-Month Extension of Unified Registration System Effective Date."

So, again, the previous effective date was Sept. 30. The new effective date is Jan. 17, 2017. That's not three months. In fact, it's closer to four months than it is to three months.

As someone who has written headlines for more than 30 years, I get it: "More than Three-Month" or Three-and-One-Half-Month" are cumbersome. But that doesn't give you license to be wrong. Just say "FMCSA Announces Extension of Unified Registration System Effective Date."

The more important misleading comments are at the end of the brief announcement, a passage that makes up more than a third of the entire item:

The agency estimates that the initial phase of URS, launched in December 2015, has saved the industry approximately $1.6 million in processing time during the first six months. To date, FMCSA has issued 62,000 USDOT numbers, removed 340,000 dormant USDOT numbers from agency databases, and screened 100% of operating authority applications for reincarnated carriers.

OK, there's probably nothing wrong factually with any of those statements, and for simplicity sake I'm willing to stipulate as such. But let's look at the comments in context of what the first phase of URS actually represented.

The first phase of URS applied only to entities that did not already have USDOT numbers. In other words, it applied mostly to companies that were not yet operating commercial motor vehicles. Yes, there were probably some interstate operations that needed USDOT numbers for whatever reason, but that's probably a small percentage.

So this $1.6 million in "industry" savings resulting from shortened processing time probably is a bit misleading. Most of these people weren't yet in the industry. Plus, it's unlikely that FMCSA's figure netted out the lost productivity due to training and unfamiliarity among companies that are in the business of registering carriers. Sure, that's a one-time cost, but FMCSA defined the benefits against a specific time period, so it's fair game.

The next two points appear to be irrelevant. Can FMCSA really claim that it would have issued fewer than 62,000 USDOT numbers absent the first phase of URS? The number of USDOT numbers issued is a function of how many people and companies seek them. By all accounts, USDOT numbers have never been a bottleneck; rather, what takes time has been confirming process agents and insurance for for-hire carriers and allowing the protest period to run.

The next point is even more clearly irrelevant. The first phase of URS applies solely to new applicants for USDOT numbers. Entities that already had USDOT numbers -- even those that seek new or additional operating authority -- continue to use the same methods they had been using to file for authority and submit their MCS-150 forms. In other words, as of today URS has nothing to do with removing dormant USDOT numbers from FMCSA databases. Indeed, that was a process that began well before December 2015.

And that brings us to the 100% screening of operating authority applications for reincarnated carriers. There likely is at least some truth to this. Just the fact that all applications for authority are now filed electronically and, apparently, are being matched against information in existing databases likely helps with this task.

However, this touted benefit begs a question related to FMCSA's plan to stop issuing MC and FF numbers on Jan. 17, 2017. The agency has on numerous occasions declared that doing away with docket numbers and using just the USDOT number for everyone will help catch reincarnated carriers. But FMCSA is still issuing MC and FF numbers under phase 1 of URS. So if this particular URS benefit has already been realized, then why discard docket numbers?

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