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Qualifying for a lower fee category under the Unified Carrier Registration (UCR) program can result in significant savings. However, it may also wave a yellow flag for auditors, so it’s important to get it right. With enrollment now open for 2023, now’s the time to check your numbers.

The process of counting your vehicles to determine your fee category has four steps – and note that intrastate vehicles are included with interstate vehicles, at least through the third step:

  1. Determine how many vehicles the registrant owns or operates.
  2. Determine how many owned or operated vehicles are commercial motor vehicles (CMVs).
  3. Determine the relevant time period of the vehicle count.
  4. Exercise (or not) certain options to add or subtract vehicles from the number of commercial motor vehicles owned or operated.

1. Owned or operated

Only vehicles owned or operated by a motor carrier or freight forwarder count toward its UCR fee. These include all vehicles that are either:

  • Registered in the name of the carrier or freight forwarder, or
  • Controlled by it under a long-term lease (one of thirty days or more) during a vehicle registration year.

Two points are important to note:

  • Ownership of the vehicle is not the determining factor, but the name under which it is registered.
  • A vehicle is not considered controlled by the carrier or freight forwarder if it is operated only under a short-term lease (one of less than 30 days).

2. Commercial motor vehicles

For purposes of the UCR, a CMV is defined as a self-propelled vehicle used on the highways in commerce principally to transport passengers or cargo, if the vehicle:

  • 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; or
  • Carries placarded amounts of hazardous materials, regardless of the vehicle’s weight; or
  • Is designed to carry more than 10 passengers, including the driver.

For purposes of the UCR fee, only power units are countable. However, the gross weight of a combination vehicle, that is, a power unit and whatever trailing equipment it may haul, determines whether the power unit is countable for UCR purposes. If the gross registered weight, gross weight rating, or actual gross weight of a combination exceeds 10,000 pounds, the combination is considered a commercial motor vehicle, and the power unit of the combination is countable for UCR if the combination is operated in interstate commerce. This is true even though, by itself, the power unit may weigh 10,000 pounds or less.

A vehicle that operates solely off-road is not counted.

A vehicle that has equipment mounted on it (mobile cranes, etc.) is a CMV under UCR.

CMVs operated entirely in intrastate commerce are to be counted. (See Step 4 for conditions under which they may be excluded from the final fleet count.)

3. Relevant time period

The size of a carrier or freight forwarder fleet is determined as either:

  • The number the UCR registrant declared it owns or operates on the last Form MCS-150 it filed with the Federal Motor Carrier Safety Administration (Option A on the registration form), or
  • The number the UCR registrant owned or operated during the year ending the June 30 before the beginning of the calendar year for which the UCR fee is being determined (Option B on the registration form).

4. Optional adjustments

At this point, the registrant should have determined the full count of CMVs, both interstate and intrastate, in its fleet. Now, UCR allows certain types of registrants to add or subtract certain categories of vehicles to arrive at the final count for purposes of determining their fees. Note that taking advantage of these provisions is entirely optional and not all types of carriers have these options:

  • Some registrants may include smaller vehicles in their fleets for purposes of the UCR fee.
  • Some registrants may exclude intrastate vehicles.

Including smaller vehicles: A for-hire motor carrier may include in the count of its fleet for purposes of the UCR fee any of the motor vehicles, regardless of their weight or the number of passengers for which they are designed, which the carrier operates on the highway to carry either freight or passengers for compensation.

A freight forwarder is not eligible to include such vehicles, and a private carrier of property is also disqualified by the requirement of hauling for compensation, which private carriers, by definition, don’t do.

Why do this? A motor carrier may wish to include its smaller vehicles since federal law (49 U.S. Code section 14506) bars state and local governments from imposing most credential requirements on an interstate motor carrier’s vehicles that have been included in its fleet when determining the carrier’s UCR fee.

Excluding intrastate vehicles: A motor carrier, either for-hire or private, may exclude vehicles that operate only in intrastate commerce in the transportation of property (including, for this purpose, waste and recyclables) from its fleet count for purposes of the UCR fee. Note that:

  • Freight forwarders are not eligible for this exclusion.
  • A motor carrier may not exclude intrastate passenger vehicles.

Remember that under UCR a vehicle is in interstate commerce if it ever, even once, during the year in question, crosses a state line or into a foreign country, or ever during that year carries either freight or passengers that began their movement in another state or country or will finish their movement in another state or country. Under the UCR definition, a great many motor vehicles that never leave a state must still be counted as interstate for purposes of calculating UCR fees.

Key to remember: Counting vehicles to determine your fee category under UCR is not a simple process, but hopefully this step-by-step method makes it easier. The UCR enrollment period for 2023 opened October 1, with registration and fees due by January 1, 2023.