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A private intrastate company with a large box truck receives a plea to move some items for a related company across the state line. The move will pay handsomely, and the truck is available. “It should be no problem,” says the owner, “I just need to get some permits for the move.”

Seems simple enough. Or is it? After making a few calls, the owner finds several issues that could throw the potential revenue opportunity off course.

Issue 1: Changing from intrastate to interstate

This move is straightforward. The driver, truck, and load are crossing a state line – the move is an interstate movement. The company may have a USDOT number because the state requires one for their intrastate carriers, but a USDOT number itself does not allow for interstate travel. The company needs to register with the Federal Motor Carrier Safety Administration (FMCSA) as an interstate carrier.

Registering as an interstate carrier
The company already has a USDOT numberSubmit an updated MCS-150 to the FMCSA indicating that the company operation is interstate
The company does not have a USDOT numberSubmit the MCSA-1 registration application

Either way, no major delay will result, but the carrier will be subject to a new entrant audit.

There are no permits that allow an entity that is not registered with the FMCSA as an interstate carrier to have any part of an interstate movement.

Issue 2: Establishing for-hire authority

As noted, the company in this example is a private carrier. Even if the carrier has some sort of state authority, in order to operate as a for-hire carrier in interstate commerce, authority must be requested and granted by the FMCSA.

For-hire authority is also known as a motor carrier or MC number. The process to obtain authority takes much longer than receiving a USDOT number - it could take up to eight weeks or more. To obtain for-hire authority, a carrier also needs to:

  • Designate process agents, and
  • Demonstrate financial responsibility.

As with FMCSA registration, there are no trip permits for operating authority.

Issue 3: Filing under Unified Carrier Registration (UCR)

Private property carriers, for-hire passenger, property, and exempt commodity carriers, freight forwarders, leasing companies, and brokers engaged in interstate commerce are subject to annual UCR registration. Each entity must submit an annual filing and be registered before operating in interstate commerce. UCR fees are based on the number of vehicles engaged in interstate commerce.

Like the interstate USDOT number and for-hire authority, there are no trip permits to cover UCR fees.

Issue 4: Addressing vehicle registration and fuel tax

When operating intrastate, vehicle registration and fuel tax responsibilities are simple. The carrier registers the vehicles annually and receives a state tag, and pays fuel tax at the pumps. There are no reports to complete and no records to maintain.

This is not the case when traveling interstate. With revenue at stake, each state on the route wants their share. Most carriers that regularly engage in interstate transportation with qualifying vehicles participate in:

  • Apportion their vehicles under the International Registration Plan (IRP), and
  • Pay fuel taxes via the International Fuel Tax Agreement (IFTA).

Trip permits are available to cover fuel tax and registration fees on a trip-by-trip basis. If a vehicle travels out of state more than five times a year, the company may want to consider permanent credentials.

Key to remember: Changing operations from intrastate to interstate is possible but may take some time. Temporary permits are not an option for most of the required credentials.