ANALYSIS: Single State Registration System resurrected

| 8/2/2007

Although the old Single State Registration System was repealed effective the first of this year, a recent mandate from Congress has set in motion a directive that will bring SSRS back to life – at least for a while.

SSRS is a federally mandated program for interstate motor carriers under which fees are collected annually on a per-truck basis by the state where the applicant’s principle place of business is located, or where he or she operates the largest number of trucks.

Language contained in the most recent highway reauthorization bill signed into law in August 2005 repealed SSRS effective Jan. 1, 2007. The Unified Carrier Registration Act also required development of a replacement program to ensure states will continue to receive funding. However, work on the new program has been slower than anticipated, and there’s no use sticking a fork in it – it’s not done.

“The UCR board has been working hard to pull the plan together in time. It’s not from lack of trying,” said OOIDA Director of Regulatory Affairs Rick Craig. “To begin with, Congress failed to provide funding for the board to do its work, and to make matters worse, the board wasn’t officially appointed until May of 2006.”

Craig is one of the five trucking industry representatives who serve on the UCR Board of Directors.

Unified Carrier Registration – or UCR as it’s called – is a plan that will have a fee structure that goes from the old per-truck basis to a per-carrier basis and will be the same for all member states. Truckers will no longer have to pick and choose states, as they do with the SSRS system. One fee will cover all states. The new UCR plan will apply to for-hire, whether exempt or regulated, and private motor carriers that operate in interstate commerce. It will also apply to leasing companies, freight forwarders and brokers.

The resurrection of the old SSRS system was part of motor carrier-related sections of a bill that implements recommendations of the Sept. 11 Commission Act of 2007. The bill emerged from a congressional conference committee last week with the SSRS language included as a late insertion by Sen. Jay Rockefeller, D-WV. Both the House and Senate have approved the bill. It has been submitted to President George W. Bush for his signature.

The bill now before the president sets Oct. 1, 2007, as the deadline for FMCSA to issue final regulations to establish a UCR system and set fees.

Craig says the Oct. 1 deadline is likely impossible. If the deadline is not met, SSRS will be in effect for this year, retroactive to Jan. 1, 2007.

Craig also said that while much of the UCR program is in place and can be done before the end of the year, the total UCR System that the feds plan to use for “one stop shopping” can’t be ready that soon. He explained the UCR System involves combining various databases into one. That database still has to be built.

“FMCSA published a proposal to establish the rules for what they term the Unified Registration System – or URS – in May of 2005, before the UCR Act was enacted,” said Craig. “We’ve been expecting a supplemental notice incorporating provisions of the law, but nothing yet. It could take two years, even more to get the required regulations in place.”

While the feds build the big UCR database, how close to completion is the UCR program? Craig said the board is very close to establishing the plan, which is comprised of several parts, including the agreement document and guidelines, a depository, and the fee structure.

Could SSRS and UCR both be running at the same time for 2007? The answer is yes.

“In fact, we could see some states charging the much higher SSRS fees and other states charging fees under the UCR program,” Craig said. “Conceivably, some states could get greedy and charge fees under both.”

And OOIDA thinks that scenario sets off some serious alarm bells.

– By Sandi Soendker, managing editor