Legislative Bulletin - August 13, 2010

TRALA Concerned with Elimination of Registrant-Only USDOT Numbers

The Federal Motor Carrier Safety Administration (FMCSA) has announced that they intend to eliminate “registrant-only” U.S. Department of Transportation (USDOT) numbers. Registrant-only USDOT numbers are used by registered owners of commercial motor vehicles (CMVs) that are not motor carriers, but lease their CMVs to motor carriers.

The registrant-only classification was established in 1999 specifically for lessors and many TRALA members currently use a registrant-only USDOT number. In announcing the federal government’s intention to drop registrant-only USDOT numbers, FMCSA stated in its August 9, 2010 Federal Register notice that they “are being used differently from what the Agency intended and thus the practice of issuing registrant-only numbers to entities that are not motor carriers is having an adverse affect on the Agency’s ability to track motor carriers’ safety violations.”

TRALA is concerned with the elimination of the registrant-only classification. In the absence of this option, a lessor would be required to register as private carrier, which would have additional implications and would not accurately reflect the nature of their business. More importantly, TRALA believes that the proposed change would not resolve the safety tracking problems outlined by the agency.

FMCSA’s commercial motor vehicle marking regulations allow a lessor’s USDOT number to remain on vehicles rented for 30 days or less. In these cases, the motor carrier is still operating under its own DOT number, which should be available on the rental agreement carried in the vehicle. Even with the elimination of the registrant-only number, law enforcement personnel would still be required to check the rental agreement for the vehicle operator’s USDOT number in order to insure accurate safety tracking.

TRALA intends to work with FMCSA to address lessor concerns with the elimination of the registrant-only USDOT classification. To see the announcement from FMCSA about their intent to eliminate registrant-only USDOT numbers, please click here. For more information, please contact TRALA’s Joe Sculley at jsculley@trala.org or by calling (703) 299-9120.