Unregistered Carriers on 10/22/2009 - 1831
Unregistered Carriers on 10/23/2009 - 1833
Approach #3 - WE’LL REGISTER ALL CARRIERS WHO “SHOW UP”
When I talk about states who “register all carriers who ‘show up’”, I am referring to states who believe their job is to wait until carriers “show up” - whether by walking in, by mail or by fax - to take care of compliance. These states do not feel any particular need to go out and “beat the bushes” for carriers - which is the real point of distinction here - because the only carriers they normally deal with come to them.
Take, for example, agencies that, in addition to UCR, also handle IRP (and, to a lesser extent, IFTA). The IRP folks know that their carriers can’t even get out on the road without coming to them. They have the benefit of registering these same carriers for UCR when they come to take care of IRP compliance.
But even many agencies who don’t handle the traditional “they have to come to us” programs have this same approach. “We don’t go out and look for business – business comes to us. If they don’t come to us, we don’t think much about them.”
It has a certain appealing ring to it, right? And if you’ve never had to “generate business” for a living, it makes a ton of sense. Business know that if you open the doors and just wait for the customers, you'll be closing the doors before long.
Personally, I think it raises one of the most interesting questions I’ve encountered lately – what, exactly, is the role of government in this case? Go find ‘em – or wait for them to find you?
Industry has obviously been banging the “States need to go find the carriers” drum hard. The Feds seem to think the States are, for the most part, doing enough.
Either way, I have a couple of issues with this approach.
First, this approach turns a relatively “blind eye” toward everybody who doesn’t “show up”.
“I don’t know if there’s anybody else out there or not - my only job is right here.” OK, we’ve got that. But your agency is responsible for making UCR work in your state. Chances are good that your agency asked for the program.
But, because some of the definitions are different between programs like IRP/IFTA and UCR, the agency that does one program may not even be thinking about other carriers that fit UCR definitions but do not fit IRP/IFTA definitions. So … everybody isn’t inherently going to be coming to you.
For example, what if I work in the IRP section? Are carriers who operate vehicles between 10K and 26K pounds going to show up at my IRP agency? Probably not. So, who will cause these carriers to get a USDOT number and register them for UCR? Nobody. Do you really think that one or two mailings are sufficient to bridge that gap?
And, if that same state is low on enforcement resources – or if those enforcement resources are mostly focused on issues other than UCR – that state could be teeming with potential UCR candidates that will probably never register. Heck, despite your one or two letters, many of them will still never have heard of UCR.
Second, it dramatically increases the likelihood of under-collecting UCR revenue.
If I’m short of revenue, my main recourse appears to be: I guess I’ll just sit here and wring my hands - and hope more people show up. Good luck with that! Sometimes, you just have to go out and find the money. We have a lot more recipient states than donor states. Maybe it’s time to consider another approach.
Third, you may have an "artificially high" registration percentage.
I say "artificially high" because if you only UCR register carriers who come to you for plates - you SHOULD have a high UCR percentage. But it may not be a representation of how many of your state's carriers should be registered especially if you have weak roadside enforcement. I'll talk more about this concern in upcoming posts.
Next time, I’m going to talk about “Registering the UCR Universe Carriers”.
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