What Did UCR Participating States Agree To Do?

Unregistered Carriers on 10/19/2009 - 1891
Unregistered Carriers on 10/20/2009 - 1867

In the interest of brevity, I'm not going to spend time exploring the subtle nuances of our respective Participation Agreements. I'm going to cut to the chase and say that from a "States aren't doing enough" performance standpoint, States agreed to do two things in their Participation Agreement: register carriers and enforce the UCR program.

The enforcement issue has been pretty well vetted. I would argue that the States are doing quite a bit, but I don't intend that to be a provocation. "Quite a bit" may not equate to "enough" - but then "enough" has never really been defined.

States enforce at least two different ways: administrative and roadside. Administrative enforcement varies depending upon the agency administering the UCR program. Most agencies withhold whatever they can withhold - plates, tags, authorities - if a carrier has not registered for UCR. Roadside enforcement varies from State to State depending on resources, laws, etc. Again, this issue has been hashed and rehashed. No need to go into it here.

What I'd really like to get to is the subject of UCR registration. In my opinion, when we signed our respective Participation Agreements, I think we each agreed to do an "honorable" job of UCR registration in exchange for our "entitlement" funds. I believe that we agreed to be responsible for doing our part. The question has become, "What, exactly, did we agree to be responsible for?"

I'm going to hazard an attempt to define our responsibilities under UCR. It goes something like this:

I believe we are responsible for registering ALL carriers that the rest of the states are counting on us to register - whether they be in our own state, in non-participating states or in Mexico or Canada.

ALL of them! Too ambitious? Personally, I don't think so. Can we accomplish that? No, at least not in the literal sense. But from the standpoint of establishing responsibility, I think it's accurate. I know that very few states would agree with me - in fact, it's entirely possible that nobody agrees with me. But as we deviate from that lofty goal of total registration, it becomes a "slippery slope". And we will definitely act differently if we are trying to register ALL of them than if our goal is to register most, some or a few of them.

Over the next few days, I will discuss a variety of approaches that States appear to be taking with regard to their registration responsibilities under UCR. They are not judgments. They are not critiques. They are merely observations that I hope will be helpful in evaluating our collective registration effort ... at a time when our collective registration effort is "under fire".

Tune in tomorrow when I will explore the first of these approaches: Let's do as little as possible.