Thursday, October 22, 2009

Different UCR Approaches - Part 2

Unregistered Carriers on 10/21/2009 - 1841
Unregistered Carriers on 10/22/2009 - 1831

Yesterday, we talked about doing the least amount possible. Today, we're going to discuss:

WE’LL REGISTER UNTIL WE HIT OUR CAP

Obviously, this can only happen in a state that is looking forward to actually hitting their cap – which is clearly the exception rather than the rule these days. More power to you on hitting that cap! But we need to talk.

This approach – like Approach #1 - is perfectly understandable from the standpoint of the state adopting this approach. Why continue to collect revenue that you can’t keep? Heck with that!

But this approach flies in the face of a - no, make that THE - central premise of UCR participation – if Donor States don’t keep collecting after they’ve hit their cap, then many Recipient States are doomed to remain in a deficit situation. We’re in this together, folks!

Consider the plight of a small state that has a legitimate entitlement of $2MM dollars.

Suppose that even if every carrier in their state registered - that's EVERY CARRIER (100% Registration) - they would only collect $1.5MM from their own carriers. Where does the other $.5MM come from? You guessed it - you!

“That’s not my problem” says the state taking this approach (you). Au contraire, mon frère! (That’s French for “What are you thinking???”) It is, in fact, your problem. You … and every other Donor State.

If your state is considering the "We'll keep collecting until we hit our cap" approach, consider how you will feel about this same issue if you don’t hit your cap next year. I predict that you will pray like crazy that all those Donor States will keep collecting money so that you will keep getting checks from the depository generated from the excess collections of – you know who - those wild and crazy Donor States!

Tune in tomorrow for Approach #3 - "We'll Register Everybody Who Shows Up At Our Door."

Wednesday, October 21, 2009

Exploring Different UCR Approaches - Part 1

Unregistered Carriers on 10/20/2009 - 1867
Unregistered Carriers on 10/21/2009 - 1841

As I indicated yesterday, I'm going to do a series of posts on different State approaches to UCR.

Approach #1 - LET’S DO AS LITTLE AS POSSIBLE

This approach is more understandable than might be apparent at first blush. It doesn’t mean “Let’s do next to nothing.” It means “Let’s do as little as we have to do so that people can't say that we're not doing anything.”

There are a variety of legitimate reasons why agencies might take this approach.

Maybe the agency is not getting much UCR money.

Some states are NOT getting millions of dollars in UCR revenue. In fact, some states aren’t getting enough revenue from the program to pay for setting up a decent UCR program ... if you figure that a "decent program" includes Registration, Administrative Enforcement and Roadside Enforcement.

Maybe the agency just doesn’t have enough internal resources.

In some cases, revenue isn't the problem, but States just don’t have the headcount to do much – especially in this economy. “I’ve got two people – and, in addition to UCR, those two people also have to accomplish X, Y and Z!”

Maybe the agency doesn’t know much about the UCR program.

In some cases, the program has shifted from one agency to the other. Maybe the first agency knew a lot about UCR, but the second agency has inherited the program without inheriting the people who understood the history or the objectives of the program – but they’re too proud or too whatever to ask for help. Maybe they don't even WANT the program - but got stuck with it anyway.

There are probably more reasons why "Let's do as little as possible" might be the approach of choice for a State, but these three give you an idea of why it may not a totally unreasonable or irresponsible approach.

Would we be better off without states that take this approach? I don't think so. That would just turn them into non-participating states --- which, in my opinion, is even worse. I think we'd be much better off trying to either 1) help them increase their performance or 2) get them to allow somebody else to take over where they leave off. I realize there's no precedent for that yet, but it's probably in everybody's best interest to explore the issue more.

Tomorrow, I'm going to discuss states who take the approach, "We're only going to register carriers until we hit our cap."

Tuesday, October 20, 2009

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.

Monday, October 19, 2009

What Is A UCR State's "Real" Responsibility?

Unregistered Carriers on 10/16/2009 - 1901
Unregistered Carriers on 10/19/2009 - 1891

I'm not going to keep doing the Pre-Add/Post-Add thing I referred to in my last post because it gets a little confusing, but I would like to point out that we added 62 new carriers over the weekend, which essentially "nullified" a great registration total on Friday. So far in October (11 work days), we have registered 673 carriers and taken in $51K.

This week, I'd like to share some observations about a participating state's responsibilities under the UCR program. Before I do, I'd like to once again point out that I see very few right or wrong answers regarding this issue, so I'm certainly not trying to point fingers or find fault. It's just a discussion.

We've all heard the mantra "the States aren't doing enough". But how do we know? Who defined "enough"? And, more importantly, how did they define it? Do any two of us - industry or state - even agree on a definition of "enough"?

Meanwhile, some UCR programs sit in DMV's, some in PUC's, some in Revenue Departments, some in DOT's ... and each of those types of agencies has its own definition of "enough" as it pertains to getting their constituents into compliance. Some of these entities conduct more than one program under their respective roofs(?) - IRP, IFTA, UCR, Intrastate Authority, MCSAP, etc. Some entities, like us, had never dealt with private carriers at all until UCR.

All of this is the backdrop for tomorrow's discussion - a litany of current and potential "attitudes" about UCR. I think you'll find that all of these "attitudes" have some merit. You might also find, as I have, that your own State's "attitude" might make sense for you, but not for other states.

Friday, October 16, 2009

UCR - TWTWTW

Unregistered Carriers on 10/15/2009 - 1904
Unregistered Carriers on 10/16/2009 - 1861 (Pre-Adds)
Unregistered Carriers on 10/16/2009 - 1901 (Post-Adds)

TWTWTW - That Was The Week That Was - TW3. Remember that old TV show? In truth, I never actually watched the show - I just thought the title was cool. And this has definitely been an interesting week. Not only did we get to do a couple of Live Meeting sessions about UCR - new technology, a chance to reach some folks who might need assistance , etc. - but, here in Illinois, we also registered a BUNCH of carriers.

I added an extra statistic to the post today in order to highlight what I've been saying about the "cornucopia of registrations" (see yesterday's title) we've been experiencing. Notice that I show both a "Pre-Adds" number and a "Post-Adds" number. Iteris runs the daily "Registration Percentage" report that most of us are familiar with very early each morning. That report gives us the "Pre-Adds" number. Then, at some point after they update that report, the Feds send them more data - new USDOT numbers, etc. - and the unregistered number for each state changes. 40 carriers got added back to Illinois' number after the report was run this morning. 40!!! So, even though we registered more than 60 carriers again yesterday, our Unregistered List went down by a whopping three carriers! Actually, that's very cool, but when you're trying to "get to zero", it's a challenge! A good challenge, though.

By the way, not that I'm watching this number closely or anything, but we are only 378 registrations behind California as of this morning. Unlike a couple of months ago, I now feel strongly that we'll catch them - unless, of course, they actually find out about this game and bury me! Competitions are so much easier when only one side knows about them!! The beauty of a silly competition like this, however, is that it motivates me to find new, more effective ways to get better. So, thanks to states like California, Maine (and a few others!), we're evolving a great set of tools and processes that I'm hoping will benefit everybody one of these days.

Have a great weekend!

Thursday, October 15, 2009

Californicopia

Unregistered Carriers on 10/13/2009 - 1964
Unregistered Carriers on 10/15/2009 - 1904

Sorry you didn't hear from me yesterday. I tried all day to write a UCR blog post, but the site was unavailable. We're here now, though, so let's get started.

On July 17, 2009, I wrote about my "My Secret Stretch Goal" - which was to register more Illinois carriers than California registered California carriers because they were - and still are - in first place.

Specifically, I wrote:

"California has registered 18,023 carriers as of this morning's Iteris report. We have registered 16,074 - so we're 1,949 registrations behind them. But they still have a pool of 10,165 unregistered carriers, while we only have 3,006. You can see the problem. Even I register all of my unregistered guys - my "getting to zero" goal - I'll only have a total of 19,000 UCR registrations. CA only has to register another 1,000 guys to beat me. As I said, it's just a fun goal anyway. The more carriers we all register, the better."

So, here we are three months later ... and the numbers are intriguing --- at least to me!

As of this morning, CA has registered 19,203 carriers - EXACTLY 1,000 more carriers than they had on July 17th - and IL has registered 18,799 carriers, so we're only 404registrations apart vs. 1,949 in July. That's cool all by itself. But ... the amazing thing is that we've still got 1,904 unregistered carriers left! And we've deactivated a lot of guys since July.

Let's summarize the intriguing part: we've registered 2700+ carriers since July 17th, but we've only reduced our Unregistered List by 1100 carriers. That's a differential of 1600 carriers in 90 days! And, if you have been following this blog, you know that there's no sign of a letup. We registered 80 carriers yesterday - and only reduced our U/L by 60. That's becoming a daily event!

What a country!!!!

Tuesday, October 13, 2009

The UCR Business is (Too) Good!

Unregistered Carriers on 10/08/2009 - 1881
Unregistered Carriers on 10/13/2009 - 1964

Do you remember late last week when I only had 1881 carriers on my Unregistered List? And then, do you remember in the last post when I told you we had already registered 393 carriers so far in October? Imagine my surprise, then, when I came in this morning and found that we now have 1964 unregistered carriers! Somehow, we added 83 more carriers to our Unregistered List over the long weekend! And most of those 83 carriers were new USDOT numbers! Go figure! We heard from a walk-in customer today that one of our IL state troopers went on local radio and announced that the state police were going to start sitting on grain elevators and writing tickets, so that may have caused another rush. At any rate, we're getting lots more new carriers in here - business is definitely good!

Meanwhile, as incredible as it sounds, we are now only 518 registrations behind California. Not very long ago (August or so?), it was 1500! We have now registered a whopping 18,646 Illinois carriers, with California sitting at 19,164. And I have a strange feeling that we are going to add a lot more new USDOT numbers and UCR registrations before the year is over. Look out, CA!