ATA Files Comments with FMCSA on Unified Registrations System
ATA filed comments today with the Federal Motor Carrier Safety Administration, on the agency’s proposed Unified Registration System, or URS. URS (which is unrelated to the Unified Carrier Registration Agreement, or UCRA) involves the integration of several internal FMCSA programs, including the registration system under which motor carriers and other entities are issued authority and DOT numbers; the financial responsibility system, under which proof of carrier insurance is filed; and the system through which carriers file the names of their agents for service of process. The URS has been in the works for a long time – the docket was opened in 1997, and ATA last filed comments on the proposal in 2005.
The current long and detailed Supplemental Notice of Proposed Rulemaking is in essentially two parts. The first sets out the concept of the changes involved in the URS, with most of which ATA agrees. The changes, provided they are well implemented, should render FMCSA more efficient, and provide better data from carriers to the federal government. We laid out some remaining concerns with the program, however, in particular the idea that carriers could in the future file updates on their data with their PRISM base states. This notion seems insufficiently developed. The other part of the rulemaking, however, is the appendix that presents the form that FMCSA proposes to take the place of the current Form MCS-150 and various other forms through which industry information and applications are funneled to the government. ATA told FMCSA that the form, in its current draft, is wholly inadequate to do the job. It is far too lengthy (at 30 pages, with 20 more of instructions), the instructions are often ambiguous or confusing, and there appear to be several errors.