Staff from the PRISM Team who participated in the call are listed in the following table: PRISM Technical Support at Volpe Technical Team Lead

Transcription

1 Federal Motor Carrier Safety Administration Performance and Registration Information Systems Management (PRISM) National PRISM Conference Call - Minutes June 12, :00 PM Eastern Time Staff from the PRISM Team who participated in the call are listed in the following table: PRISM Team Bill Mahorney Steve Parker Julie Otto Dennis Piccolo Ed Roman Chuck Kleber Tim Hayes Allen Day Harry He Xiang Li Title FMCSA Enforcement Division Chief FMCSA PRISM Technical Manager FMCSA PRISM Grant Program Manager PRISM Technical Support at Volpe Project Manager PRISM Technical Support at Volpe Technical Team Lead PRISM Consultant Law Enforcement Liaison PRISM Technical Support at Volpe Systems Analyst PRISM Consultant Systems Development/Operation PRISM Technical Support at Volpe Senior Programmer PRISM Technical Support at Volpe Systems Analyst Introduction Dennis Piccolo started the call by extending thanks to all the participants for attending. There were approximately 131 participants registered; 200 call-in ports were available. Dennis indicated this call was a follow-up to the February PRISM national conference call that discussed the Registrant only elimination to be rolled out in September Since the previous call, the PRISM team has updated the guidance memorandum, updated the Frequently Asked Questions, and drafted a letter to be sent to the Registrants informing them of the Procedural Change. The primary intent of this call is to solicit feedback from the States to help the PRISM Team in finalizing the letter. Dennis introduced the agenda that basically covered three topics, with each followed by a Q&A section. 1. Discussion on the draft letter that will be sent to the registrants for state s comment 2. Review of the updated PRISM documents and when they will be available 3. Review of the updated guidance and FAQ and provide guidance on leasing companies registration. Draft of the letter to be sent to the Registrants (Dennis Piccolo) In the last call, updates that needed to be in place on the Federal side were reviewed. These were the updated MCS-150 form to eliminate the Vehicle Registrant Only option under the Company Minutes: PRISM National Conference Call, June 2012 Page 1 of 7

2 Operation, the elimination of the Vehicle Registrant Only option from the public-facing online registration system, and elimination of the Vehicle Registrant Only option from the internal system. Dennis announced the release date for these changes is scheduled for September 15 th. The FMCSA plans to send out letters to about 250,000 registrants informing them of the changes. Current plans are to send the letters out in batches, which is expected to start in July and continue through September or October. Dennis discussed the contents in the draft letter. At the beginning of the letter, it informs that the Vehicle Registrant Only operation type will be eliminated. Then it provides instructions on how to update the company operation type through the website or by paper form. One item that didn t get into the letter but will be added is a specific instruction for leasing companies when completing the MCS150, the leasing companies will be asked to identify their status in the: Subsections 23: Operation Classification, under Other to fill in Rental and Leasing Company Subsection 24: Cargo Classification, under Other option to put in Vehicle Rental and Leasing. This will only apply for the leasing companies that operate interstate business and move vehicles across state lines. Leasing companies that are truly leasing only should inactivate their USDOT number. Another section of the letter addresses the New Entrant program. Considering the selection of Interstate Carrier, the registrants need to be aware of the federal requirements that Interstate carriers are subject to, such as the New Entrant Safety Audit. Once PRISM collects the inputs from this meeting, the letter will be updated based on the feedback and sent back to the states. States can use the letter as a part of the IRP renewal package, or handouts at the registration. Like any other MCS-150 updates, all inquiries will be handled through the FMCSA customer service hotline. The telephone number will not be on the letter, but will be available on the FMCSA website. Question and Answer: Mark Gilmore (SD FMCSA) Q: Can the PIN number be included in the letter along with the USDOT number? A: Unfortunately we cannot go against the federal security policies by displaying the USDOT number and the PIN in the same letter. What can be considered is a reminder with the PIN in a separate mailing, but there will be some cost issue. Dan Myers (MO FMCSA) Q: A mass-mailing with the PIN won t work well due to the fact that many registrants may have moved. How about adding a reference for the website in the letter for companies that are having problems obtaining a PIN number? A: Additional cost for the customer service line for PIN is the primary concern. Rena (VA) Minutes: PRISM National Conference Call, June 2012 Page 2 of 7

3 Q: Are you intending to add the FMCSA support phone number on the letter and reference the FMCSA website along with the instructions? A: There will be no phone number in the letter intentionally; we would like the registrants to go to the FMCSA website. They can find the customer service number on the website. The concern with displaying the phone number is several. The draft letter can be used as a template with the state contacts on it. A copy of MCS-150 will be attached to the letter. In case the registrants don t have their PIN, or cannot find the hotline number, they can just check a few checkboxes on the MCS-150 form, mail it back with the prepaid envelop to have their status updated. Scott Greenawalt (OK) Q: What will be the advantage of the registrants responding to this letter? A: In the 3 rd paragraph, we mentioned the consequence of delay when they go to register their vehicles. That is the advantage of having them take actions on their own. What we want to do is to trim away as much of workload as we can. When the registrants walk into the IRP office, they won t be able to get their plates until their MCS-150 is updated changing their company operation type or their registrant-only number is inactivated. Q: Can states just mark the Registrant Only USDOT numbers with Reg-Only in the IRP system? A: The intent is to involve the registrants in the process. Under the Reason For Filing section at the top of the updated MCS-150 form, registrants should choose Make My USDOT Number Inactive when they are truly registrant-only entities. Upon registration these registrants will then be marked as registrant-only in the IRP system. Barbara Hague (MO) Q: What is the main reason for requiring the MCS-150 update as it relates to eliminating the Registrant-only? Is it an internal policy? It seems to be sufficient just to have FMCSA inactivate their numbers. A: Alternatives come down to either the registrants or the FMCSA will have to take action and inactivate the numbers. The key thing is that the FMCSA would like to have the registrants involved in the correction process, and the simple way is to have them update the MCS-150. Jeff (SD) Q: A registrant-only USDOT number doesn t have authority or responsibility when it comes to PRISM. What will be the consequence of simply inactivating their USDOT number? A: There are 250,000 registrant-only USDOT numbers, and many of them are registered incorrectly with truly Interstate or Intrastate carriers registered with wrong entity type Q: So those incorrectly assigned registrant-only are illegally running in a USDOT carrier number? A: Yes, in cases. Scott Greenawalt (OK) Minutes: PRISM National Conference Call, June 2012 Page 3 of 7

4 Q: After September 2012, if registrant-only come to register at the account level, since they are no longer required to present a USDOT number to the IRP office, how is the state supposed to know that they are tied to a registrant-only USDOT number? A: In the February 14 conference call the procedure for handling this situation was discussed. Essentially it requires the states to create a file with the IRP Account Number and the associated Registrant-Only USDOT Number for each account where the registrant was automatically changed to registrant-only prior to the states going live with their updated system. Full details on the procedure are in the February 14 Conference Call Minutes. Kathy Beetle (NE): Q: NE implemented this change in September 2011, and already removed their USDOT numbers from the system. We don t know their registrant-only USDOT numbers any more. A: In the Feb conference call, we discussed with the state, prior to the switch-over, to contain all the Reg-only USDOT numbers along with the IRP account numbers in a reference table. Once a state has switched over, if needed, PRISM can help create the table. The IRP clerk verifies the USDOT number against MCMIS to ensure that the registrant has inactivated their USDOT number. If they haven t inactivated their DOT#, IRP clerk will help them to inactivate. States can contact PRISM Technical Support with a request for creating the table. Q: There are two populations in the Registrant-Only categories: One is the carriers incorrectly operating with the Registrant-only number, and the other is the registrants properly operating with the Registrant-only number. If the FMCSA inactivates all the Registrant-only numbers, the states will only have to deal with the few that should be the real carriers. When a registrant walks into the IRP office, they are the ones that need help to be changed into MCRS. The rest are the ones correctly using the Registrant-only numbers as PRISM told them to. A: The main problem with inactivating all the Registrant-only numbers is the safety issue, because those numbers that are motor carriers are not getting into New Entrant safety audit, and not measured by SMS system. Marge Noll (MN) Q: The letter is difficult for the registrants to understand, and I suggest using the same language from the guidance document, which is short and to-the-point. The states also recommend the way to address this issue is just to inactivate the numbers in the federal database. A: Other than the administrative burden, we also have to consider the safety activities on the road-side before or after a Registrant-only account are inactivated. Note: other PRISM states also agreed with the suggested approach to have FMCSA make one pass and inactivate all the Registrant Only USDOT numbers. Renee (SC) We build our system based on the PRISM requirement that, at the vehicle level, a legitimate USDOT number is required. The registrant-only USDOT numbers should be automatically inactivated without the states being involved because they are not being used in the IRP system. Minutes: PRISM National Conference Call, June 2012 Page 4 of 7

5 Jerri (ID) IRP makes sure no carrier is operating with a Registrant-only USDOT number as the MCRS, so there is no problem to inactivate those numbers because they are not supposed to operate right now. Cheryl Quirion (ME FMCSA) Whether a motor carrier gets stopped on the roadside because of inactive status versus a registrantonly, they will be treated in the same way as invalid USDOT number. The state regularly runs a report showing carriers with inappropriate activities or inactive accounts, so it s ok to have FMCSA inactivate them at once. Debby (CA): Include in the letter a time period like 90 to 120 days for registrants to make the change in MCMIS before inactivating their accounts. Cheryl Quirion (ME FMCSA) Q: How to work with the Canadian registrants? A: If a Canadian registrant number is in the state IRP system, they will receive the letter. The information will be updated in the appropriate IRP state that covers those Canadian registrants. Donna (NM) Q: The vendor is rebuilding the IRP system, and the state needs some clarification on if a USDOT number should still be built on their account level? A: Yes. Since both the USDOT number and IRP account number are included on the account level, when the Registrant-only USDOT is removed, the IRP account will still attach to the registrant. Steve closed the discussion and stated that the option to inactivate the registrant-only USDOT numbers by the federal side will be considered based on the states inputs. FMCSA will make a prompt decision on the letter, and also issue the finalized guidance to all on the call list. Updated PRISM Documents (Tim Hayes) Tim briefly covered the updates on PRISM documents for the registrant-only changes. The PRISM team is working on finalizing the PRISM Procedural Manual and the System Specifications. A whole new section (Chapter 7) has been added into the Procedural Manual that collaborate all the updates sent out previously through s and conference calls, which includes: the changes on the FMCSA side and the state IRP side; CVIEW changes; screenshots from some state systems that have completed the changes, and FAQ section. Tim mentioned that there is no new information that is different from the changes and concepts that we have discussed before, and the new section will help to put them all in one place for a good reference. Updated documents will be sent out late June or early July, and they will also be posted on the PRISM Minutes: PRISM National Conference Call, June 2012 Page 5 of 7

6 website. Dennis added that in the meantime, the states can also contact the PRISM Technical Support group if there is any particular document as needed. Guidance and FAQ to address the leasing company in particular (Ed Roman) Ed addressed a key change with leasing companies in terms of specifying the Motor Carrier Responsible for Safety (MCRS) at the time of registration. Currently if the IRP registrant rents or leases vehicles to other interstate motor carriers who will be responsible for their safe operation, the following instructions should be followed when providing the USDOT number of the MCRS of the individual rented or leased vehicles: Long Term Lease if the vehicle will be leased for 30 days or more to an interstate motor carrier, enter the lessee s USDOT number. Short Term Lease if the vehicle will be rented or leased for less than 30 days, or is unknown at the time of registration, enter the IRP registrant s USDOT number as the default MCRS provided the registrant is valid interstate motor carrier. If the registrant is a registrant-only company registration for the vehicle should be denied. Ed explained the change that PRISM is going to implement is slightly different from the current requirement. PRISM will eliminate the requirement that the lease has to be 30 days or more for registrant-only companies in order to specify the MCRS. At the time of registration, leasing-only companies should provide the USDOT number of the renter or lessee as the MCRS, even if the lease is less than 30 days. If they don t know who they will lease to, the registration should be denied. (In most cases, these companies probably will get a USDOT number). Ed mentioned this change on specifying the MCRS is only slightly different from what we ve done before and still follows the rule of using the best information available at the time of registration. More details will be included on the PRISM Procedural Manual. Question and Answer:? (SD) Q: If a leasing company never does any transportation, and currently has his own USDOT number issued. When the company moves their vehicles from one location to another, or to another individual company that they lease to, will that make it a motor carrier? What if it never transports vehicles outside of the state of South Dakota? A: Yes, we are considering that as a valid motor carrier when they deliver the vehicles to whoever they are leasing to; or pick up the vehicles across the state line, which makes them a legitimate Interstate motor carrier. The leasing company, if they never intend to cross the state line, can get an Intrastate USDOT number, but it cannot be used as the MCRS because the safety carrier has to be a valid Interstate USDOT number. Trish Smith (IN) Minutes: PRISM National Conference Call, June 2012 Page 6 of 7

7 Q: We have leasing companies that are truly leasing-only and registrant only, and they want to register and plate their vehicles but don t know the MCRS. Will it be an issue to put them as Intrastate Carrier even though they do not move their vehicles? A: Yes, they can get an Intrastate USDOT number. To get IRP plates though, they need to get an Interstate USDOT number. Q: When will FMCSA send out the 1 st wave of the letters? Will some letters get sent out after September? A: The current plan is to send out the letters from July, and the last batch probably won t be sent out until the end of September or even later. Q: Is this the last conference call before the letter being sent out? A: Yes, it is. Steve Parker reiterated the purpose of the call was to get feedback on the letter and ask for help from the states to make it go as smoothly as possible. There will be ramifications based on the feedback from today s call and the safety consideration. FMCSA will look at the other option to inactivate the registrant-only numbers and make the decision on how to proceed with the letter as soon as possible. The guidance document will be distributed in official format through the FMCSA Division office. Should there be any further comments on the letter the PRISM Technical Manager Steve Parker is the main contact with the state Division office copied. Dennis Piccolo closed out the call and provided the PRISM Technical Support as the contact for any future request for documents, or to be added into the PRISM distribution list. Minutes: PRISM National Conference Call, June 2012 Page 7 of 7