Please note the following summation regarding URS published by the Scopelitis law firm.
The original final rule implementing URS was published in August of 2013 and gave the FMCSA 26 months to implement the new system, with an effective date of October 23, 2015. Under the new timeline, most of URS will not take effect until September 30, 2016, except that on December 12, 2015, “new applicants” seeking authority will be required to use the new system. According to the rule, a “new applicant” is anyone that does not have, and has never been assigned, a US DOT number, an MC number, an MX number or an FF number. These new applicants will be required to use the new online application (Form MCSA-1) when requesting registration and a US DOT number. All other filings will continue to be made under existing systems using existing forms until September 30, 2016. The agency is adopting temporary regulations, set to expire on September 29, 2016, to effectuate this dual process. It would appear that new applicants applying under the new system between December 12, 2015 and September 29, 2016 will be issued docket numbers, but that those numbers will be discontinued on September 30, 2016.
In addition, private carriers of hazardous materials and exempt for-hire carriers registered with the agency as of September 30, 2016 will be given three additional months to file proof of financial responsibility with FMCSA. All entities registered with the FMCSA as of September 30, 2016 will be given three additional months to file their designation of process service agent (form BOC-3) via the new URS online application.
Perhaps the most important aspect of the FMCSA’s delay in the short term is that Transportation Management System (“TMS”) data feeds that rely on existing FMCSA systems should remain viable until September 30, 2016. Thus, the imminent threat of the loss of the ability to track, for instance, motor carrier authorities and liability insurance is delayed. It is to be hoped that the agency allows TMS-providers that rely on its systems to push licensing and registration data to end users such as brokers, carriers, and shippers an opportunity to build and test applications for compatibility with the FMCSA’s new systems under URS so as to ensure an orderly roll out in 2016.
