Permits Plus Inc.
Interstate Authority Overview
By Patrick R. Malloy, President, Permits Plus Inc.
Formerly known as ICC or FHWA authority, Interstate Authority is permission granted by the federal government to transport regulated freight across state lines. Interstate Authority is now granted by the Office of Motor Carrier Safety Administration. After authority is granted, all regulated motor carriers must register their authority with the states in which they will conduct operations. This is done through the Single State Registration System (38 states participate in this program) and is known as SSRS registration. If your base state is a non-participating state, then application is made through a neighboring state that belongs to the SSRS.
Any regulated freight that is transported wholly within state lines (pickup and deliver same load without crossing state lines) is considered intrastate carriage or point to point and is controlled on the state level. Permission to conduct this type of operation is known as Intrastate Authority. Most intrastate operations require registration with the state(s) where these operations take place.
Certain Freight is considered “exempt”(such as produce) and therefore bound by statutory regulations. Although exempt commodities do not require federal registration, 30 states do require the registration of your exempt interstate operations. This is commonly referred to as PUC or Exempt Authority. Once an application is filed with a state in which you will conduct exempt interstate operations, ID stamps (known as bingo stamps) will be issued and must be affixed on the back of a D-1 cab card.
If your operations require transporting separate loads of both regulated freight and exempt commodities, most states require both Interstate Authority and PUC registration.
Definitions
*Contract Carrier: A person or entity providing motor transportation for compensation under contract. Must maintain insurance as noted under Minimum Insurance Limits and must maintain process agents on file.
*Common Carrier: A person or entity providing motor transportation to the general public. Common carriers no longer have to file tariffs but must have cargo insurance on file in addition to liability insurance as noted under Minimum Insurance Limits and must maintain process agents on file.
* The ICC termination Act of 1995 defines contract carriage as truck transportation provided under a contract, but, effective January 1, 1996 it no longer distinguishes between common or contract carriers. However the act specifies that carriers still must register as either common or contract carriers. If you are unsure of which authority to secure, you may check with potential shippers to see if they have a preference.
Broker Authority: A person or entity that arranges for the truck transportation of cargo belonging to others, utilizing authorized for-hire carriers to provide the actual truck transportation. The broker does not assume responsibility for the cargo and usually does not take possession of the cargo. A broker must have process agents on file and a surety bond or trust fund in the amount of $10,000
Freight Forwarder: A person or entity that arranges for the truck transportation of cargo belonging to others, utilizing authorized for-hire carriers to provide the actual truck transportation. The forwarder does assume responsibility for the cargo from origin to destination and usually does take possession of the cargo at some point during transportation. Forwarders typically assemble and consolidate less than truckload (LTL) shipments into truckload shipments at origin and disassemble and deliver LTL shipments at destination. Process agents must be on file and Insurance requirements are the same as for common carrier unless forwarder seeks a waiver of liability insurance requirements.
Waiver of Liability Insurance Requirements: Where a Freight Forwarder certifies they
will not: A) Own or operate any motor vehicles upon the highways in the transportation of freight. B) Perform transfer, collection, or delivery services.
C) Have motor vehicles operated under its direction and/or control while performing transfer, collection or delivery services.
Insurance Requirements
Minimum Insurance Limits
Regulated Carriers with vehicles that have a Gross Vehicle Weight Rating (GVWR) of 10,000 pounds or more:
$750,000 (BI & PD) General Commodities (non hazardous)
$1 Million (BI & PD) Hazardous materials except class A & B explosives
$5 Million (BI & PD) Class A & B explosives, Hazardous materials transported in specific capacities in tanks or hoppers and/or any quantity of hazardous materials as specified in 49 CFR 173.403 of the Federal Motor Carrier Safety Regulations
Regulated Carriers using only vehicles with a Gross Vehicle Weight Rating of less than 10,000 pounds:
$300,000 (BI & PD) General Commodities except any materials listed below.
$5 Million (BI & PD) Any quantity of Class A or B explosives, for any quantity of Poison Gas (Poison A) or highway route controlled quantity of radioactive materials.
Common Carriers: Must carry minimum liability insurance as listed plus a minimum of $10,000 cargo insurance.
Broker Authority: Brokers must maintain a surety bond or trust fund in the amount of $10,000.
