FAQ – Full Reciprocity Plan (FRP)

Note: The following FAQ was modified from International Registration Plan, Inc. at www.irponline.org/.

Implementation Dates & Timing

What is the effective date of the Full Reciprocity Plan (FRP)?

Jan. 1, 2015.

If an Indiana IRP Account holder’s renewal date is, for example, April 1, 2015, at what point will he or she be affected by full reciprocity?

Any registrant whose registration year begins on or after Jan. 1, 2015 would be subject to FRP provisions. Using the example of the April 1, 2015 renewal, the motor carrier would be registered under full reciprocity.

How are early renewals to be handled? For example, would a Jan. 1, 2015 renewal that is processed prior to Jan. 1 come under full reciprocity?

Yes. Any registrant whose registration begins on or after Jan. 1, 2015, would be subject to FRP provisions regardless of when the renewal application was processed. Registrants should be advised to carry their old IRP credentials until they expire as required in IRP Article VI Section 605.

How is a transaction such as an add vehicle or add jurisdiction transaction to be handled for a fleet that the renewal date is, for example, June 1, 2015 to be handled between Jan. 1, 2015 and its renewal date?

Any registrant whose registration year begins on or after Jan. 1, 2015 would be subject to FRP provisions, including any supplemental transactions. Registrants whose registration year begins prior to Jan. 1, 2015 would be subject to provisions of the current IRP until they renew.

What brought about the change to FRP?

The idea of full reciprocity has been studied and evaluated for more than thirty years. The process supports the fundamental principle of the IRP by promoting and encouraging interstate travel and more efficient and effective administration. The distance reporting practice and calculation of apportionable fees under FRP is deemed to be a fair and just approach based on the factual operation of apportionable vehicles.

Reporting of Distance

Are all existing IRP carriers going to be subject to the average per vehicle distance chart calculations for all members jurisdictions the first year under full reciprocity?

No. Existing carriers renewing their fleets for registrant year beginning on or after Jan. 1, 2015 will report actual distance accumulated during the distance reporting period.

When should fees be based on the jurisdictional average per vehicle distance chart?

When a registrant's fleet is considered new under Section 420 of the IRP, or the fleet did not accumulate any actual distance during the distance reporting period, fees will be calculated using the base jurisdiction's average per vehicle distance chart.

When is actual distance to be used?

Under FRP, actual distance must be used when the registrant's fleet accumulated any actual distance during the distance reporting period.

For a new fleet, can a combination of actual and average per vehicle distance be used?

No, a new fleet has no actual distance. Under FRP, the jurisdiction's average per vehicle distance chart must be used to determine fees for all IRP jurisdictions. A combination of actual distance and average per vehicle distance should never be used under FRP.

How is the average per vehicle distance chart established?

The average per vehicle distance chart is to be established in accordance with Section 320 (d) of the IRP.

When are jurisdictions required to update the average per vehicle distance chart?

In accordance with Section 320 (c) of the IRP, the average per vehicle distance chart is to be updated by March 31 of each year. Jurisdictions will be asked to provide proof of the updated chart each year.

Does the 90 days of actual distance operations in the distance reporting period apply under full reciprocity?

No. The 90-day rule was removed by the FRP ballot.

How are situations handled where a carrier has only actual operations during the distance reporting period in their base jurisdiction? Does it pay 100 percent base jurisdiction fees?

Yes. Under FRP, the registrant must report the actual distance accumulated during the distance reporting period and pay fee accordingly. The official commentary under the "apportionable vehicle" definition provides guidance regarding a registrant's eligibility for IRP registration (aka 18-month rule).

When using the jurisdiction’s average per vehicle distance chart, why is the distance amount not multiplied by the number of vehicles?

There is no need. The distance percentage would be the same whether you multiplied the amount by the number of vehicles or not, because there would only be SPVD distance indicated and no actual distance.

IRP Cab Card and Weights

Under full reciprocity, what weight should be displayed on the IRP cab card?

The gross vehicle weight should be displayed on the cab card for every IRP jurisdiction. The base declared gross weight plus the comparable weight for each member jurisdiction should be reflected.

What weight should be reflected for jurisdictions where there is no actual distance and no fee collected?

The gross vehicle weight should be displayed on the cab card for every IRP jurisdiction. The base declared gross weight plus the comparable weight for each member jurisdiction should be reflected.

How are weights more than 80,000 pounds to be handled?

The FRP doesn't affect how weights more than 80,000 pounds are handled. The registrant should continue to declare the gross vehicle weight.

How are mid year weight increases to be handled? Specifically for jurisdictions where there was no actual distance and no fee paid.

The FRP doesn't affect how weight increases are handled. If no actual distance is reported, then no fees are due until the fleet accumulates distance in the jurisdiction. NOTE: This does not affect administrative fees charged by the base jurisdiction for issuance of credentials, etc.

At renewal, are jurisdictions responsible for requiring vehicles be registered at the same weights from the prior year that would have been reflected on their registration cab cards? For example, if a vehicle was registered for a weight more than 80,000 pounds the prior year, at renewal is the base jurisdiction required to ensure the vehicle is registered at the higher weight at renewal.

The FRP, nor the current IRP addresses this issue. If jurisdictions are concerned about potential abuse, they may audit the registrant.

Will the IRP FRP Task Force be supplying information for reference on jurisdictional weights by category?

No. However, the IRP, Inc. website currently reflects the maximum gross weight and associated fees for each jurisdiction. Other weight information can be found in the jurisdictional fee charts provided on the website.

Can new fleet registrants indicate less weight in some jurisdictions?

There is a 10 percent variance of registered weights rule in the IRP. Refer to IRP Section 325 regarding this and related registration weight matters.

Reporting of Transactions (Clearinghouse)

Will there be changes to the reporting of recap and transmittal information?

No. "A" will continue to be reported for actual distance. Average per vehicle distance will be reported as "E". E2s will no longer be necessary.

How will transactions that have zero distance and therefore zero fees be handled in the Clearinghouse?

The same data that is currently required to be transmitted to the Clearinghouse will not change under FRP.

Will there be changes to the IRP Clearinghouse specifications as relating to full reciprocity?

At this time there are no anticipated changes to the IRP Clearinghouse specifications resulting from FRP. Clearinghouse specifications are continually monitored and updates made as needed.

Jurisdictional Compliance

If it is not possible for a jurisdiction to make changes and comply with the Jan. 1, 2015 effective date for full reciprocity, what will be the impact or consequences for the jurisdiction?

Any IRP provisions for which the jurisdiction is found to be out of compliance will be noted by the Peer Review Committee during scheduled jurisdiction peer reviews and referred to the Dispute Resolution Committee as provided under Article XIII Section 1355 of the IRP.

Audit

After Jan. 1, 2015, do we continue to calculate audits for non-FRP fleets the way we currently do?

Yes. If the registration year for the fleet begins on or after Jan. 1, 2015, the audit of the registration year will be conducted under FRP provisions.

When a carrier has used the “Average Per Vehicle Distance” (APVD) Chart in its original fee calculations, should it use the APVD Chart in the audit calculation?

No. A carrier should only use the APVD chart if it did not accumulate actual distance during the reporting period. If the carrier was audited and actual distance was discovered, the actual distance should be used, rather than the chart.

Does the FRP impact “Insufficient Record” audits?

No.

What is the process for incorrect reporting? Example: A client provides the wrong actual kms or wrongly uses the chart but reports it as actual.

If the registration was issued under FRP, the auditor should correct either the actual distance omitted or the incorrect actual distance. The average per vehicle distance chart should only be used if the carrier did not accumulate actual distance and cannot be used in combination with actual distance.

Additional Operating Requirements

For fleets that operate only in Canada, will it be necessary for them to get a DOT number if all jurisdictions will be on the cab card?

No. Just because the US Jurisdictions are listed on the cab card doesn’t mean they will operate in the US. If they do not operate in the US, they are not subject to HVUT or DOT.