Chase tour companies and Federal transportation regulations

[Dan Robinson]

From

http://www.fmcsa.dot.gov

How do I determine whether I am subject to FMCSA's safety regulations?

If you operate any of the following types of commercial motor vehicles in interstate commerce you must comply with the applicable U.S. Department of Transportation (DOT) safety regulations concerning: CDL: controlled substances and alcohol testing for all persons required to possess a CDL: driver qualifications (including medical exams); driving of commercial motor vehicles; parts and accessories necessary for safe operations; hours of service; and inspection, repair and maintenance.

(1) A vehicle with a gross vehicle weight rating or gross combination weight rating (whichever is greater) of 4,537 kg (10,001 lb) or more;

(2) A vehicle designed or used to transport between 9 and 15 passengers (including the driver) for compensation;

(3) A vehicle designed or used to transport 16 or more passengers; or

(4) Any size vehicle used in the transportation of materials found to be hazardous for the purposes of the Hazardous Materials Transportation Act (49 U.S.C. 5101 et seq.) and which require the motor vehicle to be placarded under the Hazardous Materials Regulations (49 CFR chapter I, subchapter C).

If I'm reading that correctly, a passenger car or an SUV does not meet the criteria to fall under Federal regulations. However, a 15-passenger van does (article #2 above). I will call the FMCSA tomorrow to hear an answer from the source.

 

[Robert Edmonds]

I'd be interested in what you hear. Since, that was what I too gathered from the regulations.

 

[Dan Robinson]

Here is some more info I found. Looks like all vehicles operating for-hire passenger service must have an MC number and carry $1.5 million in liability insurance. This includes passenger cars, limos and SUVs. Still no CDL, tests and inspections for passenger cars and SUVs.

USDOT and FMCSA Requirements for Interstate Travel

A USDOT Number is required of ALL vehicles involved in interstate commerce, whether they are private carriers or for hire carriers. Limousine services and bus companies fall into the for hire category. The primary purpose of the USDOT Number is to assist enforcement personnel in identifying motor carriers... A USDOT Number can be obtained by filling out forms MCS - 150 and MCS - 150A at WWW.FMCSA.DOT.GOV ..There is no charge for this number, although you will need a valid credit card in your name to serve as an electronic "signature" on the application.An ICC Number or "MC Number" is required for all "FOR HIRE" companies that transport passengers for a fare or charter fee in interstate travel... This registration is required to demonstrate to the Federal Motor Carrier Safety Administration that a carrier is aware of the safety regulations that are in effect, as well as to prove that an interstate carrier is in possession of Liability Insurance that meets FMCSA minimum requirements, which are:

• Any vehicle with a seating capacity of 15 or less (including the driver) $1,500,000.00

• Any vehicle with a seating capacity of 16 or more $5,000,000.00

A MC Number can also be obtained from WWW.FMCSA.DOT.GOV by filling out form OP - 1 and paying a $300.00 fee by credit card. In addition, after the FMCSA informs a limousine service that a "Docket File" has been opened for them, their insurance company must submit a form MCS 90B as proof of insurance coverage. The limousine service will also need to identify "Process Agents" who will accept warrants, subpoenas and other official communications in each state they plan to do business. Please note that the Federal fine for transporting passengers in interstate travel without a valid MC Number is $10,000.00

 

[Dan Robinson]

I just got off the phone with the FMCSA and here's the scoop. Any vehicle that is designed to seat 8 people or less (including the driver) does NOT fall under Federal interstate motor carrier regulations and does not need to file for a DOT number.

However, any interstate transport of passengers for hire IS subject to state transportation regulations in EACH state that the vehicle will be operating in. This means that a chase tour vehicle must have permits to operate in each and every state chased in, if that particular state requires it. So, operating a chase tour would require checking with all Plains and midwestern states to see if permits are required, and if they are, register for a permit with those states. This is just like cabs and limos, who don't need to file under USDOT but are subject to state and local regulations.

Regarding 12 or 15-passenger vans - this type of vehicle IS subject to the full regulations of the USDOT as it is designed to carry more than 9 people. I asked if a van were to have seats removed so that it could only carry 6 people and luggage/gear, if that would exempt it from the regulations. They said no - because the van was originally designed to carry 15 people, it must fall under USDOT regulations regardless of any modifications made to it.

So there you have it.