Do Hardship Letters to Credit Card Companies Work

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					                     PRISM Implementation Committee Meeting
                               September 11, 2009
                              IRP Annual Meeting
                                Tucson, Arizona

The PRISM Implementation Committee met in Tucson, AZ in conjunction with the IRP, Inc
meeting. Vice-Chairman Jim Poe chaired the meeting. Jim introduced the committee
members. The committee members present were:

Voting members –
Jim Poe, Indiana
Sheila Rowen, Tennessee
Alana J. Gourneau, South Dakota
Cathy Beedle, Nebraska
Jay Starling, Alabama

Industry and association members –
Robert Pitcher, ATA
Tim Adams

PRISM team members –
Tom Lawler, FMCSA
Linley Oberman

Additional PRISM team members present were Chuck Kleber, Allen Day and Xiang Li.

Tom Lawler provided the group with a summary of the accomplishments for last fiscal year. These
included: conducting implementation development in five states, clerical training in two states,
implementation reviews in six states and an overview session in one state. PRISM also has split the
MCSIP step 63 into 63 and 64 (failure of new entrant audit and refusal of new entrant audit) PRISM
has also created guidelines for an expanded PRISM program for non IRP commercial vehicles and has
requested a MCSIP step for intrastate OOS. PRISM has also expanded funding for USDOT and
license plate readers. The technical team has developed web services for the target file (discussed later
in the meeting), and created a new report to identify chameleon carriers on the target file. PRISM
worked with CVIEW states to establish a special status code for vehicles suspended by the states as a
result of a Federal OOS. PRISM worked with the CVSA to add the Federal OOS to its criteria for
roadside stops. The PRISM team held a vendor meeting to review the problems discovered in the
implementation reviews. The target file for NLETS queries has been moved to the NLETS
headquarters for faster return time. Lastly, the IRP board approved the PRISM goal to eliminate the
registrant only number and the team has prepared a notice for the Federal register to announce the
decision to do this.

 Tom then presented the goals for next year. These are providing more implementation plan
development training, implementation reviews and adding to the list of states that enforce the MCS –
150 update, pass legislation for the chameleon carriers and implement an expanded PRISM program.
PRISM also hopes to have its own web site within the next few months and add a MCMIS query to the
NLETS responses. PRISM states need to be re-certified for the 3.4.1 version of the bar code
specifications. PRISM also will continue the project to eliminate the registrant only number and fund
roadside connectivity and License plate/USDOT readers.

Linley Oberman discussed the registrant only project. Changes need to be made to the IRP
systems and processes as well as researching safety events to place them on the correct
USDOT number. FMCSA division offices will take the lead on correcting those 35,000 safety
events that are currently on the registrant only numbers. States will need to determine time
frames and costs to create the new annotation for a registrant on the IRP system, modify the
validation check edits and safety check edits, renewal logic for printing MCS – 150
information, changes to the MCS 150 update logic when processing a renewal. State will need
to provide PRISM with this information and apply for supplemental grants. The PRISM team
is looking for most changes to be made by September 2010. Letters will be sent to the FMCSA
Division offices and the IRP offices as soon as the notice is published in the Federal register.

FMCSA is awaiting approval of the federal register notice from the attorney.

Tom then discussed the problem with charter motor buses and the concept of including these in
the definition of apportionable vehicle. The OOS motor coach companies are reinventing
themselves and then being involved in more crashes. The IRP does not catch them with the
PRISM safety checks since these vehicles are not currently required to register under the IRP.
FMCSA would like the IRP members to consider adding motor coaches to the IRP.

Jay Starling provided an update of the work he did to introduce the idea to the IRP community.
Jay indicated that after some discussion, it was decided to wait to see if the Reciprocity Plan is
accepted by IRP. This would then address the concern of charter busses not knowing where
they will be traveling at the time of renewal and then having to pay over 100% fees.

Xiang Li introduced the new web service for the Target File. She explained that this is
primarily for the law enforcement License Plate/USDOT readers, but can also be used by the
IRP office for the safety checks. The advantage over the target flat file is more timely data. A
start up package is available for states to implement the use of web services. Several states
indicated interest.

Due to a mix-up in the starting time of the PRISM Committee meeting, Tom and Linley
had to leave the meeting early. Jim asked that the issues be documented and responses
provided in the FAQ section of the IRP web-site.

The Motor Coach Representative commented on motor coach safety. He stated that the
fatality statistics for motor coaches are better than they are for the airlines and that motor
coaches recently involved in safety incidents would not have been caught by PRISM. He
supports safety initiatives for motor coaches, but felt that that part of the industry was
unfairly spoken of in the presentation.
Texas expressed a concern about MCMIS requiring a credit card to get a PIN for a carrier
so that they can update their MCS150 data. He wonders what they are validating with the
credit card when they can use an agent’s card number to complete the process. Industry
does not like having to use the credit card.
Update Note: MCMIS uses the credit card to identify the name of the person accessing
the account. It never charges any fee on the card.

New York said that the use of credit card numbers was causing them extra work because
of the security issues associated with having to protect credit card numbers, etc.
Update Note: The states should not be using the credit cards for access to MCMIS. This
is only when a carrier is accessing his own account online. The state should use the ID
number provided to the employee and then access MCMIS through either AAMVA or
the FMCSA COMPASS portal. The state access does not require a credit card since the
state personnel can access all records on MCMIS.

There was quite a bit of discussion on the PIN and password issue. Many carriers
received their PINs years ago and have no idea what they are and addresses have
changed, so if they were mailed, they would never receive them. They felt that there
needed to be a faster way for a carrier to get their PIN restored. The central issue here
was the MCS - 150 update requirement of PRISM. There were two sides to the
discussion: Those who felt that there was a problem and those who felt that things were
working fine. There is a lack of understanding of the processes available when a carrier
does not have their PIN. For example, having the Service Center make the updates or fax
in the changes.
Update Note: States can access through MCMIS the original letter that provided the PIN
to the carrier. The state employee can then give the PIN to the carrier. Caution should be
taken to be sure the carrier is who they say they are before providing the PIN.

One state expressed a concern about having to download the full MCS150 file each
month for their staggered registration process. They stated that this part of the process
was causing a hardship to them.
Update Note: The PRISM technical support unit will work with the state to resolve the
problems encountered.

There was a discussion on the Chameleon Carrier situation. Nebraska had some
situations where the carrier voluntarily returned their plates and went out of business.
They then went to a neighboring state and re-created themselves. They were aware of the
situation but were unable to do anything about it. FMCSA would have to take action
against the new carrier before the new jurisdiction could take any action. They said that
the FMCSA’s attorneys knew of the situation but would not take any action so there was
nothing that the state IRP could do.
Update note: There are three things that the government agencies can do. First, the states
need to have the chameleon legislation passed so that they can refuse the registration to
the carrier who has reinvented themselves. Secondly, the FMCSA division offices should
conduct a compliance review immediately for the reinvented carrier. This will take time,
but will lead in most cases to another OOSO being issued. Third, FMCSA is currently
working on a vetting process to catch the chameleon carrier before issuing operating
authority. This is only being piloted for buses and household goods carriers currently.
This process will be reviewed to determine if it should apply to all carries in the future.
Since the chameleon carrier issue has been given priority in FMCSA, it is also likely a
new policy will be issued so that all the attorneys are on the same page.

Jim Poe made a request for volunteers to serve on the PRISM committee.

Jim Poe was nominated and voted to be the new committee Chair. Sheila Rowan was
selected by Jim for the position of Vice Chairman and was approved by the committee

The meeting was adjourned at 11:30..

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