Household Goods Carriers “Household Goods Carrier” means a carrier handling: (a)personal effects and property used or to be used in a dwelling; (b)furniture, fixtures, equipment, and the property of stores offices, museums, institutions, hospitals or other establishments, when a part of the stock, equipment, or supply of such stores, offices, museums, institutions, including objects of art, displays and exhibits, which, because of their unusual nature or value, require the specialized handling and equipment usually employed in moving household goods.

OPERATING AUTHORITY OPTIONS HHG carrier leases vehicles from agent to operate either:  Committed lease - solely under carrier’s operating authority or  Uncommitted lease - intermittently under both carrier’s and agent’s authorities Agent has own trucking operation that is separate from the carrier’s business and held confidential – carrier does not have access to agent’s records

 Carrier’s Bill of Lading btw carrier & shipper  Equipment lease agreement btw carrier & agent  Operating lease agreement btw carrier & agent  Van Operator agreement with agent Carrier Equipment Agent Agent owned w/ carrier logo

May represent a single day or several days of travel Agent may use carrier’s trip form for their own authority business V/O remits trip form to either carrier or agent depending on authority Carrier trip reports + agent trip reports = total vehicle mileage

Who Reports the IFTA? IFTA ARTICLES OF AGREEMENT – ARTICLE V *R520 HOUSEHOLD GOODS CARRIERS In case of a household goods carrier using independent contractors, agents, or service representatives, under intermittent leases, the party liable for motor fuel tax shall be: a.The lessee (carrier) when the qualified motor vehicle is being operated under the lessee’s jurisdictional operating authority..... b.The lessor (independent contractor, agent or service representative) when the qualified motor vehicle is being operated under the lessor’s jurisdictional operating authority. The base jurisdiction … shall be the base jurisdiction of the lessor, regardless of the jurisdiction in which the qualified motor vehicle is registered for vehicle registration purposes.

HHG Carrier Switch operating authority HHG Agent Agent must return to their operational location before switching from carrier’s to their own authority

Which IFTA Decal Do I Wear? IFTA ARTICLES OF AGREEMENT ARTICLE VI. MOTOR VEHICLE IDENTIFICATION G. Qualified motor vehicles that are to be operated by more than one IFTA licensee during the calendar year may display IFTA decals for each active licensee concurrently. HHG CARRIER’S DECAL HHG AGENT’S DECAL

Types of Record Keeping Systems for HHG Carriers and their Agents Driver submits paper/electronic trip record to either HHG carrier or agent HHG Agent’s computer system- electronically or manually HHG Carrier’s computer system- electronically or manually HHG Carrier’s reports HHG Agent’s reports

CHARACTERISTICS OF MILEAGE TRACKING SYSTEMS  Manually or electronically inputted  Data verifications include visual and system checks  Odometer readings may not be available to due intermittent mileage reporting  Interruptions in driving time for packing & warehouse duties

Types of Fuel Purchasing Practices for HHG Carriers and their Agents  OVER THE ROAD PURCHASES – carrier or agent’s name on invoice  BULK FUELING AT AGENT’S LOCATION – fueling weekly/ monthly statement forward to HHG carrier  CARD LOCK FUELING AT AGENT’S LOCATION

CHARACTERISTICS OF FUEL REPORTING  Mpg must be within in acceptable range of vehicle type operation  Imputed mpg  Unused fuel report  Maximum gallon threshold

IRP Registration Options for HHG Carriers and Agents HHG Carrier Obtains IRP….. HHG Agent (Service Representative) Obtains IRP….. State IRP Apportioned Cab Card USDOT # - HHG CARRIER Registrant – HHG Carrier Lessee/Lessor – HHG Agent (Service Representative) State IRP Apportioned Cab Card USDOT # - HHG CARRIER Registrant – HHG Carrier Lessee/Lessor – HHG Agent (Service Representative) OR

IRP ( effective 7/1/08 ) – Article VII Household Goods Carriers 700 EQUIPMENT LEASE FROM SERVICE REPRESENTATIVES A Household Goods Carrier using an Apportionable Vehicle Leased from a Service Representative may elect that the Base Jurisdiction for such Vehicle be either that of the Service Representative or that of the Household Goods Carrier. 705 REGISTRATION IN BASE OF SERVICE REPRESENTATIVE When a Household Goods Carrier elects under Section 700 to base an Apportionable Vehicle in the Base Jurisdiction of a Service Representative, the Vehicle shall be Registered in the name of the Service Representative, with the name of the Household Goods Carrier shown as the Lessee, and the fees for the Vehicle shall be apportioned According to the combined records of the Service Representative and the Household Goods Carrier..... A Vehicle registered under this Section shall be deemed fully registered for operations under the authority of the Service Representative as well as that of the Household Goods Carrier.

IRP ( effective 7/1/08 ) – Article VII Household Goods Carriers (cont.) 710 REGISTRATION IN BASE OF CARRIER If a Household Goods Carrier elects under Section 700 to base an Apportionable Vehicle in the Base Jurisdiction of the Household Goods Carrier. The Vehicle shall be registered in the name of the Household Goods Carrier as well as the name of the Service Representative, as Lessor, and the fees for the Vehicle shall be apportioned according to the combined records of the Household Goods Carrier and the Service Representative..... A Vehicle registered under this Section shall be deemed fully registered for operations under the authority of the Service Representative as well as that of the Household Goods Carrier.

HOUSEHOLD GOODS CARRIERS AUDITING ISSUES

AUDIT ISSUE #1 Determining types of leases among agent fleet How many units in the fleet are on intermittent leases? How many on permanent lease?

AUDIT ISSUE #1 Solution: Stratify the sample Represent both intermittent and permanent lease agents, if significant portions of the fleet operate under one or the other.

AUDIT ISSUE #2 What to do with date gaps between trip reports Is the gap in days because the agent was running on his own authority? Or Are we missing a trip report?

AUDIT ISSUE #2 If the agent is being audited, Does he have access to trip information reported by the carrier?

AUDIT ISSUE #2 Solution –Request carrier provide trip detail for trips reported under agent’s authority. –If auditing the agent, he should already have all trip reports for IRP purposes.

AUDIT ISSUE #3 If a gap is discovered, Which party is liable?

AUDIT ISSUE #3 Solution: Lease agreement might provide answer. In case of intermittent lease, it may be the owner/agent who is responsible

AUDIT ISSUE #4 How to deal with unusual MPGs What could artificially raise the MPG for the trip run for the carrier.

AUDIT ISSUE #4 An agent fuels his truck at the end of a trip run on his own authority Then runs a trip for the carrier. How does the auditor know the agent filled at the end of its own trip?

AUDIT ISSUE #4 Solution: Attempt to obtain all fuel and miles for the truck Then analyze the MPG

AUDIT ISSUE #5 What about an agent who has bulk fuel? Did agent supply carrier with withdrawal information?

AUDIT ISSUE #5 Solution: If data is NOT provided: No credit gallons allowed MPG must be recalculated, if bulk gallons are not included in total.