Midwest Specialized Transportation, Inc. - Comments

Midwest Specialized Transportation, Inc would ask that the FMCSA reconsider the proposed increase to the Unified Carrier Registration Agreement (UCRA) fee for 2010 all together, or at a minimum we would ask that the FMCSA consider “gradually” increasing the fees as the economy begins to show signs of recovery. We are simply asking that FMCSA follow the language provided in the justification for the increase. In this rulemaking, FMCSA provides justification for the increase in fees based on language that says…. “Fees may be adjusted within a reasonable range on an annual basis”. We would argue that an increase of 122% in a single year is not in a “reasonable range” in any year. But given this is the worst economic climate for the trucking industry in 30 years, it would seem obvious that at this time a fee increase of 122% would be considered extremely “unreasonable”. If the present UCRA fees need to be adjusted to increase revenue, they should be adjusted in an incremental fashion that will allow the Motor Carrier industry time to adjust to the new fees.