- Option A calculates UCR fleet size using the commercial motor vehicle count reported on the carrier’s most recent MCS-150 or MCSA-1.
- Option B uses qualifying commercial motor vehicles owned or operated under long-term leases during the applicable 12-month period and may require supporting vehicle records.
- Long-term leases, qualifying intrastate exclusions, and IRP-plated vehicles can change the calculation, so carriers should document how each vehicle was classified before selecting a UCR fee bracket.
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Your UCR fleet size is not automatically the number of trucks parked in your yard on filing day. Motor carriers and motor private carriers generally choose between Option A, which uses the commercial motor vehicles reported on the most recent MCS-150, and Option B, which uses qualifying vehicles owned or operated during the prescribed 12-month period. The choice can change the fee bracket and the records you must retain.
Why UCR Fleet Size Is Easy to Miscalculate
UCR fees for carriers and freight forwarders are divided into brackets based on commercial motor vehicles owned or operated. A current snapshot of the fleet may differ from the MCS-150 count or from the number operated during the UCR measurement period. That is why the filing method matters.
Trailers are not counted as self-propelled commercial motor vehicles for the bracket. Passenger vehicles and property-carrying vehicles may qualify when they meet the UCR definition, including relevant weight, passenger-capacity, or hazardous-material criteria.
Option A: Use the Most Recent MCS-150
Option A starts with the commercial motor vehicle information on the carrier’s most recently filed MCS-150 or MCSA-1. It is usually the simplest approach when the FMCSA record accurately reflects the operation.
Option A may fit when
- The fleet has remained stable since the latest MCS-150 update.
- Owned and term-leased power units are correctly reported.
- The reported count places the business in the correct UCR bracket.
- There are no known discrepancies between the federal record and current operations.
Updating the MCS-150 solely to force a preferred UCR bracket is not an appropriate shortcut. The federal record should accurately describe the business’s operations.
Option B: Use the Alternative 12-Month Count
Option B generally uses the total qualifying commercial motor vehicles owned or operated under a long-term lease during the 12-month period ending on June 30 before the registration year. It can be useful when the most recent MCS-150 does not represent the measured period.
When Option B produces a lower bracket than Option A, the registrant may need to retain a vehicle list supporting the calculation and make it available for audit. The exact documentation requirement should be checked against the UCR Agreement, handbook and base-state instructions.
How Leased Vehicles Affect the Count
The UCR Agreement generally includes vehicles controlled under a long-term lease lasting more than 30 days. Equipment operated under a lease of 30 days or less is generally excluded from that long-term lease count. Contract wording and actual control should be reviewed instead of relying only on how a unit is described internally.
Can Intrastate Vehicles Be Excluded?
A carrier may be able to exclude owned or leased commercial motor vehicles operated exclusively in intrastate transportation of property, waste or recyclable materials. The exclusion is conditional. A unit used in interstate commerce, or a vehicle that does not fit the permitted category, should not be removed simply because most of its mileage is local.
Commercial motor vehicles registered with apportioned IRP plates cannot be excluded under the relevant UCR counting rule. Maintain documentation showing how each disputed vehicle was classified.
A Repeatable Fleet-Count Process
- Export the most recent MCS-150 vehicle data.
- Build a list of qualifying self-propelled commercial motor vehicles used during the Option B period.
- Label each unit as owned, long-term leased or short-term leased.
- Identify exclusively intrastate property vehicles and IRP-plated units.
- Calculate both permitted options and record why the selected method applies.
- Retain the vehicle list, lease evidence, and filing confirmation with the UCR receipt.
When to Ask for Help
Get assistance with the Simplex Group team when the fleet crossed a bracket, the MCS-150 is stale, leases changed during the year, passenger operations are involved, or intrastate exclusions materially reduce the count. A documented calculation is more defensible than a number reconstructed after an audit.
FAQs
Do trailers count toward UCR fleet size?
Generally, UCR brackets are based on self-propelled commercial motor vehicles, so trailers are not counted as power units. Review the official definition and the filing method for the specific operation.
Does every leased truck count?
No. Long-term leases and short-term leases are treated differently under the UCR Agreement. Duration, control, and the selected calculation option matter.
Can Option B reduce the UCR fee?
It can produce a different bracket when the permitted 12-month count differs from the latest MCS-150. A lower bracket may create additional record-retention obligations, so the calculation should be documented.