– In comments filed on May 25 with the International Registration Plan (IRP), the Truck Renting and Leasing Association (TRALA) requested that:
All commercial truck registrants, regardless of the industry sector, be treated equitably.
The term “apportionable vehicle” be referenced consistently.
No timetable be established to determine whether a vehicle is apportionable. The IRP is undergoing a major rewrite and is currently in the second draft.
As part of the rewrite, TRALA is seeking the authority for truck lessors to consolidate their fleet registrations through a single base jurisdiction. This is a common practice utilized by fleet vehicle owners in the for-hire and private carrier segments of the trucking industry. Under the current version of the IRP, truck lessors are required to register their vehicles in the base jurisdiction of each customer.
TRALA has also requested that the definition and official commentary regarding the term “apportionable vehicle” state that an apportionable vehicle is “used or intended for use” in two or more jurisdictions. Also with regard to apportionable vehicles, TRALA opposes language included in the current IRP draft stating that a company must have evidence that a vehicle traveled between two jurisdictions in 18 months in order for the vehicle to be presumed apportionable.