[Tod Wulff]

Good day, folks.

I have been looking for a resource that can help a noob get up to speed in short order with some specific dynamics related to regulatory requirements and the like.

I had looked for an IRC channel that had an audience to what I suspect the user base herein is comprised of. Unfortunately, I wasn't able to locate a suitable channel. All of the ones I came across were for gaming...

So, while web forums are not as 'real-time' as IRC, it seems that this might be the best resource for posing my inquiries and securing related guidance.

With that, I'll begin:

I am the Director of Gov't Services for an Aerospace Service Provider. We are bidding on a US Gov't contract to provide fueling services at a US Military Installation. The current contractor has elected to go out of business and is not competing for the new contract. I have articulated an opportunity to bid on their fleet of 20 vehicles (3ea 4-wheelers, 8ea tractor/trailer-tank combos (8200+ gal), and 9ea Straight Trucks (with single and dual product tanks ranging from 2500 gal to 5000 gal)).

The trucks are currently on-base (at an East Cost installation and will not be moved from there). The trucks are currently owned by the departing contractor. The company I work for intends to purchase the vehicles.

The contract is to retrieve US Gov't owned and furnished aviation and ground fuel from the base's tanks and, using the above mentioned fleet, deliver the fuel to aircraft and facilities on the base. there will be three trucks that are used to deliver fuel (aviation and ground fuel) to two off-base annexes (both located w/in 10 Miles of the base) - these three trucks will be traversing public roads.

My questions:

1. Is it correct to presume that we'll need to get a USDOT number?
2. The equipment all meets MC-/DOT-406/-407 requirements. Is there any reason in which I would have to replace any of this equipment with -412 certified assets?
3. Since we are not (presumably) engaging in interstate commerce movement, is it correct to presume that I'll not need to worry about securing an MC Operating Authority as a For-Hire Motor Carrier, but rather that we will be operating solely as a Private Motor Carrier, and not need the OA?
4. Our company is based in the Mid-West. It is correct to presume that we would need to register the fleet assets in our home state, or is there a compelling reason that I should attempt to register them in the state in which they currently reside and will continue to reside for the next 5 years?
5. The majority (15ea) of the vehicles are transporting Diesel based fuels (#2 Heating Oil, JP-5 & JP-8). One straight-truck will be carrying 100 octane low lead (avgas) and another straight-truck will be transporting ground vehicle unleaded fuel (mogas). I understand that only these two tanks will require annual hydrostatic testing due to the volatile fuels that they are carrying. Is this correct?
6. For the three straight-trucks that will be traversing public roads, are there any requirements that I haven't mention or should vet further?
7. The fuel product being delivered is US Gov't owned and is being delivered to US Gov't aircraft and US Gov't facilities. We will not be transiting across state lines with any product. As such, it is correct that we'll not have to pay excise tax on the fuel delivered, and only be burdened with paying excise tax on the fuel consumed by my prime movers in delivering the product?
8. I presume that I will need to provision for paying the Federal Heavy Highway Vehicle Use Tax (FHVUT) predicated by the IRS and collected via Form 2290, correct? Or, since I am merely delivering fuel to local USG equipment/installations, can I avoid this burden?
9. Is the term 'Fuel Tax Stamp' synonymous with the excise tax (IRS Pub 510) or the FHVUT?
10. Besides the obvious maintenance/repairs, Purchase Tax, Insurance, and the items mentioned above (State Registration/Tags, Excise Tax, and FHVUT), is there any other one-time or recurring charges that I should look into to verify responsibility for?

That's it for now. Please advise if someone has knowledge of these elements, or if there is a resource on the web where I can get smarter on these dynamics.

Thank you, in advance, for any assistance you can offer. It is much appreciated.

-t

[GMAN]

You may want to call the state IRP office where you will base the trucks. I would also recommend contacting OOIDA. www.ooida.com. They can assist you with most questions concerning motor carriers. I am not sure if it will make any difference since you will only be dealing with the federal government, but I will give a shot as to my opinion. You can also call the fmcsa in Washington DC. at 202-385-2435 or 202-358-7000. I would expect that you will at least need state or intrastate authority. You only need interstate authority if you cross state lines. The state IRP office should be able to answer that question for you. You will also likely need to set up an IFTA account and file quarterly reports since you will be traveling on public roads. When hauling hazmat, you will also likely need hazmat authority. It is separate from the motor carrier authority. There are additional requirements when you haul hazmat. You will need to pay your UCR for all vehicles. The UCR is an annual tax and is based upon the number of power units. A 2290 only needs to be paid on vehicles put into service that will be driven over 5,000/year. You can download the 2290 form from the IRS website or just go by your local IRS office. It will list the requirements for having to pay the tax. You will need to prove the tax has been paid or that you qualify for the exemption before you will be allowed to get your baseplates.