OTA Dispatch Issue 1, 2019

8 Oregon Trucking Associations, Inc. Oregon Truck Dispatch IN ISSUE 3 of the Oregon Truck Dispatch, I wrote an article titled, “What to Expect and How to Best Participate in a Weight Mile Tax Audit.” In that article I observed that if your records are “complete and accurate,” you have the right to request a complete audit of the audit period. A full month by month audit is the most accurate and you may serve yourself well by ensuring that your records allow such an audit to be undertaken. This follow-up article will discuss what your records must include in order to be judged to be “complete and accurate.” All carriers must maintain records containing the following information for each vehicle: ` ` Dates of each trip (starting and ending). ` ` Origin and destination points of each trip. ` ` Routes of travel for each trip. ` ` Daily beginning and ending odometer, hubodometer, engine control module or other mileage recording device readings for each vehicle for each trip. See the electronic records requirements in OAR 740-055-0120, Sections (4). ` ` Oregon entry and exit points. ` ` Number of actual Oregon miles operated for each trip in Oregon. ` ` Pickup and delivery points in Oregon for each trip. ` ` Load tickets and/or bills of lading for each shipment transported. ` ` Identification of any exempt miles claimed, which shall include beginning and ending odometer or other mileage recording device readings for the exempt portion of each trip. If repeated trips are made to and from the same locations, a one-time recording of mileage readings for the exempt portion of those trips may be applied to the total number of trips. Carriers operating motor vehicles that are issued or required to obtain an annual variance permit under ORS 818.200(1)(a) to (c) shall provide for each reporting period: ` ` The number of axles in the vehicle configuration. ` ` A record of changes of operation. A change of operation occurs when the vehicle configuration remains the same but the actual weight of the vehicle and load changes from over 80,000 lbs. to 80,000 lbs. or under. Empty movements are not changes in operation; and Carriers operating motor vehicles in multiple configurations shall provide the number of miles operated in each motor vehicle configuration for each trip. Records generated from on-board recording devices, vehicle tracking systems or other electronic data recording systems may be used in lieu of, or in addition to, the records required in this rule provided that the electronic records: ` ` Meet all the requirements listed above. ` ` Are provided in printed format upon request. All registrants that pay registration fees via registration trip permits must retain a copy of each registration trip permit. The same requirement applies to trip permits. Weight mile tax records must be kept for a minimum of three (3) years from the date your tax return is filed; however, if you are relying on these same records for IRP or IFTA purposes the retention period will be longer. You may well at this point be thinking that’s a lot of information and recordkeeping, right? There are a variety of ways that you can attempt to maintain the required records on a vehicle by vehicle basis. One solution is ODOT provides a link to an on-line fillable Vehicle Trip Record Form 735-9002E at www.oregon.gov/ODOT/Forms/ Motcarr/9002efill.pdf that captures all required data. That form is for interstate and intrastate carriers. ODOT also provides FORM 735-9002C for log and dump truck operators. It’s also worth noting that while tax reporting for a diesel fuel tax is done at the fleet summary level, weight mile tax reporting does require reporting at the individual vehicle level. Therefore, you’d need to complete one Vehicle Trip Record for each licensed vehicle in your fleet. ODOT advises that when operating five or fewer vehicles, it may be to the carrier’s advantage to submit vehicle trip records with the weight mile tax report. ODOT has produced and supplied a video on Weight Mile Tax Record Keeping Requirements By Gregg Dal Ponte, OTA’s Director of Regulatory Compliance REGULATORY COMPLIANCE