Permitting for Multi-State Projects: Strategies for Efficiency

A view from inside a truck cab looking out at a two‑lane road on a cloudy day, with a white semi‑truck driving toward the camera and industrial buildings and greenery lining both sides of the street.

Managing permits for multi-state projects can feel complex and overwhelming, and have many opportunities for mistakes. But with a well thought-out plan in place, you can sleep easy knowing you have control over your project. Follow these 6 steps to create a plan that works for you: 

1.      Apply for interstate operating authority if you don’t already have it. 

If you are already authorized for interstate commerce, you may skip this step. If you aren’t, it is essential that you register for authority as soon as possible.  

There is no temporary permit to be able to make an interstate trip without updating the MCS-150. A carrier will be considered to be operating as an interstate carrier if they make even one trip crossing a single state line. Changing operations from intrastate to interstate is possible, but may take some time and includes:  

  • Applying for/establishing: 
  • MCS-150, and 
  • For-hire authority; 
  • Updating process-agents; 
  • Demonstrating financial responsibility; 
  • Registering for UCR and pay the fee; 
  • Passing a new-entrant audit; and 
  • Ensuring compliance with all Federal Requirements for interstate carriers, including but not limited to DQ files, drugs/alcohol testing program, etc, 

After being issued a new entrant registration, the carrier is also subject to an 18-month safety-monitoring period. During this safety monitoring period, the carrier’s roadside safety performance will be closely monitored to ensure the carrier’s basic safety management controls are operating effectively. Also, during this safety-monitoring period, the motor carrier will receive a safety audit. 

2.      Determine which states you’ll be operating in. 

You can’t know what you need to stay compliant if you don’t know where you will be operating. Write a list detailing each state in which you will be operating.  

3.      Register for IFTA and IRP if appropriate.  

IFTA is an agreement on the collection and distribution of fuel use tax revenues among the lower 48 United States and 10 Canadian provinces. This program simplifies fuel tax reporting for carriers operating across multiple jurisdictions. To participate, you’ll need to obtain an IFTA license and file quarterly fuel tax returns. 

Under the IRP, qualifying commercial vehicles can travel through several jurisdictions with one license plate, provided the apportioned registration fees have been paid to the base jurisdiction. After collecting the fees, the base jurisdiction sends each jurisdiction its share and issues a single IRP cab card and apportioned vehicle registration plate, which allows motor carriers to travel in all jurisdictions. 

4.      Research state requirements. 

Once you have your list together, begin studying the requirements of each state. Do they require permits for either fuel taxes or oversize/overweight loads? Do you need to obtain them? 

  • Fuel permits – If you aren’t registered for IFTA, then look up permits needed for fuel taxes in each state. Depending on what you find, you may want to consider registering for IFTA.  
  • Size and weight permits – Determine your load size and weight, and look up each state’s size and weight limits, requirements, and permits.  
  • Highway use/mileage taxes – Several states (examples include: Connecticut, Oregon, New York, Kentucky, and New Mexico) impose additional taxes beyond fuel taxes. In most cases, trip permits are available to satisfy tax requirements for carriers not permanently registered.  

5.      Obtain all proper permits ahead of time. 

If you need permits, it’s best to begin that process as soon as possible. Some permits can be obtained very quickly, with instant approval being common for trip and fuel permits, while oversize and overweight permits may take a few days.  

6.      Create an organization system that works for you. 

You will want to find a way to store all of this information, including registrations and permits, in a way that ensures they are always easily accessible. 

Take the complexity out of multi-state projects by planning ahead and obtaining the proper authorities, registrations, and permits.