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entitled 'Motor Carrier Safety: Commercial Vehicle Registration Program 
Has Kept Unsafe Carriers from Operating, but Effectiveness Is Difficult 
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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

May 2009: 

Motor Carrier Safety: 

Commercial Vehicle Registration Program Has Kept Unsafe Carriers from 
Operating, but Effectiveness Is Difficult to Measure: 

GAO-09-495: 

GAO Highlights: 

Highlights of GAO-09-495, a report to congressional committees. 

Why GAO Did This Study: 

To reduce the number of crashes involving commercial motor carriers, 
the Federal Motor Carrier Safety Administration (FMCSA) within the 
Department of Transportation orders unsafe carriers out of service. To 
help keep these carriers off the road, FMCSA’s voluntary Performance 
and Registration Information Systems Management (PRISM) grant program, 
a small program funded at $5 million per year, helps states establish 
information systems connections between state vehicle registration and 
FMCSA’s safety databases. These connections provide states with up-to-
date information on carriers’ safety status when carriers try to 
register or renew registrations with the state. For states to deny, 
suspend, or revoke registrations to out-of-service carriers, states 
must pass legislation enabling them to do so. 

As directed by a congressional committee, GAO examined (1) PRISM’s 
effectiveness and (2) the potential to fully implement the program 
nationally. GAO reviewed FMCSA data and discussed PRISM with a wide 
variety of federal, state, industry, and safety stakeholders. 

What GAO Found: 

Twenty-five states have implemented PRISM to the point where they are 
able to keep carriers that FMCSA has ordered out of service from 
obtaining or maintaining vehicle registrations. However, PRISM’s safety 
impact is hard to measure. FMCSA data show that vehicles associated 
with 972 out-of-service carriers in 2008 had registrations denied, 
suspended, or revoked—about 15 percent of carriers placed out of 
service that year. However, this is likely an underestimate because the 
data can be difficult to track. Officials from the 13 states GAO 
contacted that are denying, suspending, or revoking vehicle 
registrations of out-of-service carriers and representatives from 
safety and industry associations said PRISM is worth the effort, but 
its impact on safety is hard to measure. An evaluation of the program 
sponsored by FMCSA in 2007 concluded that PRISM states show some 
improved safety over time compared with other states, indicating PRISM 
could have contributed to lower crash rates. However, because all FMCSA 
programs are aimed at reducing crash rates, isolating PRISM’s effect is 
difficult. Nonetheless, the evaluation recommended that FMCSA adopt 
program measures to assess PRISM’s effectiveness. FMCSA has not adopted 
all of these measures for various reasons, including a lack of 
resources. In GAO’s view, applying such measures, while ultimately 
useful, may be premature since PRISM’s success is undercut by the 25 
states—including states with the greatest numbers of registered 
commercial motor vehicles—and the District of Columbia that do not yet 
have the ability to deny, suspend, or revoke vehicle registrations of 
out-of-service carriers. 

National implementation may not occur for years if PRISM continues as a 
voluntary program. FMCSA data show that, on average, it took states 
about 3 years and 4 months to get to the point where they could deny, 
suspend, or revoke registrations once they decided to implement PRISM—a 
process that took as little as 10 months to more than 7 years. 
Officials in states GAO contacted said that PRISM implementation was 
facilitated by such things as hiring a contractor to help with the 
program’s technical components, and was hindered by such things as 
difficulty in passing state legislation needed to implement the 
program. According to officials in states GAO met with, FMCSA has been 
helpful in encouraging states to adopt and implement the program, but 
can do little in other areas, such as when state legislation is needed. 
Officials in some states and representatives from safety associations 
told GAO that Congress should require PRISM implementation so that no 
state becomes a refuge for registering out-of-service carriers. Other 
officials said that such a requirement is unnecessary, since only three 
states have not committed to implementing PRISM. While there are 
benefits to a congressional requirement that could lead to speedier 
national implementation, there are several significant potential 
drawbacks to doing so (for example, some states may require substantial 
money to adapt their information systems to make PRISM work) that lead 
GAO not to recommend such a requirement. 

What GAO Recommends: 

GAO recommends that FMCSA measure PRISM effectiveness when a sufficient 
number of states have the ability to deny, suspend, or revoke 
registrations to out-of-service carriers. In commenting on a draft of 
this report, the department generally agreed with the recommendation. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-495]. For more 
information, contact Susan A. Fleming at (202) 512-2834 or 
flemings@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

PRISM Has Helped Keep Unsafe Carriers from Registering, but Its Impact 
on Safety Is Hard to Measure: 

National PRISM Implementation May Not Occur for Years if PRISM Is 
Maintained as a Voluntary Program: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Applicability of Mandatory and Voluntary Approaches to 
Implementing PRISM: 

Table 2: State Agencies and Industry and Safety Associations 
Interviewed: 

Figures: 

Figure 1: States Participating in PRISM, as of April 2009: 

Figure 2: Time Taken for States to Reach Ability to Deny, Suspend, or 
Revoke Vehicle Registrations: 

Figure 3: Progress in Implementing PRISM, 2000 through April 2009: 

Abbreviations: 

BAC: blood alcohol concentration: 

DOT: Department of Transportation: 

FMCSA: Federal Motor Carrier Safety Administration: 

IRP: International Registration Plan: 

NDR: National Driver Registry: 

PRISM: Performance and Registration Information Systems Management: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

May 12, 2009: 

The Honorable Patty Murray:
Chairman:
The Honorable Christopher Bond:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development, and 
Related Agencies:
Committee on Appropriations:
United States Senate: 

The Honorable John W. Olver:
Chairman:
The Honorable Tom Latham:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development, and 
Related Agencies:
Committee on Appropriations:
House of Representatives: 

In the United States, commercial motor carriers account for fewer than 
5 percent of all highway crashes, but these crashes result in about 13 
percent of all highway deaths, or about 5,500 of the approximately 
43,000 highway fatalities that occur nationwide each year.[Footnote 1] 
In an attempt to reduce the number and severity of crashes involving 
large trucks and buses, the Federal Motor Carrier Safety Administration 
(FMCSA) within the Department of Transportation (DOT) identifies unsafe 
motor carriers and takes them off the road by ordering them out of 
service. Carriers that have been ordered out of service by FMCSA may 
not operate until their safety performance improves and FMCSA rescinds 
the out-of-service order. 

The primary way that FMCSA ensures that carriers the agency has ordered 
out of service do not continue to operate is the Performance and 
Registration Information Systems Management (PRISM) grant program. 
PRISM works by allocating grant money to states to establish 
information systems connections between state commercial vehicle 
registration databases and FMCSA's safety databases that, when fully 
implemented, (1) provides up-to-date information on the safety status 
of the carrier responsible for the safety of a commercial vehicle prior 
to issuing or renewing the vehicle registration and (2) generates a 
daily list of vehicles registered in the state that are associated with 
carriers that have just been ordered out of service by FMCSA. For new 
registrations or renewals, when state personnel enter carrier and 
vehicle information into the system, it automatically checks the 
information against FMCSA databases, and a notice will appear to deny 
the registration if the carrier is out of service. For vehicles already 
registered in the state, state personnel use the list the state creates 
each night to suspend or revoke the vehicle registrations associated 
with newly ordered out-of-service carriers. To implement PRISM, states 
must pass enabling legislation, providing state registration agencies 
(motor vehicle administrations) with the ability to deny, suspend, or 
revoke vehicle registrations of carriers ordered out of service by 
FMCSA. 

PRISM's innovation is that it associates vehicle identification numbers 
with out-of-service carriers to prevent the carrier from registering or 
reregistering its vehicles (either under the carrier's original name 
or, more importantly, disguised under a new name) until FMCSA lifts the 
out-of-service order. Once the out-of-service order is lifted, the 
carrier may obtain valid vehicle registrations. Preventing unsafe motor 
carriers from obtaining or maintaining vehicle registrations deters 
these carriers from operating, since state law enforcement agencies 
continually check commercial vehicles for valid registrations.[Footnote 
2] 

In the Intermodal Surface Transportation Efficiency Act of 1991, 
Congress mandated the PRISM pilot demonstration project to evaluate the 
potential benefits of using state commercial motor vehicle registration 
sanctions as an incentive to improve motor carrier safety. Five states 
participated in the pilot, which ended in 1997, and a final report 
assessing the program was submitted to Congress in 1998. In 1998, 
Congress authorized additional funding to implement the program 
nationwide. As of April 2009, 47 states and the District of Columbia 
participate in it to some degree. Twenty-five of these states have 
implemented PRISM to the extent that they can automatically identify 
out-of-service carriers and then deny, suspend, or revoke their vehicle 
registrations.[Footnote 3] 

The Senate Committee on Appropriations directed that we assess (1) the 
PRISM grant program's effectiveness in removing unsafe motor carriers 
from U.S. roadways and (2) the potential to fully implement the program 
nationally. 

To report on the extent to which the PRISM grants program has 
effectively removed unsafe carriers from the roadway, we obtained FMCSA 
data on the number of motor carriers that had vehicle registrations 
denied, suspended, or revoked as a result of an FMCSA out-of-service 
order. We interviewed FMCSA officials to discuss how data are collected 
and verified and how the data are used to assess PRISM's effectiveness. 
We also conducted semistructured interviews with a nongeneralizable 
sample of state motor vehicle administration officials and state law 
enforcement officials from 13 states that deny, suspend, or revoke 
vehicle registrations to discuss their experience implementing PRISM, 
how effective the program has been, and the soundness of reported data. 
We obtained the view of state officials and representatives from motor 
carrier industry and safety associations on the extent to which PRISM 
has improved states' ability to identify unsafe carriers and take them 
off the road by denying, suspending, or revoking vehicle registrations 
and any factors that impact PRISM's effectiveness. We reviewed a 2007 
Volpe National Transportation Systems Center evaluation of the PRISM 
program that reported on the extent to which PRISM has improved the 
safety and limitations of FMCSA's data on the denial, suspension, or 
revocation of vehicle registrations of out-of-service carriers[Footnote 
4]. We reviewed information from interviews and the Volpe report to 
identify and describe the factors that limit PRISM's effectiveness. 

To report on the potential to fully implement the program nationally, 
we met with officials from FMCSA, state motor vehicle administrations, 
and state law enforcement in 26 selected states, as well as 
representatives from industry and safety associations. We conducted 
semistructured interviews with state motor vehicle administrations from 
13 states that deny, suspend, or revoke vehicle registrations; 3 states 
that are implementing PRISM but do not yet have the capability to 
affect vehicle registrations; 8 states that have committed to implement 
PRISM but are not far along in implementation; and 2 states that do not 
participate in PRISM at all. We analyzed testimonial evidence to 
identify factors that enabled states to deny, suspend, and revoke 
registrations and factors that have delayed or prevented other states 
from moving forward with PRISM implementation. We analyzed the 
information to identify the factors FMCSA can affect and those it 
cannot. We also conducted a general literature search to identify the 
conditions for when either a mandatory approach or a voluntary approach 
is preferred for achieving program participation and certain desired 
outcomes. In addition, we identified and analyzed drawbacks to 
requiring state implementation of PRISM and potential options available 
to Congress for encouraging--rather than mandating--state legislative 
or regulatory action that could speed nationwide PRISM implementation. 

As part of our review, we assessed the reliability of FMCSA's data on 
the number of motor carriers that had vehicle registrations denied, 
suspended, or revoked because of an FMCSA out-of-service order. While 
we identified some shortcomings to the data (discussed later in this 
report), we determined that the data were sufficiently reliable for our 
purpose, which was to provide a general sense of the extent to which 
PRISM implementation has resulted in vehicle registration sanctions. We 
conducted this performance audit from June 2008 to May 2009 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. (See appendix I for 
additional information on our scope and methodology.) 

Background: 

The interstate commercial motor carrier industry is large and dynamic. 
According to FMCSA data, there are about 716,000 interstate carriers 
registered with FMCSA to operate. While the largest motor carriers 
operate upward of 50,000 vehicles, most carriers are small, with 
approximately 80 percent operating between one and six vehicles. 
Commercial motor vehicles travel over 222 billion miles each year over 
the nation's extensive road network. 

FMCSA's primary mission is to reduce the number and severity of crashes 
involving large commercial trucks and buses involved in interstate 
commerce. It carries out this mission by issuing, administering, and 
enforcing federal motor carrier safety regulations and hazardous 
materials regulations and gathering and analyzing data on motor 
carriers, drivers, and vehicles, among other things. FMCSA also takes 
enforcement actions itself and funds and oversees enforcement 
activities at the state level through Motor Carrier Safety Assistance 
Program grants. 

FMCSA ensures that motor carriers comply with safety regulations 
primarily through compliance reviews of carriers already in the 
industry and safety audits of carriers that have recently started 
operations. Compliance reviews and safety audits help FMCSA determine 
whether carriers are complying with its safety regulations and, if not, 
to take enforcement action against them, including placing carriers out 
of service.[Footnote 5] FMCSA makes its compliance determination based 
on a carrier's performance in six areas: one area is the carrier's 
crash rate, and the other five areas involve the carrier's compliance 
with regulations, such as insurance coverage, driver qualifications, 
and vehicle maintenance and inspections. In addition, FMCSA places 
carriers out of service for failure to pay civil penalties levied by 
FMCSA, failing a safety audit, and for failing to schedule a safety 
audit. Out-of-service carriers must cease operations and cannot resume 
operations until FMCSA determines that they have corrected the 
conditions that rendered them out of service. If a carrier fails to 
comply with or disregards an out-of-service order, FMCSA may assess a 
civil monetary penalty each time the vehicle is operated in violation 
of the order. In 2008, FMCSA ordered 6,707 carriers out of service. 

FMCSA and state law enforcement agencies are dwarfed by the size of the 
industry and, as a result, are only able to conduct compliance reviews 
on a very small percentage of carriers--about 18,400 in fiscal year 
2008.[Footnote 6] Safety audits are required for all new entrants to 
the trucking industry; approximately 37,400 safety audits were 
conducted in fiscal year 2008. In addition to compliance reviews and 
safety audits, FMCSA and state law enforcement agencies conduct about 
2.3 million vehicle inspections each year at weigh stations and other 
locations to assess the safety compliance of individual vehicles. 

FMCSA and state law enforcement agencies use several methods to ensure 
that carriers that have been ordered out of service do not continue to 
operate. For example, FMCSA and its state partners monitor data on 
roadside inspections, moving violations, and crashes to identify 
carriers that may be violating an out-of-service order. FMCSA will 
visit some suspect carriers that it identifies by monitoring crash and 
inspection data to determine whether those carriers violated their 
orders. Also, recently, the Commercial Vehicle Safety Alliance[Footnote 
7] began to require checking for carriers operating under an out-of- 
service order during roadside inspections and to take enforcement 
action against any that are. However, given the large size of the 
industry, the nation's extensive road network, and the relatively small 
size of federal and state enforcement staffs, it is difficult to catch 
motor carriers that are violating out-of-service orders. In addition, 
some carriers change their identities by changing their names and 
obtaining new DOT numbers[Footnote 8]--which are generally referred to 
as chameleon carriers--to avoid being caught. 

FMCSA allocates PRISM grants to states to address the problems of out- 
of-service carriers registering or reregistering vehicles (when renewal 
is needed), including chameleon carriers. PRISM grants enable states to 
work through the registration protocol--known as the International 
Registration Plan (IRP)[Footnote 9]--that state motor vehicle 
administrations use to register vehicles of carriers involved in 
interstate commerce. In 2008, over 2 million vehicles had IRP 
(interstate) registrations. PRISM grants provide the state motor 
vehicle administration where the vehicle is registered--called the 
"base state"--with the capability to check the safety status of motor 
carriers, using the carrier's DOT number and the vehicle identification 
number, prior to issuing or renewing a carrier's registration. 

According to FMCSA, sanctioning the IRP (interstate) registrations of 
commercial motor vehicles is a powerful enforcement tool in deterring 
out-of-service carriers from operating on U.S. roadways. If the carrier 
or vehicle is associated with an out-of-service order at the time of 
registration, the state motor vehicle administration will deny the 
registration of that carrier if the state has implemented PRISM to the 
point where it can deny registrations to out-of-service carriers. In 
addition, state motor vehicle administrations also suspend or revoke 
the registrations of vehicles associated with out-of-service carriers, 
without waiting for the carrier to attempt to reregister. States use 
various methods to inform a carrier that its vehicle registrations have 
been suspended or revoked. For example, some states notify the carrier 
via letter, and some states request that the carrier return the vehicle 
license plates. Other states send motor vehicle administration 
personnel or state law enforcement to the carrier's place of business 
to retrieve the license plates following a registration suspension or 
revocation. 

Another benefit of PRISM is that it helps prevent an out-of-service 
carrier from registering in a state other than its base state in an 
attempt to avoid having its registration denied. This works to the 
extent that the nonbase state or states in which the carrier seeks to 
register participate in and have fully implemented the PRISM program 
(that is, deny, suspend, or revoke vehicle registrations to out-of- 
service carriers). As of April 2009, 25 states have this capability. 
(See figure 1.) Six other states are collecting vehicle identification 
numbers and the DOT number of the carriers associated with those 
vehicles and may be checking the safety status of the carrier at the 
time of registration. Sixteen other states and the District of Columbia 
have entered into an agreement with FMCSA to implement PRISM grants but 
have not yet moved forward substantially to implement the program. The 
remaining three states do not participate. 

Figure 1: States Participating in PRISM, as of April 2009: 

[Refer to PDF for image: map] 

Entered into an agreement with FMCSA to implement PRISM but have not 
yet moved forward substantially to implement the program (16 states and 
D.C.): 
California: 
Colorado: 
District of Columbia: 
Florida: 
Hawaii: 
Illinois: 
Massachusetts: 
Mississippi: 
Montana: 
New Jersey: 
New York: 
North Dakota: 
Rhode Island: 
Virginia: 
Wisconsin: 
Wyoming. 

Collecting vehicle identification numbers and the DOT number of the 
carriers associated with those vehicles and may be checking the safety 
status of the carrier at the time of registration (6 states): 
Arizona: 
Louisiana: 
Oklahoma: 
Oregon: 
Pennsylvania: 
Texas. 

Denying, suspending, and revoking vehicle registrations of out-of-
service carriers(25 states): 
Alabama: 
Alaska: 
Arkansas: 
Connecticut: 
Delaware: 
Georgia: 
Idaho: 
Indiana: 
Iowa: 
Kansas: 
Kentucky: 
Maine: 
Minnesota: 
Missouri: 
Nebraska: 
New Hampshire: 
New Mexico: 
North Carolina: 
Ohio: 
South Carolina: 
South Dakota: 
Tennessee: 
Utah: 
Vermont: 
Washington: 
West Virginia. 

Do not participate (3 states): 
Maryland: 
Michigan: 
Nevada. 

Source: FMCSA (data); and MapArt (map). 

Note: While Alaska and Hawaii do not participate in IRP, each state has 
a system that provides them with the capability to deny, revoke, or 
suspend the commercial vehicles regulated by FMCSA. 

[End of figure] 

Within FMCSA's 2008 budget (including grants) of about $530 million, 
the PRISM grants program is very small. Under the Safe, Accountable, 
Flexible, Efficient Transportation Equity Act: A Legacy for Users, 
PRISM is authorized $5 million annually from fiscal years 2005 through 
2009.[Footnote 10] These amounts have been appropriated each year. 
FMCSA officials told us that they annually allocate about $4 million to 
participating states in the form of grants and $1 million for FMCSA 
program administration. 

States use PRISM grant funds--approximately $500,000 per state--to 
implement several requirements.[Footnote 11] For example, for 
registration requirements, states create and maintain information 
technology connections to FMCSA's safety databases and the state's IRP 
system to collect and validate the DOT number of the carrier each 
vehicle is associated with and to check the safety status of those 
carriers. States also develop the programs necessary to load and 
retrieve data and correctly process the information to its system. In 
addition, in order to capture the DOT number and other carrier 
information on each vehicle record, states will need to modify existing 
forms, screen formats, and information storage. States also develop 
procedures to check the carrier safety status on each registration or 
renewal and train staff on how to do such checks. Although PRISM grants 
are intended to pay for the total costs to carry out all program 
requirements, states contribute some funds for program implementation. 

FMCSA uses its PRISM funds for technical support for its databases, as 
well as for travel costs. Although FMCSA did not use PRISM funds to 
support PRISM program personnel's travel in fiscal year 2008, FMCSA 
officials told us that it has done so to date in fiscal year 2009 due 
to general agency travel budget constraints associated with the fiscal 
year 2009 continuing resolution. 

PRISM Has Helped Keep Unsafe Carriers from Registering, but Its Impact 
on Safety Is Hard to Measure: 

PRISM Has Enabled 25 States to Identify and Keep Unsafe Carriers from 
Obtaining or Maintaining Vehicle Registrations: 

FMCSA data show that PRISM has resulted in the denial, suspension, or 
revocation of the commercial motor vehicle registrations of 972 
carriers in 2008.[Footnote 12] According to FMCSA data, 671 unsafe 
motor carriers had vehicle registrations suspended or revoked, while 
301 unsafe motor carriers had vehicle registrations denied--together 
representing about 15 percent of carriers that were ordered out of 
service in 2008.[Footnote 13] These results are likely understated 
because some states that are reporting are not able to track the data 
in a systematic or verifiable way. Three of the 13 states we contacted 
that deny, suspend, and revoke vehicle registrations based on an out- 
of-service order do not track the number of registration denials. 
Officials in one of those three states told us that no record is 
created when registrations are denied. Rather, after a carrier 
attempting to register or reregister a vehicle associated with an out- 
of-service DOT number in that state is told the out-of-service order 
precludes registration, the carrier typically leaves the office, ending 
the matter. Officials in another state manually track denials, but have 
no method of verifying the data. FMCSA officials acknowledge that there 
are limitations to the data and that the data probably underestimate 
the number of denials, suspensions, and revocations that occur. 

Stakeholders Contacted View PRISM Implementation as Worth the Effort, 
Although Its Impact on Safety Is Difficult to Measure: 

Officials from each of the 13 states we contacted that deny, suspend, 
or revoke registrations told us that they believe PRISM is worth the 
effort to implement because the grant program provides a deterrent 
against unsafe carriers. State officials told us that the deterrent can 
increase safety, but they could not quantify improved safety outside of 
tracking the number of denials, suspensions, and revocations of vehicle 
registrations to out-of-service carriers. Law enforcement officials in 
one state we met with told us that PRISM grants may enable them to 
identify these carriers by providing officials with wireless 
connections to safety databases, allowing officials to check a 
carrier's safety status at weigh stations on the roadside. As a result, 
several state officials believe that PRISM has helped keep their 
roadways safer. For example, officials in one state told us that PRISM 
implementation is worth the effort--even if it has only prevented a few 
out-of-service carriers from registering. The state official said that 
if PRISM implementation prevents a major, expensive crash, then the 
program would be a success. 

FMCSA officials told us that state denial of vehicle registrations 
associated with out-of-service carriers serve as a sufficient deterrent 
to prevent some unsafe carriers from attempting to obtain valid 
registrations. Representatives from industry and safety groups echoed 
these comments. Representatives from a safety association we met with 
told us that PRISM is the only program that establishes a safety 
connection between a vehicle and the motor carrier company on an up-to- 
date basis. 

We believe that the PRISM program appears to have a very strong 
potential cost-benefit component. The overall cost of implementing the 
program ($5 million per year) is relatively small in comparison to the 
potential benefit of increased roadway safety as a result of reduced 
out-of service carriers operating on U.S. roadways, especially as more 
states deny, suspend, and revoke the registrations of vehicles 
associated with out-of-service carriers. 

FMCSA Has Looked for Ways to Measure PRISM's Impact on Safety, but Has 
Not Yet Adopted Measures: 

FMCSA sought to understand PRISM's effectiveness by sponsoring an 
evaluation of the PRISM program and the extent to which PRISM has 
improved safety. In 2007, the Volpe Center, which conducted this 
evaluation, concluded that states with denial, suspension, and 
revocation capability show some improved safety over time compared with 
other states, indicating that PRISM, when fully implemented, could have 
contributed to lower crash rates, although its results were 
inconclusive in several areas.[Footnote 14] The Volpe report used two 
measures to assess how PRISM's registration sanction component affected 
commercial vehicle safety:[Footnote 15] 

* Comparison of commercial vehicle crash rates in pre-PRISM versus post-
PRISM states and in PRISM versus non-PRISM states by year. The report 
found that the comparison of crash rates in eight states that 
progressed from nonparticipating to denying, suspending, and revoking 
vehicle registrations between 2000 and 2005 revealed a potential 
downward influence on crash rates in states that fully implemented 
PRISM. While almost all eight states had rising crash rates over time, 
the increase was lower for these states compared with other states that 
did not fully implement PRISM over the same time period. Comparisons 
between commercial vehicle crash rates in states that do not 
participate in PRISM and states that deny, suspend, and revoke vehicle 
registrations by year were inconclusive. 

* States' success in denying registrations to out-of-service carriers. 
The report found that, with few exceptions, PRISM states did not 
erroneously issue registrations to out-of-service carriers. 

The Volpe report concluded that PRISM cannot succeed alone, as it works 
in conjunction with other FMCSA and state programs (for example, 
compliance reviews, new entrant safety audits, and roadside 
inspections) to reduce crashes and safety violation rates. Because all 
FMCSA programs are aimed at reducing crash rates and because numerous 
factors contribute to crash rates, isolating PRISM's effect is 
difficult. 

Although isolating PRISM's impact on safety is difficult, measuring 
performance when a significant number of states fully implement PRISM 
could help FMCSA assess PRISM's effectiveness in achieving the program 
goal of improved safety. The 2007 Volpe report suggested that FMCSA 
evaluate the program's effectiveness by using the measures discussed 
above, which Volpe initially used to assess PRISM's effect on 
commercial vehicle safety (that is, comparison of crash rates and state 
success in sanctioning registrations). FMCSA officials told us they 
have not evaluated crash rates in states pre-and post-PRISM 
implementation because of insufficient resources and because of the 
difficulty of isolating PRISM's effect on crash rates. For example, the 
benefits of PRISM implementation may not be seen in the state that 
implemented the program (that is, a vehicle denied registration in one 
state may have had a crash in another state). As such, isolating 
PRISM's effect on state crash rates is complicated, particularly when 
only about half the states have fully implemented PRISM. Consequently, 
changes in crash rates pre-and post-PRISM may be attributable to other 
factors. FMCSA officials told us that this may simply represent a 
correlation, rather than a cause and effect relationship, or may be the 
result of the state implementing a variety of safety-related actions. 
However, as the Volpe report noted, an effective control method for 
factors that influence motor carrier crash occurrence (for example, 
highway infrastructure or weather) is to observe the impact of PRISM 
implementation one state at a time, comparing pre-and post-PRISM crash 
rates within the same states over time. The Volpe report added that 
while such an approach does not eliminate the problem of external 
factors that influence crash rates, it provides a degree of control not 
possible in simple comparisons of crash rates between PRISM and non- 
PRISM states. 

While the current FMCSA data on PRISM--the number of denials, 
suspensions, and revocations--are useful, they do not fully measure 
PRISM's effectiveness. In particular, the number of denials is an 
imperfect measure. As the Volpe report points out, a reduction in the 
number of denials over time may imply either that PRISM is not doing a 
good job or that PRISM has had a substantial positive influence by 
functioning as a deterrent that discourages carriers from attempting to 
register vehicles while under an out-of-service order. Over time and as 
more states participate in PRISM, the number of denials may decrease 
because carriers will know that they will not be able to receive valid 
registrations if they are out of service.[Footnote 16] Furthermore, 
until all--or nearly all--states are fully implementing PRISM, the 
numbers of suspensions and revocations are also imperfect measures, 
since out-of-service carriers can obtain vehicle registrations in the 
states that are not fully implementing PRISM. According to FMCSA 
officials, since the Volpe evaluation, PRISM has implemented an alert 
report that identifies vehicles when they are placed out of service. 
State officials then suspend these vehicles in a timely manner, leaving 
very few vehicles that are available to fit into the category of denial 
of registration at renewal. 

FMCSA officials also told us that the number of carriers that have 
vehicle registrations suspended and revoked under PRISM will not be 
equal to the number of carriers ordered out of service in a given year 
for several reasons. First, according to FMCSA data, the majority of 
carriers (about 87 percent) ordered out of service in 2008 were new 
entrants. These entrants may not have tried to register vehicles, so 
there may not be any vehicle registrations to suspend or revoke, or 
they may have mistakenly registered as an interstate carrier when they 
should have registered as an intrastate carrier or a registrant only. 
[Footnote 17] According to FMCSA officials, these registrants provide a 
DOT number at the time of registration for the carrier responsible for 
safety. Since the DOT number is not associated with a carrier that is 
out of service, the vehicles will not be suspended even if the 
registrant's number is associated with an out-of-service order. Second, 
for those carriers ordered out of service for failure to pay fines 
(about 8 percent in 2008, according to FMCSA data), FMCSA advises 
states to check with the state FMCSA Division Office before they go 
through the work of denying, suspending, and revoking vehicles. FMCSA 
advises this action because the fines may be resolved within a couple 
of days, and it would not be worth the effort of sanctioning the 
registrations to reinstate them hours or days later. In addition, there 
are also out-of-service carriers in non-PRISM states that will not have 
their vehicle registrations suspended. Last, the numbers of out-of- 
service carriers include interstate carriers that operate vehicles that 
weigh between 10,000 and 26,000 pounds. IRP does not require carriers 
to register vehicles that weigh less than 26,000 pounds. Since PRISM 
only affects IRP registrations--these carriers are not included in 
PRISM. 

The Volpe report indicated that PRISM will struggle to achieve its full 
potential until most states (perhaps 90 percent) are implementing PRISM 
to the extent that they can deny, suspend, and revoke vehicle 
registrations. FMCSA officials said that other than collecting data on 
the number of out-of-service carriers that had vehicle registrations 
sanctioned, it is difficult to measure PRISM's effectiveness. One 
official told us that as long as the program is executed correctly, 
PRISM enables states to deny, suspend, or revoke the vehicle 
registrations of out-of-service carriers. When most states have the 
capability to sanction registrations, it may be easier to demonstrate 
PRISM's effect on safety. FMCSA officials have suggested that this 
might be from about 38 to 40 states. 

In response to the Volpe evaluation, FMCSA developed performance 
measures for state participants, such as suspending or revoking the 
registration of vehicles associated with an out-of-service carrier for 
all reasons permitted by state law, and for the PRISM team, such as 
performing annual implementation reviews on six states, assisting 
states in preparing their implementation plans, and publishing two 
newsletters each year. For the most part, these measures seem to be 
process-oriented and do not appear to demonstrate the achievements of 
the program. 

In our view, applying outcome performance measures such as Volpe's two 
measures and measuring the percentage of out-of-service carriers 
affected by PRISM, while ultimately useful, may be premature at this 
time. Currently, PRISM's success is undercut by the 25 states and the 
District of Columbia that either do not yet have the capability to 
deny, suspend, or revoke vehicle registrations of out-of-service 
carriers or do not participate in the program. 

Patchwork Implementation Is One of Several Factors Limiting PRISM's 
Effectiveness: 

According to FMCSA data, 22 states and the District of Columbia are not 
far enough along in implementing PRISM to deny, suspend, or revoke 
vehicle registrations of out-of-service carriers, and 3 states do not 
participate in PRISM at all. As a result, out-of-service carriers in 
these 25 states and the District of Columbia can register and 
reregister vehicles and keep operating with valid registrations, albeit 
in violation of FMCSA's out-of-service orders. In addition, carriers 
that had been denied registration in PRISM states may be able to 
register vehicles in non-PRISM states or PRISM states that do not yet 
have the capability to deny, revoke, or suspend registrations for out- 
of-service carriers. Of the over 2 million vehicles with IRP 
registrations in 2007, about 1.3 million vehicles (or 65 percent) were 
registered in states that are not denying, suspending, or revoking 
vehicle registrations. States with some of the largest numbers of 
commercial vehicle registrations, such as Indiana, Illinois, Oklahoma, 
New Jersey, and California, have not fully implemented PRISM. 

In addition, charter buses are exempt from IRP (interstate) 
registration and thus not subject to PRISM.[Footnote 18] Charter bus 
crashes are relatively rare but can be particularly deadly, since many 
people may be involved. The American Bus Association commissioned a 
2008 motor coach census, which found that in 2007, over 3,400 carriers 
operated about 33,500 buses in the United States and Canada.[Footnote 
19] Over 96 percent of carriers provided charter services. Although 
some charter buses choose to register through IRP, many do not and, 
therefore, are not included in PRISM. Representatives from IRP, Inc., 
the American Association of Motor Vehicle Administrators, and the 
United Motorcoach Association, as well as officials from FMCSA, told us 
that charter buses are exempt from IRP registrations because the 
vehicles are for hire and may not be able to reliably predict which 
states they may travel to in order to properly apportion registration 
fees. The representatives, however, were not able to provide a 
rationale for why this exemption does not apply to for-hire trucking 
companies that also may not be able to reliably predict the states in 
which they may travel. Officials from FMCSA told us that charter buses 
could be included in PRISM if charter buses were required to register 
through IRP or if PRISM was expanded to include non-IRP vehicles. 
Officials from nine states we met with that sanction vehicle 
registrations of out-of-service carriers told us that charter buses 
should be included in PRISM. According to representatives from IRP, 
Inc., there has been some discussion on changing the exemption to 
require charter buses to register through IRP; however, no changes have 
been formally submitted for approval by its member states. 

Finally, while PRISM helps states identify vehicles associated with an 
out-of-service carrier, they are not always able to keep these vehicles 
from being registered. Theoretically, when an out-of-service carrier 
attempts to reregister a vehicle using a new carrier name and new DOT 
number, states implementing PRISM would know that the vehicle 
identification number is or has been associated with an out-of-service 
DOT number. In some states, officials said that they deny registrations 
to carriers they suspect of being chameleon carriers because the IRP 
system alerts them that the vehicles are associated with an out-of- 
service carrier. However, officials from 6 of the 13 states we 
contacted that deny, suspend, and revoke vehicle registrations told us 
that they provide registrations because they cannot conclusively link 
the new carrier to the old out-of-service carrier at the time of 
registration--even if the vehicle identification number is or has been 
associated with an out-of-service carrier--especially when the new 
carrier is presenting legitimate documentation of the new company. In 
one state, officials told us that if a vehicle identification number 
for a new registration is identified through PRISM as being associated 
with an out-of-service DOT number, the carrier is notified that the 
vehicle is attached to the out-of-service DOT number. If the carrier 
provides proper documentation to support ownership (for example, proof 
of an established place of business in the state, proof of title for 
the vehicles being registered, and other documents), the vehicle is 
registered[Footnote 20]. Officials added that they would also provide 
registration for these carriers because it would be next to impossible 
to prove differently based on speculation. 

In another state, officials told us that once a chameleon carrier 
obtains a new DOT number, the motor vehicle administration is unable to 
prevent the carrier from obtaining an IRP registration--even if they 
know the carrier is a chameleon carrier--because they do not deny the 
registration until FMCSA connects the identity of the "new" carrier 
with the out-of-service carrier. According to those state officials, 
they issue new registrations to carriers that have valid paperwork 
showing a new name and DOT number, among other things. Those officials 
also told us that they contact the state FMCSA division office when 
they suspect that a carrier may be evading an out-of-service order. An 
official from the FMCSA state division office told us they investigate 
the carrier by reviewing carrier, driver, and vehicle records to 
determine whether the carrier is in fact a chameleon carrier. If they 
are able to prove that the carrier reinvented itself to evade an out- 
of-service order, the out-of-service order will be transferred to the 
new DOT number, and the state can then suspend the vehicle 
registrations associated with the new DOT number. 

Chameleon carriers may also remain in operation in many states by 
registering as intrastate carriers, but continuing to operate as 
interstate carriers. By registering as intrastate carriers, these 
carriers are no longer subject to federal regulation. Officials in 12 
of the 13 states we contacted were not using vehicle identification 
numbers to check for federal out-of service orders prior to issuing an 
intrastate registration to a carrier. According to FMCSA officials, 
FMCSA has been recommending that states modify their laws to prohibit 
the issuance of any vehicle registration to a carrier that has received 
a federal out-of-service order. FMCSA has also allocated a supplemental 
grant to Washington state to incorporate non-IRP registrations into the 
PRISM network to ensure that state motor vehicle administrations check 
federal out-of-service orders before issuing registrations to non-IRP 
vehicles. Georgia officials told us they requested funds to expand 
PRISM to non-IRP commercial vehicles. According to FMCSA officials, the 
agency provides funds to expand PRISM's registration sanction framework 
to include vehicles exempt from IRP registrations. Most states have two 
databases for registering motor vehicles--one for vehicles that are 
required to obtain IRP registrations and one for vehicles that are 
exempt, such as charter buses that are under FMCSA's oversight and 
intrastate carriers. Thus, even though intrastate carriers are not 
generally under FMCSA's regulatory authority, they are included within 
the registration database of other vehicles that are under FMCSA's 
regulatory authority. 

National PRISM Implementation May Not Occur for Years if PRISM Is 
Maintained as a Voluntary Program: 

Time States Need to Implement PRISM Varies: 

PRISM will be most effective when all--or nearly all--states have the 
ability to deny, suspend, and revoke registrations; only about half of 
them have this capability now. At the outset of PRISM implementation, 
FMCSA works with each state to create an implementation plan, which 
includes identifying responsible parties, how the state will meet the 
program requirements, timelines for completion, and estimated costs. 
States are also required to report their progress to FMCSA on a regular 
basis, as designated in the implementation plan. While some states have 
implemented PRISM relatively quickly, it has taken other states much 
longer. FMCSA data show that the average time it took states to affect 
vehicle registrations after the states committed to implementing PRISM 
was 3 years and 4 months, but it can take as little as 10 months or as 
long as 7 years and 4 months. (See figure 2.) In addition, FMCSA data 
show that nine states have been implementing PRISM for 5 years or more 
but are not yet able to deny, suspend, or revoke vehicle registrations 
of out-of-service carriers for reasons discussed later in this report. 
FMCSA officials stated, however, that in comparison with other 
voluntary programs, such as IRP and the International Fuel Tax 
Agreement (a fuel use tax agreement that establishes uniform 
administration of motor fuel taxation laws for interstate motor 
vehicles), states are implementing PRISM at a satisfactory pace. IRP 
began in 1973, while the International Fuel Tax Agreement began in 
1983. Neither program had participation among all 48 contiguous states 
until the Intermodal Surface Transportation Efficiency Act of 1991 
encouraged state participation.[Footnote 21] 

Figure 2: Time Taken for States to Reach Ability to Deny, Suspend, or 
Revoke Vehicle Registrations: 

[Refer to PDF for image: vertical bar graph] 

Time taken: Less than 1 year; 
Number of states: 1. 

Time taken: 1 year to less than 2 years; 
Number of states: 3. 

Time taken: 2 years to less than 3 years; 
Number of states: 7. 

Time taken: 3 years to less than 4 years; 
Number of states: 4; 

Time taken: 4 years to less than 5 years; 
Number of states: 4. 

Time taken: 5 years or more; 
Number of states: 4. 

Source: GAO presentation of FMCSA data. 

Note: Iowa and Minnesota also have the ability to deny, suspend, or 
revoke registrations. These states were part of the pilot of PRISM and 
had this ability while in the pilot stage. Therefore, their data are 
not included in this figure. 

[End of figure] 

State officials we met with identified several factors that affected 
the time states needed to fully implement PRISM. Officials in all 13 
states we met with that are denying, suspending, and revoking vehicle 
registrations identified one or more of the following three key factors 
that facilitated implementation: 

* Hiring a contractor to implement technical aspects of PRISM, rather 
than implementing PRISM with current state staff. Ten states hired a 
contractor to implement technical aspects of PRISM. State officials 
told us that an experienced contractor often provides states with the 
expertise to properly implement PRISM's technical components in a 
timely manner. Officials from one state told us that hiring a 
contractor that had been used by other states to implement technical 
aspects of PRISM made implementation easy. 

* Having one agency responsible for motor carrier issues. Officials 
from five states told us that having one agency responsible for issuing 
motor carrier registrations and providing motor-carrier safety 
oversight helped facilitate implementation. Officials from one of those 
states told us that three separate motor vehicle agencies 
(registration, enforcement, and oversight) came together into a single 
motor carrier services division, which made PRISM implementation much 
easier. Prior to that time, agreeing on an agenda and coordinating 
between the agencies was difficult. 

* Sufficient financial support to fully implement the program. Each 
year, FMCSA allocates $4 million to various states to implement PRISM. 
Some states receive more grant funds or a second grant allocation. 
Officials from 11 states told us that these PRISM grant allocations 
were sufficient; 6 of these 11 states received a second grant. 

Officials from the 26 states we contacted identified one or more of the 
following three key factors that prevented or delayed PRISM 
implementation: 

* Overhauling outdated commercial vehicle registration systems that 
have difficulty incorporating technical aspects of PRISM. Officials in 
nine states cited having outdated state IRP registration systems that 
needed significant updating to incorporate PRISM functions. One state 
was implementing a new, updated IRP system. According to officials from 
that state, the cost of the new system was approximately $11 million. 
FMCSA officials told us that they were aware that the state had to 
improve its technical connectivity because its system was insufficient 
to support PRISM. 

* Competing priorities within state motor vehicle registration 
administrations. Officials from eight states told us that competing 
priorities within state motor vehicle administrations delayed or 
hampered PRISM implementation. State motor vehicle administrations 
typically have multiple responsibilities (such as licensing drivers and 
registering passenger vehicles), and the registration of commercial 
vehicles may only be a small part of these responsibilities. Officials 
in one state told us that they prioritize programs that deal with 
licensing drivers and registering passenger vehicles due to those 
registration volume demands. Also, officials from four states said that 
they were working on other commercial vehicle safety efforts, such as 
the commercial vehicle information exchange window system, and unable 
to move forward with PRISM implementation.[Footnote 22] Furthermore, 
PRISM may conflict with a state motor vehicle administration's focus on 
timely and efficient customer service. State motor vehicle 
administrations often focus on processing registration applicants as 
quickly as possible. PRISM may impose some time-consuming requirements, 
depending on the state's registration system capabilities. For example, 
two states have to manually check an applicant's safety status and work 
with the carrier to update carrier information (also required by 
PRISM),[Footnote 23] which can slow down the registration process. 

* Inability to or difficulty in passing enabling legislation needed to 
deny, suspend, or revoke commercial vehicle registrations based on a 
federal out-of-service order. Officials from five states told us that 
their states do not have PRISM-enabling legislation to revoke, deny, or 
suspend registrations of out-of-service carriers. States need the legal 
authority to impose vehicle registration sanctions against motor 
carriers that FMCSA has prohibited from operating. State trucking 
associations, however, may stall or block such enabling legislation. 
For example, officials from one state told us that in trying to pass 
legislation, the state trucking association was initially concerned 
about the timeliness for carriers to get vehicle registrations 
reinstated once the out-of-service order is rescinded. Once the 
association understood that timeliness would not be an issue, it 
supported PRISM. 

FMCSA Is Limited in Accelerating National PRISM Implementation: 

FMCSA has worked to address some of the factors states cited that delay 
or prevent PRISM implementation, but is limited in its ability to speed 
national implementation. Due largely to its voluntary nature, FMCSA is 
limited in its ability to compel states to pass PRISM-enabling 
legislation, prioritize PRISM implementation, or overhaul outdated 
commercial vehicle registration systems. However, FMCSA has taken some 
action to address these factors. First, FMCSA has drafted model PRISM- 
enabling legislation that is available on its Web site. State 
legislatures, however, may meet infrequently and may not value PRISM- 
enabling legislation as an important agenda item, thereby delaying the 
passage of needed legal authority to deny, suspend, or revoke the 
registration of out-of-service motor carriers. Second, FMCSA holds a 2- 
day training session with states to identify and begin to work through 
the issues related to implementing PRISM, and develops an 
implementation plan that presents step-by-step procedures to implement 
PRISM. FMCSA cannot, however, compel states to move quickly on taking 
those steps. Finally, FMCSA works with older state registration systems 
(referred to as legacy systems) to facilitate connectivity to FMCSA 
databases, and FMCSA staff provide technical assistance to help states 
identify and address technical barriers to establishing connectivity. 
FMCSA officials, however, told us that PRISM grants cannot fund a 
multimillion dollar overhaul of the state's legacy system just to 
establish PRISM connectivity, since PRISM connectivity is a relatively 
minor aspect of such a registration system. 

States we contacted that do not have the ability to deny, suspend, or 
revoke vehicle registrations had differing views regarding actions that 
FMCSA could have taken to help them implement PRISM more quickly. 
Officials in three of the nine states that have been implementing PRISM 
for 5 years or more without the ability to deny, suspend, or revoke 
vehicle registrations of out-of-service carriers did not identify 
actions that FMCSA could have taken to encourage them to implement 
PRISM more quickly.[Footnote 24] Most state officials we contacted in 
states not fully implementing PRISM told us that FMCSA consistently 
offered to provide whatever support it could to help the state move 
forward with implementation, although as previously mentioned, FMCSA 
was often limited in its ability to influence certain factors. 
Officials in two states, however, told us that FMCSA officials could 
have contacted them more often or otherwise put more pressure on them 
to raise PRISM's priority to ensure their state's participation in 
PRISM. In addition, states that have fully implemented PRISM were 
generally satisfied with FMCSA's actions to assist them in continuing 
to operate PRISM. 

Requiring Full PRISM Implementation Would Accelerate National 
Implementation, but Faces Significant Drawbacks: 

We conducted a general search of public policy literature for when a 
mandatory or voluntary approach is preferred for program participation 
and to achieve certain desired outcomes. Our review indicates that 
requiring states to fully implement PRISM--thereby enabling them to 
deny, suspend, or revoke the commercial vehicle registration of 
carriers that FMCSA has ordered out of service (the desired outcome)-- 
may be a quicker approach toward achieving national PRISM 
implementation than the current voluntary approach. PRISM 
implementation and the program's desired safety outcome are consistent 
with conditions indicating that a mandatory, rather than voluntary, 
approach would work best. (See table 1.) 

Table 1: Applicability of Mandatory and Voluntary Approaches to 
Implementing PRISM: 

Approach: Mandatory approach; 
Condition of success: Desired outcome cannot be achieved through 
voluntary efforts; 
Applicability of approach to implementing PRISM: Uncertain; After 10 
years, 25 states and the District of Columbia still do not deny, 
suspend, or revoke the commercial vehicle registration of carriers that 
FMCSA has ordered out of service. While all states may eventually have 
this desired outcome, a mandatory approach that includes timelines 
would achieve the desired outcome more quickly. 

Approach: Mandatory approach; 
Condition of success: Uniform application of a desired outcome is 
sought; 
Applicability of approach to implementing PRISM: Yes. After 10 years, 
25 states and the District of Columbia still do not deny, suspend, or 
revoke the commercial vehicle registration of carriers that FMCSA has 
ordered out of service. While all states may eventually have this 
desired outcome, a mandatory approach that includes timelines would 
achieve the desired outcome more quickly. 

Approach: Mandatory approach; 
Condition of success: Regulating agency seeks assurance that its 
compliance policies will be followed and establishes accountability; 
Applicability of approach to implementing PRISM: Yes; Some out-of-
service carriers continue operating, thereby increasing the public's 
safety risk. Having all states denying, suspending, or revoking the 
registration of these carriers better provides FMCSA with the assurance 
and accountability that unsafe carriers are not operating. 

Approach: Voluntary approach; 
Condition of success: Safety risks can be easily identified; 
Applicability of approach to implementing PRISM: No; Out-of-service 
carriers are not easy to identify, particularly chameleon carriers that 
change their identities. 

Approach: Voluntary approach; 
Condition of success: Regulator has a strong sense of duty to achieve a 
desired outcome; Applicability of approach to implementing PRISM: No; 
Denying, suspending, or revoking the registration of out-of-service 
carriers is generally not the principal concern of state motor vehicle 
administrations. 

Approach: Voluntary approach; 
Condition of success: Regulator faces a tight budget and increasing 
pressure to find cost-effective tools; 
Applicability of approach to implementing PRISM: Yes; Federal costs 
would almost certainly increase if the remaining 25 states and the 
District of Columbia were to fully implement PRISM over the short term. 
Thus, voluntary approaches may enable cost savings for FMCSA over 
mandates. In addition, states are facing tight budgets in this 
recessionary period. 

Source: GAO analysis of public policy literature on preferable 
attributes of mandatory and voluntary approaches. 

[End of table] 

Stakeholders we met with differed on whether Congress should enact 
legislation that would require states to fully implement PRISM. 
According to officials in 12 states and representatives from safety 
associations we interviewed, Congress should require all states to 
fully implement PRISM. These officials and representatives suggested 
that all states should be required to implement PRISM to ensure 
nationwide coverage so that no state becomes a "dumping ground" for 
unsafe or chameleon carriers. In addition, requiring states to 
implement PRISM by a certain date could result in timely national 
implementation. Conversely, officials in 3 of the 26 states supported 
keeping PRISM a voluntary program.[Footnote 25] These officials noted 
that a mandate was unnecessary, since only 3 states have not committed 
to PRISM implementation. Furthermore, several state officials that are 
currently implementing PRISM told us that even though they did not 
implement PRISM quickly, the factors that prevented them from moving 
forward were eventually overcome. In addition, states are making 
progress in fully implementing PRISM. Since 2000, state participation 
and implementation of PRISM has increased steadily. (See figure 3.) For 
example, in 2000, 33 states and the District of Columbia were not 
participating in PRISM, and as of April 2009, only 3 states were not 
participating. FMCSA data also indicate progress toward increased PRISM 
participation. 

Figure 3: Progress in Implementing PRISM, 2000 through April 2009: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2000; 
States not participating in PRISM: 33; 
States implementing or committed to implementing PRISM: 15; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 2. 

Year: 2001; 
States not participating in PRISM: 29; 
States implementing or committed to implementing PRISM: 17; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 4. 

Year: 2002; 
States not participating in PRISM: 22; 
States implementing or committed to implementing PRISM: 22; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 6. 

Year: 2003; 
States not participating in PRISM: 21; 
States implementing or committed to implementing PRISM: 18; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 11. 

Year: 2004; 
States not participating in PRISM: 13; 
States implementing or committed to implementing PRISM: 21; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 16. 

Year: 2005; 
States not participating in PRISM: 8; 
States implementing or committed to implementing PRISM: 23; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 19. 

Year: 2006; 
States not participating in PRISM: 5; 
States implementing or committed to implementing PRISM: 24; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 21. 

Year: 2007; 
States not participating in PRISM: 5; 
States implementing or committed to implementing PRISM: 23; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 22. 

Year: 2008; 
States not participating in PRISM: 4; 
States implementing or committed to implementing PRISM: 21; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 25. 

Year: April, 2009; 
States not participating in PRISM: 3; 
States implementing or committed to implementing PRISM: 22; 
States denying, suspending, or revoking vehicle registrations based on 
federal out-of-service order: 25. 

Source: GAO presentation of FMCSA data. 

Note: This figure does not include the District of Columbia, which 
began its participation in 2008 when it committed to implementing 
PRISM. Its status remains unchanged as of April 2009. 

[End of figure] 

While our review of public policy literature indicated that requiring 
states to fully implement PRISM may be a quicker approach toward 
achieving national PRISM implementation than the current voluntary 
approach, requiring states to implement PRISM within a certain time 
frame faces significant potential drawbacks and barriers--both 
technical and legal. First, such a requirement will likely cause PRISM 
implementation to move toward the top of a state motor vehicle 
registration administration's priority. PRISM implementation, however, 
may not be the most important activity for a state motor vehicle 
administration and may inhibit the administration's ability to complete 
other responsibilities, such as processing driver's licenses. Second, 
some states with significant barriers to PRISM implementation may need 
to obtain substantial funds in order to comply with a PRISM 
requirement. States with legacy registration systems that do not allow 
connectivity to FMCSA safety databases, for example, may need 
substantially more funds to enable them to fully implement PRISM than 
PRISM grants generally can provide. This could be problematic in 
today's recessionary climate. PRISM grants are intended to fund the 
costs of creating technology interfaces between the states' systems and 
FMCSA databases and not to fund complete registration system overhauls, 
which could cost millions of dollars. In addition to these technical 
issues, Congress may not have the legal authority to require states to 
implement PRISM. Congress can impose nationwide requirements pursuant 
to authorities specified in the Constitution. Under the Tenth 
Amendment, however, Congress cannot require states to enact laws or 
regulations that would compel a state to enforce a federal regulatory 
program.[Footnote 26] 

While Congress is limited in its ability to require state adoption of 
PRISM, it has three options that may enable it to strongly encourage 
state participation. First, Congress can attach conditions upon the 
receipt of federal funds. For example, as it has done in the past, 
Congress could require that states will lose a certain percentage of 
highway construction funds if they fail to fully implement PRISM within 
a given time. In DOT's 2001 appropriations act,[Footnote 27] Congress 
provided the National Highway Traffic Safety Administration with the 
ability to encourage states to adopt stricter standards for making it 
illegal for people to drive with a specified blood alcohol 
concentration (BAC) of .08 percent.[Footnote 28] Under this provision, 
later codified, states that did not adopt a conforming .08 percent BAC 
law by October 1, 2003, would have a percentage of highway construction 
funds withheld each year.[Footnote 29] Consequently, by July 2004, the 
legislatures in all 50 states and the District of Columbia passed laws 
defining it as a crime to drive with a BAC at or above .08 percent, 
whereas in 1999, only 16 states had enacted such a law. If this 
approach was applied to PRISM, a state motor vehicle administration 
that chooses not to implement PRISM would trigger a reduction in that 
state's transportation department's highway construction funds. As a 
result, Congress may be withholding funds from a state agency that is 
not responsible for implementing PRISM. But, such a scenario is similar 
to states adopting .08 percent BAC laws. 

A second option available to Congress is to provide financial 
incentives to states that speed PRISM implementation. Congress can 
provide an incentive payment, such as a one-time payment for 
implementing PRISM within a predetermined number of years. Furthermore, 
Congress can require states that do not stay in the program for a 
predetermined period to return the payment to ensure states stay 
committed to full PRISM implementation. States, however, may find that 
financial incentives such as payments are insufficient to overcome the 
factors that prevent or delay them from fully implementing PRISM-- 
particularly in states that need expensive overhauls of outdated 
registration systems. Furthermore, as more states move forward with 
PRISM implementation, Congress may end up allocating a substantial 
amount of financial incentives to states that eventually would have 
fully implemented PRISM without such an enticement. In addition, 
according to FMCSA officials, states that have already implemented 
PRISM may find this option unfair. 

Finally, Congress can strongly encourage state participation by 
developing associated mandatory elements. As discussed earlier, 
Congress, through the Intermodal Surface Transportation Efficiency Act 
of 1991,[Footnote 30] developed mandatory elements of enforcement, 
regulation, and reporting that strongly encouraged states to 
participate in IRP and the International Fuel Tax Agreement. With the 
IRP, the act stated that after September 1996, a nonparticipating state 
could not establish or enforce its own motor vehicle registration laws 
and regulations on vehicles that have IRP registrations from other 
states.[Footnote 31] With the International Fuel Tax Agreement, the act 
stated that after September 1996, a state can establish or enforce a 
law or regulation that has a fuel tax reporting requirement or provides 
for the payment of fuel tax only if it does so in a way that meets the 
requirements of the International Fuel Tax Agreement.[Footnote 32] In 
applying a similar approach to PRISM, Congress could condition states' 
ability to issue IRP registrations on using PRISM functions to check or 
deny a carrier's operating status prior to issuing such registrations. 
Such strong encouragement to impose PRISM, however, may cause problems 
for states that do not have the money needed to overhaul an outdated 
registration system to enable PRISM functionality. 

Similar to IRP and the International Fuel Tax Agreement, Congress can 
look to the National Driver Registry (NDR) as a comparison of a 
voluntary roadway safety initiative that achieved significant state 
participation following strong federal encouragement. The National 
Highway Traffic Safety Administration administers the NDR database 
system, which is similar to PRISM in its purpose and framework. Similar 
to PRISM, states are not required to participate in the NDR. The NDR 
facilitates the exchange of driver information between participating 
states to ensure that commercial vehicle drivers who have had their 
licenses suspended or revoked or who have been convicted of serious 
traffic violations (for example, driving while impaired by alcohol or 
drugs) in one state do not receive a new or renewed license in another 
state. State motor vehicle administrations provide the NDR with the 
names of individuals who have lost driving privileges or who have been 
convicted of a serious traffic violation. When a person applies or 
reapplies for a driver's license, the state queries the system-- 
maintained by the American Association of Motor Vehicle Administrators-
-to see if that applicant is listed on the NDR. If a state has reported 
the applicant on the NDR as a problem driver, the state may deny the 
applicant's request for a license. 

According to a National Highway Traffic Safety Administration official, 
before 1986, the NDR was not fully effective since not all states were 
checking the NDR prior to issuing commercial driver's licenses. 
Congress, however, passed the Commercial Motor Vehicle Safety Act of 
1986,[Footnote 33] which required states to check the NDR prior to 
issuing new commercial driver's licenses in the state. Still, while all 
states checked the NDR when new licenses were issued, not all states 
were checking the system during renewals. Consequently, commercial 
vehicle drivers who were convicted of serious traffic violations in a 
state other than where they were licensed were still able to have their 
licenses renewed in their home states. Subsequently, Congress passed 
the Motor Carrier Safety Improvement Act of 1999,[Footnote 34] which 
required states to check the NDR for all new license issues and 
renewals.[Footnote 35] A National Highway Traffic Safety Administration 
official told us that, partly due to this requirement, state queries of 
the NDR went from 35 million per year in 2001 to over 100 million per 
year in 2008. 

Conclusions: 

As a relatively small program, FMCSA's PRISM grants appear to have 
great potential to improve highway safety by preventing motor carriers 
that FMCSA has ordered out of service from obtaining or maintaining 
valid vehicle registrations, thereby inhibiting their ability to 
operate unlawfully. Although 47 states and the District of Columbia are 
either committed to or already implementing PRISM, the program's impact 
is unknown because FMCSA has not adopted measures of program 
effectiveness. This makes some sense, since the program has not been 
fully implemented in 25 states and the District of Columbia. Until a 
sufficient number of states have the ability to prevent unsafe motor 
carriers from obtaining or maintaining vehicle registrations, 
attempting to measure the effectiveness of PRISM grants will not be 
particularly fruitful. FMCSA officials have suggested that a sufficient 
number of states might be 38 to 40 states. 

Finally, despite the potential safety advantages in having all states 
and the District of Columbia fully implement PRISM and a variety of 
options for doing so, we are not suggesting that Congress legislate 
such a requirement because of the drawbacks and challenges of doing so. 

Recommendation for Executive Action: 

In order to assess PRISM's effectiveness in keeping unsafe carriers off 
the road, we recommend that the Secretary of Transportation direct the 
Administrator of FMCSA to measure PRISM program effectiveness when the 
number of states that have the ability to deny, suspend, or revoke 
registrations to out-of-service carriers is sufficient to make such 
measurements meaningful. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Transportation 
for its review and comment. The department generally agreed with the 
recommendation. It also offered one technical comment, which we 
incorporated. 

We are sending copies of this report to congressional committees 
interested in motor carrier safety issues; the Secretary of 
Transportation; the Administrator of FMCSA; and the Director of the 
Office of Management and Budget. In addition, the report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-2834 or flemings@gao.gov. Contact points for 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Staff who made key contributions to this 
report are listed in appendix II. 

Signed by: 

Susan A. Fleming: 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To report on the extent to which the Performance Registration 
Information Systems Management (PRISM) grants program has effectively 
removed unsafe carriers from the roadway, we obtained Federal Motor 
Carrier Safety Administration (FMCSA) data on the number of motor 
carriers that had vehicle registrations denied, suspended, or revoked. 
These data are to be reported to FMCSA on a quarterly basis by states 
that have implemented PRISM to the point where they are denying, 
suspending, and revoking vehicle registrations of out-of-service 
carriers. We interviewed officials from FMCSA to discuss how data are 
collected and verified and how the data are used to assess PRISM's 
effectiveness. We also conducted semistructured interviews with a 
nongeneralizable sample of state motor vehicle administration officials 
and state law enforcement officials from 13 states that deny, suspend, 
or revoke vehicle registrations to discuss their state's experience 
implementing PRISM, how effective the program has been, and the 
soundness and conclusiveness of reported data. We selected the 13 
states based on their progress implementing PRISM and their status as 
states with the largest numbers of commercial vehicles registered 
through the International Registration Plan (IRP).[Footnote 36] We 
selected states with the most vehicles registered, assuming that the 
proportion of out-of-service vehicles are distributed relatively evenly 
across states. State data on out-of-service vehicles are incomplete, 
and we did not test this assumption. 

In determining the reliability of FMCSA's data on the number of motor 
carriers that had vehicle registrations denied, suspended, or revoked 
because of an out-of-service order, we interviewed officials from FMCSA 
who are knowledgeable about the data and how the data are collected and 
analyzed. We also attempted to obtain similar information from states 
that are fully implementing PRISM. We identified shortcomings with 
these data, which we disclosed in this report, but found the data 
sufficiently reliable for our purpose, which was to provide a general 
sense of the extent to which PRISM implementation has resulted in 
vehicle registration sanctions. 

We met with state officials and representatives from motor carrier 
industry and safety associations and obtained their views on the extent 
to which PRISM has improved highway safety or had other benefits. (See 
table 2 at the end of this appendix for a list of industry and safety 
associations we interviewed.) We reviewed a 2007 Volpe National 
Transportation Systems Center evaluation of the PRISM program that 
reported on the extent to which PRISM has improved roadway safety and 
the limitations to FMCSA's data on the denial of commercial vehicle 
registrations to motor carriers FMCSA placed out of service. Finally, 
we reviewed information from interviews and the 2007 Volpe report to 
identify and describe the factors that limit PRISM's effectiveness. 

To report on the potential to fully implement the program nationally, 
we met with officials from FMCSA, state motor vehicle administrations, 
and state law enforcement offices in 26 selected states, as well as 
representatives from industry and safety associations. We conducted 
semistructured interviews with state motor vehicle administrations from 
13 states that have fully implemented PRISM; 3 states that are 
implementing the grant program (that is, they are collecting vehicle 
identification numbers and the DOT numbers of the carriers associated 
with those vehicles and may be checking the safety status of the 
carrier at the time of registration) but do not yet have the capability 
to affect vehicle registrations; 8 states that have entered into an 
agreement with FMCSA to implement PRISM grants but have not yet moved 
forward substantially to implement the program; and 2 states that do 
not participate in PRISM at all. (See table 2 for a list of state 
agencies we interviewed.) We selected these states based on their 
progress implementing PRISM and their status as states with the largest 
numbers of commercial vehicles registered through the IRP in 2006, the 
latest year for which full data were available at the time we selected 
states to interview. We reviewed FMCSA data regarding the time states 
have taken to reach the ability to deny, suspend, or revoke vehicle 
registrations of out-of-service carriers, after signing a statement of 
intent to participate in the PRISM program. We analyzed testimonial 
evidence to identify factors that enabled states to deny, suspend, and 
revoke registrations and factors that have delayed or prevented other 
states from moving forward. We also analyzed the information to 
identify the factors FMCSA can affect and those it cannot. 

As part of our work on the potential to implement the program 
nationally, we conducted a general search of public policy literature 
for when a mandatory or voluntary approach is preferred for program 
participation and to achieve certain desired outcomes. Through our 
literature search, which covered materials dating from 1998 to 2008, we 
identified and analyzed five articles that listed conditions for when a 
mandatory or voluntary approach works best. The articles described when 
a mandatory or voluntary approach is preferable for implementing 
environmental, animal production and processing, and food safety 
regulations on private sector entities; we did not find literature that 
identified conditions for when a federal agency should administer a 
mandatory or voluntary approach on state governments to achieve a 
certain desired outcome. Furthermore, we identified similar, 
comparative programs that have mandatory elements. In addition, we 
identified and analyzed drawbacks to mandating state implementation of 
PRISM and potential options available to Congress for encouraging-- 
rather than mandating--state legislative or regulatory action that 
could speed nationwide PRISM implementation. Finally, we assessed 
FMCSA's oversight for those states that are denying, suspending, and 
revoking registrations by obtaining testimonial information on FMCSA's 
efforts to assist them in continuing to operate PRISM. 

Table 2: State Agencies and Industry and Safety Associations 
Interviewed: 

States denying, suspending, or revoking vehicle registrations of out- 
of-service carriers: 

Alabama Department of Revenue:
Alabama FMCSA Division Office:
Georgia Department of Revenue:
Georgia Department of Public Safety:
Idaho Transportation Department:
Iowa Department of Transportation:
Iowa FMCSA Division Office:
Minnesota Department of Public Safety:
Minnesota FMCSA Division Office:
Minnesota State Patrol, Commercial Vehicle Division:
Missouri Department of Transportation:
Nebraska Department of Motor Vehicles:
Nebraska State Patrol:
New Mexico Commercial Vehicle Bureau, Taxation and Revenue Department:
New Mexico Department of Public Safety:
New Mexico FMCSA Division Office:
North Carolina Department of Motor Vehicles:
North Carolina FMCSA Division Office:
North Carolina State Highway Patrol:
Ohio Department of Public Safety, Bureau of Motor Vehicles.:
Ohio Contractor, Affiliated Computer Services, Inc.
Ohio FMCSA Division Office:
Ohio State Highway Patrol:
Tennessee Department of Revenue:
Tennessee Department of Safety, Highway Patrol:
Utah Division of Motor Vehicles:
Utah Department of Public Safety, Highway Patrol:
Washington Department of Licensing:
Washington FMCSA Division Office:
Washington State Patrol. 

States that implement PRISM but do not yet have capability to sanction 
vehicle registrations: 

Indiana FMCSA Division Office:
Indiana Department of Revenue:
Indiana State Police:
Pennsylvania Department of Transportation:
Texas Department of Transportation. 

States committed to implementing PRISM: 

California Department of Motor Vehicles:
California Highway Patrol:
Florida Department of Highway Safety and Motor Vehicles:
Illinois Office of the Secretary of State:
Illinois FMCSA Division Office:
Massachusetts Registry of Motor Vehicles:
Mississippi State Tax Commission:
Oklahoma Corporation Commission, Transportation Division:
Virginia Department of Motor Vehicles:
Virginia State Police:
Wisconsin Department of Transportation. 

States not participating in PRISM: 

Maryland Motor Vehicle Administration:
Michigan Department of State. 

Industry associations: 

American Association of Motor Vehicle Administrators:
American Trucking Associations:
United Motorcoach Association. 

Safety associations: 

Advocates for Highway and Auto Safety:
Commercial Vehicle Safety Alliance:
Truck Safety Coalition. 

Source: GAO. 

[End of table] 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Susan A. Fleming, (202) 512-2834 or flemings@gao.gov. 

Staff Acknowledgments: 

In addition to the contact named above, James Ratzenberger (Assistant 
Director), Michelle Everett (Analyst-in-Charge), Samer Abbas, Brandon 
Haller, Delwen Jones, Hannah Laufe, Joshua Ormond, and made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] Commercial motor carriers operate large commercial trucks and 
buses. Large trucks are those with a gross vehicle weight greater than 
10,000 pounds. A bus is a motor vehicle that carries more than eight 
passengers (including the driver). Crashes involving motor carriers may 
result from errors by truck, bus, or passenger vehicle drivers; vehicle 
condition; and other factors. The fatality rate (deaths per 100 million 
miles traveled) for commercial motor vehicles has been fairly stable 
since 2002. 

[2] There are three other components of PRISM. First, PRISM may provide 
state law enforcement agencies with the funds to access systems to 
check the safety status of the carrier for which vehicles stopped at 
the roadside are operating, to ensure vehicles are not operating for 
carriers that have been ordered out of service--if this capability does 
not already exist. Second, PRISM includes the deployment of roadside 
technologies, such as wireless access to FMCSA databases and bar-code 
readers that read driver and vehicle information and automatically 
populate data fields in roadside reports to improve the efficiency and 
accuracy of data collection. Last, PRISM includes the Motor Carrier 
Safety Improvement Process, which is a data-driven process that uses 
current safety event information such as accidents, inspections, driver 
violations, compliance review data, and other information, to assess 
and monitor motor carrier safety performance. This report deals with 
the commercial vehicle registration aspects of PRISM and not these 
three other components. 

[3] According to FMCSA officials, in addition to the 25 states, 4 
states suspend and revoke vehicle registrations for of out-of-service 
carriers; however, they do so on a case-by-case basis when requested by 
FMCSA and do not have the capability to check the safety status at the 
time vehicle registration renewals are requested in order to deny 
registrations. These 4 states do not report any suspension or 
revocation information to FMCSA. Additionally, there are 2 other states 
that also deny, suspend, and revoke vehicle registrations of out-of- 
service carriers, but these states do so when requested by FMCSA, not 
through the regular structure of the PRISM program. As such, we did not 
include these 6 states in our count. 

[4] John A. Volpe National Transportation Systems Center, Motor Carrier 
Safety Division for FMCSA Strategic Planning and Program Evaluation 
Division, Performance & Registration Information Systems Management, 
Program Evaluation Final Report (August 2007). 

[5] Safety audits and compliance reviews also provide education and 
outreach opportunities for motor carriers and drivers on safety and 
hazardous materials regulations. 

[6] FMCSA is developing a new initiative--Comprehensive Safety Analysis 
2010--to extend its reach. See GAO, Motor Carrier Safety: The Federal 
Motor Carrier Safety Administration Has Developed a Reasonable 
Framework for Managing and Testing Its Comprehensive Safety Analysis 
2010 Initiative, [hyperlink, http://www.gao.gov/products/GAO-08-242R] 
(Washington, D.C.: Dec. 20, 2007) and FMCSA's Web site at [hyperlink, 
http://www.fmcsa.dot.gov/safety-security/csa2010/home.htm]. 

[7] The Commercial Vehicle Safety Alliance is an international not-for- 
profit organization comprised of local, state, provincial, territorial, 
and federal motor carrier safety officials and industry representatives 
from the United States, Canada, and Mexico that establishes minimum 
inspection and vehicle out-of-service criteria for highway enforcement 
officials. 

[8] The DOT number serves as a unique identifier when collecting and 
monitoring a carrier's safety information acquired during audits, 
compliance reviews, crash investigations, and inspections. Companies 
that operate commercial vehicles transporting passengers or hauling 
cargo in interstate commerce must be registered with the FMCSA and must 
have a DOT number. Also, commercial intrastate hazardous materials 
carriers that haul cargo requiring a safety permit must have a DOT 
number. 

[9] IRP is used to register commercial motor vehicles with a gross 
vehicle weight of over 26,000 pounds that travel between two or more 
states or Canadian provinces to ensure an equitable distribution of 
registration fees, which is based on vehicle miles traveled in each 
state or Canadian province. All states (except Alaska and Hawaii) are 
members of IRP. 

[10] Pub. L. No. 109-59, 119 Stat. 1144 (2005). 

[11] Grants have ranged from $180,700 to $750,000. FMCSA determines the 
grant amount based on a variety of factors, such as whether the state 
uses a contractor for the IRP program or uses in-house support, the 
level of current technology in the state, and the level of 
communication for law enforcement. Also, some states receive a second 
grant allocation. PRISM grants are reimbursable--that is, states incur 
costs, and ask FMCSA to reimburse them with grant funds for eligible 
expenditures. 

[12] FMCSA compiles state-reported data on a quarterly basis. Beginning 
in March 2006, FMCSA added fields for states to report the number of 
denials, suspensions, and revocations. Prior to 2006, FMCSA officials 
told us that they would call the limited number of PRISM states that 
had implemented the denial, suspension, and revocation requirement to 
gather the data. For 2008 data, at least 10 of the 25 states that 
provided reports to FMCSA each quarter did not report data on denials, 
suspensions, and revocations. FMCSA officials told us that they assume 
that these states did not deny, suspend, or revoke any registrations 
during that quarter. Officials do not follow up with states to 
determine if this is the case or if the state had mistakenly not 
reported data. As a result, data could be underreported. 

[13] It is possible that carriers that were denied vehicle 
registrations had their registrations suspended or revoked in the same 
year. An FMCSA official, however, told us that this is unlikely since 
suspensions and revocations occur during the registration year and 
denials occur the following year--when a carrier attempts to register 
new vehicles or reregister vehicles. 

[14] John A. Volpe National Transportation Systems Center, Motor 
Carrier Safety Division for FMCSA Strategic Planning and Program 
Evaluation Division, Performance & Registration Information Systems 
Management, Program Evaluation Final Report (August 2007). 

[15] The Volpe report also compared driver and vehicle out-of-service 
violation rates in PRISM to evaluate the effectiveness of one of 
PRISM's other components--the Motor Carrier Safety Improvement Process, 
which helps to target high safety-risk carriers for roadside 
inspections to improve their safety status. The analysis did not show a 
conclusive relationship between these violation rates and PRISM. 

[16] The number of carrier suspensions and revocations should be 
relatively consistent with the number of carriers being ordered out of 
service in a given year. 

[17] Registrant-only entities register commercial motor vehicles but do 
not operate as motor carriers under any circumstances; these entities 
are usually comprised of leasing companies that do not have operating 
authority and are not identified as the carrier responsible for safety 
for IRP registration. Consequently, motor carriers that use the 
registrant-only number may escape FMCSA oversight. 

[18] Charter buses provide service to groups traveling together to a 
specified location or for a particular itinerary. 

[19] Nathan Associates, Motorcoach Census 2008: A Benchmarking Study of 
the Size and Activity of the Motorcoach Industry in the United States 
and Canada in 2007 (Dec. 18, 2008). 

[20] Officials in this state also said that in many cases, when the out-
of-service DOT number is identified, it is usually an owner-operator 
trying to register their vehicle under a different carrier that is not 
out of service. Owner-operators own their own vehicles and may act as a 
driver for another employer at certain times or may be self-employed at 
other times. 

[21] With IRP, the Intermodal Surface Transportation Efficiency Act of 
1991 stated that after September 30, 1996, a nonparticipating state 
could not establish or enforce its own motor vehicle registration laws 
and regulations on vehicles that are in the state but are registered in 
participating states. With the International Fuel Tax Agreement, the 
act stated that after September 30, 1996, a state may establish, 
maintain, or enforce a law or regulation that has a fuel use tax 
reporting requirement (including any tax reporting form) only if the 
requirement conforms with the International Fuel Tax Agreement. 

[22] The commercial vehicle information exchange window system consists 
of a comprehensive database of motor carrier safety and credential 
information, along with software that ensures the smooth flow of these 
data to and from other federal and state motor carrier, vehicle, and 
driver safety information systems. The system interfaces with a state's 
existing information systems and exchanges data with federal safety 
databases. 

[23] PRISM also requires carriers to update an FMCSA carrier form (the 
MCS-150), which details company information such as how many vehicles a 
carrier operates. In PRISM states, carriers are required to update this 
information annually, as opposed to once every 2 years. 

[24] We interviewed four of the nine states that have been implementing 
PRISM for 5 years or more but do not yet have the ability to deny, 
suspend, or revoke vehicle registrations. 

[25] Officials from the remaining 11 states did not or preferred not to 
provide an opinion on requiring PRISM implementation. Representatives 
from industry associations we met with told us they did not support a 
mandate for various reasons. Those representatives said that states 
lack the necessary resources to comply with such a mandate and that 
there is no need for such a mandate, since roadside law enforcement has 
the ability to identify and sanction any carrier operating after FMCSA 
has placed the carrier out of service. 

[26] The amendment states that "the powers not delegated to the United 
States by the Constitution, nor prohibited by it to the States, are 
reserved to the States respectively, or to the people." See, for 
example, Printz v. United States, 521 U.S. 898 (1997); City of New York 
v. United States, 505 U.S. 144 (1992). 

[27] Pub. L. No. 106-346, 114 Stat. 1356 (2000). 

[28] A .08 percent BAC is the level at which a person's blood contains 
8/100ths of 1 percent alcohol. 

[29] Specifically, states that did not adopt a conforming .08 percent 
BAC law by October 1, 2003, would have 2 percent of certain highway 
construction funds withheld. The statute added that each year, the 
withholding percentage would increase by 2 percent, up to 8 percent in 
fiscal year 2007 and later. Those states that adopted a conforming .08 
percent BAC law within 4 years of any withholding would be reimbursed 
for those withheld funds. If a state had not adopted a conforming .08 
percent BAC law by October 1, 2007, portions of the state's withheld 
funds would begin to lapse and would no longer be available. 23 U.S.C. 
§ 163(e). 

[30] Pub. L. No. 102-240, 105 Stat. 1914 (1991). 

[31] 49 U.S.C. § 31704. 

[32] 49 U.S.C. § 31705 (a), (b). 

[33] Pub. L. No. 99-570, title XII, § 12009(a)(20), 100 Stat. 3207 
(1986). 

[34] Pub. L. No. 106-159, 113 Stat. 1748 (1999). 

[35] 49 U.S.C. § 30304(e). 

[36] In two cases, we met with officials from states in the early 
stages of our engagement, before we finalized our methodology. In 
another case, we met with a state that was not fully implementing PRISM 
at that time, but subsequently obtained full implementation status. 

[End of section] 

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