Wednesday, January 9, 2019

Hey Fletch … We have been getting a lot of conflicting opinions about whether churches need to apply for a DOT number for the operation of church buses that require CDL drivers. My best understanding is that when you cross state lines and there is some sort of imbedded charge for transportation (part of the event cost perhaps), that we are required to have a DOT number, but then I saw a list of states that require it even within the state. 

Are churches exempt from this requirement though? It seems like it would increase our insurance requirements to $5 million and require a drug testing program. So it’s a big step that I don’t want to make needlessly.  

Thanks for your great advice & looking forward to the new Smart Money book!

DRF—Richard Hammer has a good article on the subject and says:

Note that a United States Department of Transportation (USDOT) number is required if you are an interstate PMCP regardless of business or non-business status. No fee is assessed to obtain a USDOT number. You must complete Form MCS-150 (Motor Carrier Identification Report) to obtain a USDOT number. The form can be found at Form MCS-150 can be completed online or you can print a copy of the form to complete and mail to the address indicated. If you do not have access to the Internet, you can call the Federal Motor Carrier Safety Administration’s toll-free number at 1-800-832-5660 to have the form mailed to you.

The Federal Motor Carrier Safety Administration has an article entitled, “Faith Based Organization-Related Transportation.” That article validates what you mentioned about insurance levels:

The required level of financial responsibility (insurance or other acceptable security) for for-hire, interstate passenger transportation is determined by the highest seating capacity of your vehicles. Vehicles with a seating capacity of 15 or fewer passengers (including the driver) require $1.5 million of coverage, and $5 million is required for vehicles with a seating capacity of 16 or more passengers (including the driver).

There are some exemptions noted in the article. However, you would want to talk to the FMCSA field office about whether your church fits those exemptions. 

• Call the FMCSA Information Line at 800-832-5660

• Contact your local FMCSA field office

If you are exempt, it would do well to get that data in print from FMCSA. Perhaps they would send you a confirmation letter with the regulations and how your church would be exempt. And remember, don’t drive 15 passenger vans for church travel—they can be unsafe.