Timing is the most important part of applying for your first FMCSA Certificate of Public Convenience and Necessity. The Application process is quick, especially if you file online, since you get an MC Number and a USDOT Number immediately. However, you are then required to file your proof of insurance within 20 days. If not, a Decision is issued granting you an additional 60 days within which to comply or have your Application dismissed. As stated in the preceding article on the new “vetting” procedure, this may take 4-6 weeks to gain approval. All the while you are paying for insurance and the financing on the new bus, but unable to operate same. Here is what I suggest. About 60 days prior to the date upon which you wish to operate, file the Application with the FMCSA and USDOT, arrange for the bus to be held for you for 60 days, arrange for insurance to be filed 40 days after your Application is submitted, and hopefully, everything will coincide at the 60 day mark, i.e. your Certificate is received, and the bus is ready to be picked up for inspection by your State DOT.
Jerry A. Casser, Esq. (Fairfield NJ Transportation attorney) www.jcasser.com