auth-interstate-vs-intrastate

Use this skill to determine whether you need interstate FMCSA authority or just intrastate state authority. Covers the federal/state divide.

SKILL.md

GitHub

Interstate vs Intrastate Authority — What Do You Need?

Interstate (federal) vs intrastate (state-only) authority is a fundamental distinction. Wrong choice = unauthorized operation + penalties.

What's interstate

Any operation that:

  • Crosses a state line, OR
  • Originates AND terminates in different states, OR
  • Crosses an international border (US-Mexico, US-Canada)

What's intrastate

Operation that:

  • Originates AND terminates in the same state
  • Doesn't cross state lines
  • Doesn't cross international borders

Special cases

  • Some intrastate operations may be subject to federal jurisdiction (interstate commerce regardless of state lines)
  • "For hire" vs "private" — different requirements
  • Hazmat operations — federal jurisdiction regardless of state

What you need for interstate

  • USDOT number
  • MC number (if for-hire transportation)
  • BMC-91 (insurance proof)
  • BOC-3 (process agents in each state)
  • IFTA + IRP if applicable

What you need for intrastate

  • State motor carrier registration
  • State insurance proof (varies)
  • State-issued license plate
  • USDOT number (only if vehicle weight/use exceeds federal threshold)

State motor carrier registration

  • Each state has its own registration process
  • Some states use IRP (apportioned plates)
  • Some states have separate intrastate registration
  • Insurance requirements vary state to state

How to determine

  1. List your operating routes
  2. Identify which cross state lines
  3. If ANY interstate operation → need federal authority
  4. If ALL operations intrastate → state authority only

Common confusion

  • "I deliver only in [state]" — but if you pick up loads from interstate carrier, you may be operating in interstate commerce
  • "I deliver locally" — but if you cross a state line (even briefly), interstate authority required

Penalties for wrong authority

  • Federal: $10,000+ per violation
  • State: varies, but typically $500-$5,000

Compass authority module

  • Tracks current authority level (federal or state)
  • Alerts if interstate operation occurs without federal authority
  • Manages USDOT/MC/IFTA/IRP renewal cycle

CFR citations

  • 49 CFR Part 365
  • State Motor Carrier Laws

How Compass surfaces this

Searchable in Compass Ask. Runs against carrier fleet data when invoked from the relevant tracker. Read-only; no actions without explicit user approval.


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This skill is published under the X3 Compass open skills initiative. Contributions welcome at https://github.com/x3fleetsafety/skills