Welcome back to the Regulatory Rundown!


Issue #2: The DOT Special

Buckle your seatbelt—it’s going to be a fast and bumpy trip with hopefully no road construction or detours. This month we will be merging onto the DOT highway with MCS-150 biennial reporting, Background Checks, and Heavy Vehicle Use Tax (Form 2290). Don’t worry, we’ve completed the pre-trip inspection and have done all the load securement—so you can just sit back and enjoy the ride.

• A significant number of at-fault CMV incidents happen at low speed—backing up, in parking lots, and on private property—rather than road driving. This is a reminder to Get Out And Look (G.O.A.L.)
• DOT numbers aren't just for BIG trucks—many pickups need one depending on weight and use.
• In 2025, more than 3.1 million roadside inspections were conducted on commercial motor vehicles. 56.3% resulted in at least one violation and nearly 20% resulted in an out-of-service violation.

Beware of MCS-150 Renewal Solicitations

From time to time, our cooperatives receive letters stating that our Biennial Update / MCS-150 filing is “Currently Due” or that immediate action is required to remain in compliance. (Click the image on the right to see an example.)

• Before responding or sending any payment, stop and verify who sent the letter.
• These notices are commonly solicitations from private DOT processing services and are not affiliated with the Federal Motor Carrier Safety Administration (FMCSA). The letters are designed to look official and may use urgent language intended to make the recipient believe that a payment is required to complete the filing.
• Completing the Biennial Update (MCS-150) is a free FMCSA service and can be completed online directly through the federal government.
• There is generally no reason to pay a third-party company simply to complete the MCS-150 filing for you.
• Do not assume the letter is from the federal government.
• If the notice is from a private “DOT Processing Service” or similar company, treat it as a solicitation, not a federal invoice.
• If you are unsure whether your filing is actually due, contact us before taking action.

Are you verifying that your non-CDL employees who drive company vehicles have a valid driver’s license? Are you doing this annually or just when hired?

You shouldn't have to find out about a driver's license problem because they were involved in an accident. Annual driver record inquiries help ensure employees who operate company vehicles remain legally qualified to drive and allow the company to identify suspensions, restrictions, serious violations, or other concerns before they become a bigger problem. Without an annual review, an employer may unknowingly put an unqualified driver behind the wheel, creating unnecessary exposure to accidents, liability, insurance issues, and questions about whether the company exercised reasonable due diligence. It's a simple check that can prevent a very expensive surprise.

Before checking a driving record (Motor Vehicle Record or MVR), federal law (Fair Credit Reporting Act / FCRA) requires the employer to get a written or electronic signature.

• This disclosure must be given to the employee as a standalone document.
• It cannot be buried inside a long employee handbook or mixed into the text of a regular job application.

Recently, we have been fielding several questions about this tax and whether there are any exemptions or ways to avoid completing and filing the IRS HVUT Form 2290. Depending on how you answer a couple of questions, the answer could possibly be yes.   

• HVUT is an annual federal highway use tax paid to the federal Internal Revenue Service (IRS) on vehicles operating on public highways at a gross weight of 55,000 lbs. and greater. https://wisconsindot.gov/Pages/dmv/vehicles/title-plates/fee-chart.aspx
• Many new tandem axle digger and bucket trucks are being registered from the manufacturer at 56,000 pounds—which is flagging a request to complete a Form 2290 Heavy Highway Vehicle Use Tax form. 
• Please reach out to the WECA compliance team if you have questions about reducing your registered weight of these vehicles.  

Important Note

Before changing the registered weight of any vehicle, it is the responsibility of the vehicle owner/operator to verify all applicable federal, state, and local laws, regulations, registration requirements, permit requirements, and weight restrictions. Increasing or decreasing a vehicle’s registered weight may affect more than registration fees and may impact legal load limits, axle and tire ratings, licensing requirements, operating authority, insurance, road restrictions, and other regulatory obligations.

Requirements can vary depending on the vehicle, its configuration, where it is operated, and the type of load being transported. Do not change a vehicle’s registered weight based solely on the information provided here. Always confirm the requirements with the appropriate state and federal agencies and ensure the vehicle remains within all applicable weight and equipment limitations before operating it at the new registered weight.

Upcoming PCB Seminar

Based on feedback from our last Warehouse Meeting, it is clear there is a genuine interest—and maybe a little healthy concern—about PCB requirements. We are hosting a PCB Workshop on Tuesday, October 13, from 10 a.m.–2 p.m. at Oakdale Electric Cooperative, with lunch provided by RESCO.

We’ll cover PCB regulations, EPA inspections, testing and disposal, labeling, storage requirements, and include a tour of the PCB storage area. Whether you’ve been managing transformers for 30 years or 30 minutes, this practical, hands-on workshop should have something valuable for everyone.

No virtual option will be available. If you haven’t already registered for this event, please reach out to Ben and let him know how many from your co-op will be attending.

Please don’t hesitate to reach out to either of our compliance team members with general questions, assistance, or sample documents and forms. 

Until next time, keep your paperwork current, your PPE inspected, your spill kits stocked, and your coffee away from the compliance files.