Do Kentucky Trip Permit Miles Count on Your IRP Mileage Report?
Table Of Contents
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Introduction
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The Short Answer
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What a Kentucky Trip Permit Is
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What Kentucky's IRP Rule Says About Mileage
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Which Reporting Period Counts
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When Trip Permit Miles Show Up in Your Fleet
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Records You Need to Keep
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What Happens in an Audit
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Common Mistakes to Avoid
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Why Many Trucking Companies Choose Our Service
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FAQ
Introduction
Many carriers run a few loads on a Kentucky Trip Permit before switching to apportioned plates. When it's time to file the IRP application, a common question comes up: do those trip permit miles belong on the mileage report, or can you leave them off?
Kentucky's IRP regulation answers this directly. This guide explains the rule, the reporting period, and the records you should keep so your IRP mileage holds up in an audit.
The Short Answer
Yes. Under 601 KAR 9:135, Section 3(1)(f), the fleet mileage on a Kentucky apportioned (IRP) application shall include miles operated under trip permits.
The same rule says your mileage must also include loaded and unloaded trips and intrastate and interstate trips. Trip permit miles are not a separate category you can skip.
What a Kentucky Trip Permit Is
Under KRS 281.838, a nonresident whose vehicle is not exempt from Kentucky registration fees under a reciprocal agreement can get a temporary permit in lieu of the fees in KRS 186.050. The permit:
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Is issued for a specific vehicle,
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Covers a specified period of no more than 10 days, and
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Comes in two classes by declared gross weight: 55,000 lbs or less and 55,001 lbs or more.
The IRP regulation ties the two together. 601 KAR 9:135, Section 2(1) says the operator of an apportionable vehicle running in more than one jurisdiction must apply for apportioned registration unless a trip permit has been purchased for each trip into the jurisdiction.
An apportionable vehicle is one with two axles and a gross weight over 26,000 lbs, three or more axles at any weight, or a combination over 26,000 lbs.
What Kentucky's IRP Rule Says About Mileage
Section 3(1) of the regulation sets out how fleet miles are reported on Schedule B (TC 95-303B):
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Report miles by jurisdiction. Miles in each jurisdiction must be reported whether or not it is an IRP member and whether the vehicle is empty or loaded.
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Include every type of trip. Loaded and unloaded, intrastate and interstate.
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Include trip permit miles. Miles run under trip permits are part of the total.
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Count added or removed trucks correctly. For a power unit added to or deleted from the fleet during the period, report only the miles it ran while it was part of the apportioned fleet.
Which Reporting Period Counts
Kentucky uses a fixed mileage year. Fleet miles are those traveled from July 1 through June 30 of the year immediately preceding the registration year.
If your registration year begins in July, August, or September, the reporting period is the previous 12 months.
So a Kentucky Trip Permit you used in the reporting period belongs in that period's mileage, along with the rest of the truck's miles.
When Trip Permit Miles Show Up in Your Fleet
Trip permit miles usually appear on an IRP mileage report in these situations:
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Switching to apportioned plates. You ran some trips on trip permits, then applied for IRP. Miles from those trips that fall in the reporting period are part of your actual distance.
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Entering a jurisdiction not on your cab card. An apportioned truck that runs into a jurisdiction it isn't registered for may use a trip permit for that trip. Those miles still count.
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Mixed operations. Fleets that run some units on trip permits and others on apportioned plates need clear records for each unit.
Leaving these miles off makes your jurisdiction percentages wrong, and those percentages decide how your apportioned fees are split.
Records You Need to Keep
601 KAR 9:135, Section 3(2) requires you to keep operational records for the current registration year and the three registration years before it.
The information goes in an individual vehicle mileage record that shows:
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Registrant's name and fleet number
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Beginning and ending date of each trip
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Trip origin and destination
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Route of travel
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Beginning and ending odometer or hubometer reading
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Total trip miles
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Miles by jurisdiction for each trip
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Vehicle unit number and VIN
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Driver's name or signature
Keep a copy of each Kentucky Trip Permit with the trip record, so the permit dates match the miles you report.
What Happens in an Audit
The Division of Road Fund Audits audits Kentucky-based apportioned registrants are given 30 days' written notice before an audit.
If you can't produce the Section 3 records when asked, the regulation allows a penalty under the IRP Audit Assistance manual or cancellation of your apportioned registration. If the audit finds fees due, you get a tax due statement and have 45 days to pay or file a written protest.
Missing trip permit miles are an easy finding for an auditor, because fuel receipts and logs show the truck was in a jurisdiction that the mileage report left out.
Common Mistakes to Avoid
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Leaving trip permit miles off Schedule B. The regulation requires them.
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Dropping empty miles. Unloaded trips count too.
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Using the wrong reporting period. Use July 1 to June 30 before the registration year.
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Reporting miles for a truck before it joined the fleet. Only count miles while it was part of the apportioned fleet.
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Throwing away old permits and trip sheets. Keep records for the current year and three prior years.
Why Many Trucking Companies Choose Our Service
Kentucky Trucking Online issues your Kentucky Trip Permit fast and sends you a clear copy for your trip records, so your IRP mileage is easy to back up later.
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IRP trip permit over 55,000 lbs: $95
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IRP trip permit under 55,000 lbs: $95
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KYU trip permit: $95
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IFTA (fuel) trip permit: $95
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KIT trip permit: $95
We provide support 24/7 and also work weekends and holidays.
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FAQ
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Do Kentucky Trip Permit miles count on an IRP mileage report?
Yes. 601 KAR 9:135 says fleet mileage shall include miles operated under trip permits.
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What reporting period does Kentucky use for IRP mileage?
July 1 through June 30 of the year before the registration year.
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Do empty miles count?
Yes. Mileage includes loaded and unloaded trips.
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How long do I keep mileage records?
For the current registration year and the three registration years before it.
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How long is a Kentucky Trip Permit valid?
Up to 10 days, for one specific vehicle.
For more information, visit the Kentucky Transportation Cabinet.