Who Reports as a Carrier?
Types of Carriers that are required to report to ExSTARS
Bulk Carriers and bulk transport carriers are required to file with ExSTARS. Bulk Carrier/bulk transport carriers are companies that operate a pipeline, barge, ship or other vessel to transport liquid product to or from an approved facility.
Carriers must report all liquids (including taxable fuel) delivered to and/ or removed from an approved facility by filing Form 720-CS. The party that exercises the control, direction and safety of the fuel transport is responsible for filing the Forms 720-CS returns.
In the case of vessels, the person, who the shipper / consignor contracts to arrange delivery of petroleum and renewable fuels products, is the reporting carrier.
A vessel is defined as a waterborne fuel transporting vessel. A vessel may include a tugboat pulling a barge of taxable fuel, or the barge itself, or both. Any person that operates a vessel within the bulk transfer/terminal system, excluding deep draft ocean-going vessels is considered a vessel operator. Vessel operators are required to register on Form 637 (Activity letter "X").
Reporting Deliveries and Receipts from Facilities Do Not Have FCNs
Receipt and delivery transactions occurring at facilities that do not have FCNs are not reportable at this time. For vessel operators, all receipts from approved facilities and deliveries to approved facilities are reportable. For pipeline operators, all receipts from approved terminals and all deliveries to approved terminals are reportable.
Companies that operate only transport trucks and rail cars are not bulk carriers. Truck and rail carriers are not required to report at this time.
Carrier Reporting Scenario
Company A and company B have barges. They both contract with company C to push their barges. C is the owner/operator of the tugboat and has no relationship with A or B.
Both Company A and B must file carrier reports showing the dates and TCNs reflecting when the fuel is delivered. Company C does not file. Company A and B have the information on destination and content and are the filers.