Advocacy
Advocacy
We represent members on regulation that affects how they operate. This page describes how a position is arrived at, what we deliberately do not do, and what either means for the deductibility of your dues.
What we do
Federal agencies that regulate this industry publish proposed rules and take public comment before finalising them. Anyone may comment. In practice a nine-truck carrier does not have the time to read a rulemaking docket, and a comment that speaks for many carriers carries more weight than one that speaks for a single company.
That is the work: reading what is proposed, asking members what it would actually cost them to comply, and filing a comment that says so. It is unglamorous and it is public — every filing goes into a docket anyone can read.
What we do not do
- We are not registered lobbyists
- Submitting comment into a public rulemaking docket is not lobbying and requires no registration. We employ no registered lobbyists and retain no lobbying firm. If that changes, the registration will be public and this page will say so before it does.
- We operate no political action committee
- No PAC, no candidate contributions, no solicitation of members for political giving. The software has the capability behind a flag that is switched off, and turning it on is a board decision with its own disclosure obligations — not a configuration change.
- We do not coordinate what members charge
- Taking a joint position on a proposed rule is lawful and is most of what a trade association is for. Using the same room to align prices, allocate customers, or agree on terms is not, and the distinction does not soften because everyone in the room agrees the rule is bad. The antitrust policy sets out what that means in practice, including which conversations get stopped.
How a position is adopted
A member is entitled to know how the association came to speak for them. The process is published so that answer does not depend on who they ask.
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A matter is raised
By a member, a committee, or staff monitoring the federal register. Anything raised is logged, including matters that go no further.
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Members are consulted
Consultation is on the regulatory question — what a rule would cost to comply with, whether it is workable for a small fleet. It is never on what members charge or plan to charge.
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The board adopts or declines
A position is the board’s to take, not staff’s. The vote and its margin are recorded, and a member can see how the position they are represented by was reached.
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The position is filed and published
Comment goes into the public docket under the association’s name. What we filed is published here, in full, including where we were unsuccessful.
A member who disagrees with an adopted position can say so on the record, and their dissent is minuted. An association whose members all appear to agree is usually one that stopped asking.
What this means for your dues
Dues paid to a business league are generally deductible as a business expense. Where an association spends part of its budget on lobbying, federal tax law requires it to tell members what share of their dues is not deductible, and members must exclude that share from what they claim.
No percentage is stated yet
That figure is determined annually by the association's accountant from actual expenditure, not estimated in advance. Ours has not been determined, so no number appears here or on any invoice.
When it is, it will be shown on your invoice and in your renewal notice for the tax year it applies to — not as a single site-wide figure, because the share changes year to year and a member needs the one that matches their receipt.
This is a description of how the disclosure works, not tax advice. What you may deduct depends on your own circumstances; ask your accountant.
Our record so far
There isn't one. No positions have been adopted and no comment has been filed. When that changes, filings will be published here in full — including the ones that did not work.
Associations tend to publish only their wins, which makes it impossible to judge whether the advocacy is effective or merely well-timed. We would rather be judged on the whole record from the start, while it is short enough to be honest about.
Raising something
Members can raise a regulatory matter through their account or the governance address. Tell us what the rule would cost you to comply with and how you know — a specific operational account from one carrier is more useful in a docket than a general objection from a hundred.