Was FMCSA's Motus site vibe coded?

Speaker 1:

The persistent technical and administrative glitches plaguing the FMCSA's modernized registration system MOTUS and what motor carriers are facing as a result. Hey everybody. Welcome back. I'm Jason Cannon and my co-host is Matt Colton. Four months after it's launched, the Federal Motor Carrier Safety Administration's new modernized registration system, MOTUS, continues to cause operational headaches for motor carriers across the country. It's turning routine administrative tasks and normal out of service periods into months long ordeals.

Speaker 2:

The core issues range from basic account linking failures and frozen verification screens to automated authority revocations driven by insurance policy updates that are effectively putting perfectly compliant carriers out of business.

Speaker 3:

I would say the biggest problems is going to be just issues with being able to link it in general, getting access to it, getting your account established. Two, I would say issues that are caused specifically by bugs in the FMCSA system that's causing changes on people's DOT numbers or authorities through no fault or action of their own. And number three would just be the consistently horrible support experience that people get and the power that the FMCSA is stripped away from basically anyone other than the customer service agents. So like FMCSA field officers, even state representatives that are licensed to do safety audits and so on, they no longer have access to the system on their side like they once did. So before field officers could, say if you were contacted for a safety audit and you say, "I don't have any interstate trips yet," they could help you switch to intrastate to remove you from the safety audit pool.

They no longer have that ability. If a carrier gets placed out of service and whether it's failure to contact or a failed safety audit or whatever, and they do the steps to get back in service and they're outside of their out of service period, if they can't get into MOTUS to reactivate the DOT number, then they're basically still just going to remain as out of service. And again, not even field offices or anyone other than the 1-800 customer support line at the FMCSA can actually help you. And even then, they're not really going to help you. They're just going to say, "Well, submit a ticket or we'll open a ticket for you and then you can reactivate the DOT number once you get access." But I mean, that's a month long process. So what should be a 30 day out of service period is turning into 90 day out of service period for a lot of carriers that we talk to.

So as far as the main issues that we see, and I mean there's lots of little kind of tangentially related ones here, but the core ones is when you first sign into MOTUS, it says the application is no longer active, which is confusing for people and ends up making people file for new DOT numbers is something we see happen a lot. That one has kind of died down. We're seeing less of that issue now, but it still pops up. The button to link the DOT number being grayed out is still by far the thing that we get called about the most and the issue that we help people through the most. Obviously DOT number and authority being placed is inactive for genuinely no reason.

One of the other things, once they actually can get signed in and they do the ID verification, their email address on that field, it has you confirm your user information, the email address is blank, won't let you edit it and it won't let you continue without the email, which doesn't make a lot of sense considering you've already had to log in with an email to even get to that screen. Obviously the most recent one is the insurance requirements being raised to five million and authority is getting revoked because of that. Something we've seen a lot is if you had a policy that was say set to cancel on September 16th and you had another policy, so say you went from a 750 policy to a million, your insurance company will post it. So one is canceled on the same day that the other one goes effective.

That was never an issue before MOTUS, but now it's saying that or people are getting revoked because it says no required insurance on file even though there was clearly no lapse of coverage according to the FMCSA's own records in MOTUS. Buggy document authorization. So FMCSA now requires for new DOT numbers and even for changes to an existing one, they require you to upload supporting documents. Address verification is probably the buggiest one that we've seen. Even once you're able to get in and you have all your stuff configured, sometimes just trying to update something simple like an address or numbers to drivers and vehicles, it will just sit there as pending or you'll see this rap sheet of all of these canceled changes even though you only submitted one and it's really unclear where those are coming from. One thing that we ran across today, and I can even send you the communication that we have with the FMCSA on it, where we're trying to get assistance with this person's account and they're saying that they just can't find the email anywhere in the system, even though again, this is the login.gov email that was used to set up the DOT number, it's what they used to log in.

Speaker 1:

Technical bugs are compounded by a lack of transparency, guidance and responsive support from FMCSA. With average wait times for ticket resolution stretching between 45 to 60 days, many small and mid-sized carriers are seeing their businesses paralyzed through no fault of their own.

Speaker 3:

When you call in, it does give you an option to call back or to get a call back if there's a long hold time. Even before MOTUS, that just didn't even work. People don't get callbacks. Customer service agents are just not knowledgeable. It's like a one in 20 chance that you're actually going to get connected with someone who has more than six months of experience and actually understands the issue that you're asking about, which is extremely frustrating if you're waiting weeks on responses for tickets or you're spending hours on the phone waiting to talk to someone. Multiple, multiple times now the FMCSA has resolved issues that we've submitted tickets for without sending any kind of response or notification. No update on the ticket, no communication with us or with the carrier. We just have to basically log in and see sometimes. Without clear guidance on what needs to be done, they're making it harder for everyone.

So for example, if you go to the FMCSA's website and submit a ticket, there's still not any options for issues with MOTUS. You have to select other issue and then ask about a topic not listed. There's still really, except for the one page where they said, if you can't link your DOT number, it might be because it was set up as a supporting company account, which we still to this day have not actually seen. That's the only guidance they've posted on, "Hey, if you're experiencing this issue, here's what you can do to resolve it." Even just having a daily updates help page, posting notifications, giving people guidance on submit a ticket for this issue, here's what you should say in the body of the message, here's the documents that we'll need in order to approve this request. And because there's no guidance on this, people are just continuously submitting more and more tickets.

And again, it's really just making it harder for the FMCSA too because they're having to go through these duplicate tickets again and again and again. Weeks to months to get any kind of response from an initial ticket submission. Right now we're seeing average wait time is like 45 to 60 days, which is enough time to shut down a lot of people's businesses. One person that we talked to says that she had called so much that the representative basically said, "You've called us too much, so I'm going to go ahead and escalate this and get you connected with a supervisor and gave her the direct email to a supervisor who was able to resolve the issue for her pretty quickly. And she was having the issue with the five million insurance and authority revocation. And from any kind of call center experience, it's pretty clear that they have an idea of when people call in, how many open tickets they have and so on.

I really do think it's the lack of communication and acknowledgement from the FMCSA on any of this. It's not only affecting these people's businesses and almost every single carrier that we already worked with prior to MOTUS immediately started having issues with it. But we posted one help article on our website of just like," Hey, here's some issues with MOTUS. Here's what we know will resolve those. "Just trying to provide some guidance. And it is still the most viewed page on our website. It was worse probably a couple weeks ago. It has slowed down a little bit, but I mean, we get a dozen plus calls a day from people we've never talked to before that are just looking for guidance with MOTUS. And we're a business too. We provide a service, but we don't feel that we don't want to charge people for help walking them through the MOTUS thing when it's not really something that we can do for them.

We can provide guidance, we can answer questions and that we're not just going to hang up on someone because they're having issues with MOTUS. We want to help people, but it's eaten up an incredible amount of time and energy on our side just to field these issues and these questions and concerns that really the FMCSA should be resolving. But again, because of all of these other issues in the ecosystem that they've set up with this launch, they're clearly not getting the help that they need from the FMCSA, so they're reaching out to anyone that they can. And again, we're happy to help. I'm glad to know that we've been able to get people through some of these issues, but it's overwhelming for us just like it's overwhelming for them. Issues with linking stuff in FMCSA systems is not a new concept to us. Before MOTUS, there was the changes that they did with the FMCSA portal a few years ago, and that was bad enough.

That's a whole different hairball, so to speak. But when it comes to something that's completely outside of anyone's control but the FMCSA, again, authority is just getting revoked without any real reason. At least for the carriers that we work with, we feel partly responsible. We're working with them to keep them active, to keep them in compliance. And then the FMCSA turns around and does something that we're supposed to essentially be protecting the carrier from to be on the lookout for these things. And again, I think my biggest frustration with it is just the fact that it's like the FMCSA is trying to brush it under the rug, thinking that it's just going to be resolved with the next system update. And then the next system update comes out. None of the original issues that were there before have been fixed and they've introduced something new that we get to deal with.

And even for people who's like, maybe they had a DOT number three years ago and now they want to start it up again, they want to get their authority going and they're interested in our help with doing that. It's like the first question we have to ask is, okay, have you set up your MOTUS account? And when they say, nope, I haven't, it's like, okay, well, you're looking at probably two months or more before we're able to even have the conversation of what you need to get back on the road. That hurts our business. And straight up, it's just turned away a lot of people where they're like, well, no. If that's what it's going to take, then I'm just going to figure out something else to do in the meantime. And I can't speak to how valuable these people would be to the industry overall, but it's certainly driving people away from the trucking industry at the moment.

I think it's just overall a very bad look for truckers or for prospective truckers looking to get into the industry or start their own company. How can you be confident in starting a small trucking business when you feel like the very systems that you're required to use to even start are crumbling underneath you?

Speaker 2:

Code level analysis of the platform also points to reliance on automated development practices and AI-assisted front-end architecture, raising Bailey's concerns over underlying system design and inadequate pre-launch testing. CCJ asked DOT if or how AI was used in coding MOTUS and they did not respond, but Bailey suspects it was used heavily.

Speaker 3:

For any kind of software that you use on a browser, there's two parts of it. There's a backend and there's a front end. So the backend is usually what controls the actual actions that get taken. So when you file for a new DOT number, it's the backend of the system that generates the DOT number for you. And then there's the front end of the system, which basically controls when you click a button on a webpage, it will take you to the next page or it will pop up the screen or whatever it might be, stylize it, all these things. So the backend code is going to be on an FMCSA server somewhere. There's no way that anyone would have access to that without actual infiltration. But front-end code is visible on any website. It has to be just as part of the way the whole system works basically.

So typically there's a process called minification where when you have code that you know is going to be visible potentially to users, you minify it, which makes a name or the name of a variable, like username becomes the letter U. So it's just one letter now. And when you have that across an entire huge file of code, it makes it essentially unreadable because you don't really have any real names to attach things to. Minification will also strip out any comments. So you can have active code blocks and then above that you can have essentially just commented human readable text that says what this part of code is supposed to do. So when people are developing a website, you minify the code and you're supposed to leave out any references that would basically link you to the unminified version of it. The FMCSA didn't, which is kind of problem number one, that's really amateurish to do that.

That should never hit a production website where something that's going to be used by actual users where there's now a link to essentially the raw version of that code. And that raw version of code is accessible. I can send you the files and you can read the comments. And this is all public information. There was no sleuthing or anything like that to get there. This is literally just following the breadcrumbs that the FMCSA put there or left there, I should say. And in these comments, there's a few telltale details that are really obvious. So one, I'm sure that just reading stuff online, you notice that because AI is trained on public writing, there's M dashes everywhere. There's never any typos. There's M dashes everywhere. Sometimes the language that's used is really just kind of obtuse. It doesn't sound like something a person would say. And there's literal examples in that code base where you can see a comment where it's like none of the words are capitalized.

There's typos, just simple ones that we make all the time, something that you probably would gloss over just reading it until you take a second look at it. And then you'll see, and even under that, what used to be an active code block has been commented out. And then you look in another file that now basically has that same code block will have the same comment above it, but it's been corrected. Words are now capitalized. There's punctuation. The typos that were there have now been fixed. If someone was going to copy code from one file to another, you wouldn't take the time to rewrite the comment to make sure it had proper grammar or punctuation or anything like that. So that's one kind of small thing. But number two would be just essentially M dashes everywhere. I can promise you there's not a single developer on this planet.

As someone who's been doing software for years myself, there's not a single developer on this planet that's going to use M dashes in commented code. It's just not going to happen, but it's everywhere over this code. And again, that representation of obtuse language, you'll see a one line of code that has, again, spelling errors and is all lowercase and it will just be one line, very simple, this is what this does. And then in another file, you'll see a paragraph that's all, again, perfect, M dashes, and then it uses something like while this hydrates, instead of the word loading, hydrates isn't a verb that we would typically use, but again, it's a telltale sign of LLM generated code. So I would say for me, it's 100%, there's no doubt in my mind that at the very least, the front end of MOTUS is AI assisted.

Now I don't think they're using ChatGPT. They're probably using USAI or whatever other internal models that they have that are distilled from something like ChatGPT. But just knowing from what I know in my own experience also playing with some LLM assisted coding and stuff like that, it's clear to me not only in the writing style, but also just in really the issues, the issues that are happening. It doesn't seem like even when they push these updates that things are being tested properly. Again, issues like, "Oh, sorry, your insurance requirement suddenly got raised to $5 million." Those things should never happen in production. They should have separate testing databases and staging environments where they're testing these things, where they're running it through gamuts of different testing and metrics to make sure that it's working like it should before they push anything to a critical government system, a live government system that people are relying on in order to run their businesses.

Even if Facebook pushes out an update, you can best believe that they've spent a significant amount of time in testing and making sure that it works and putting it through benchmarks and all of these things. And sometimes things still slip through. That's just the nature of software. But the variety of different issues that we've seen, the consistency of these issues, basically rearing their head every few weeks when a new update gets pushed, there's, again, no doubt in my mind that with all of these things together, that at the very least the front end is heavily AI assisted, but even the technology stack is what it's called that they're using is, it's basically going to be written very similarly on the front end as it is on the backend. So for me, I don't see any reason why they would do something like use AI to assist on what should be the easier part, the front end, the way things look versus the backend, which is the important business logic, the stuff that makes things happen in the real world.

It's going to be very similar styles of code on each side. So I highly doubt that they're basically segregating it and saying, "We're only going to use AI on the front end. It's fine there, but we're going to do everything by hand on the back end." And just in general, if you look at the way that say company snapshot or the old licensing and insurance system was developed, it's a completely different coding style, different type of programming than is used for the MOTUS system. And I think a big part of that is because the way the MOTUS system is designed is one of the more popular ways to build websites quickly these days and something that AI in particular is very good at because there's lots of code on the internet that uses that style of code, those languages. And so it has lots of training data to go on.

So yeah, it would make sense that they would go, "Oh, well now we can take advantage of AI to do this quicker because we're on a deadline. We said we were going to get this done and it's not done yet, so now we need to hurry up and rush this out. So we're going to use AI, but it's going to go a lot better or a lot faster if we completely switch the entire foundation of how these systems are developed because the AI is going to be better fitted towards those versus the way that these systems have been designed for decades now and have been working mostly without issue, at least nothing like we've seen with these.

Speaker 1:

As complex as all that sounds, Bailey says it doesn't necessarily spell long-term pain for MOTUS's learning curve, but expert human intervention is probably necessary at this point.

Speaker 3:

I think if we continuously tamp out the fires, it will eventually get under control, but I think there needs to be a wave of hiring for experienced software engineers at the FMCSA, not all of these other roles that they've been hiring for recently. And far less, or even I would say personally, I would feel better if AI wasn't used at all for any government systems that I rely on. I don't want AI to be integrated into irs.gov when it comes to determining if I did my taxes correctly. I would want human expertise on those issues. And if AI is going to be used, then I think that that needs to be public information. It needs to be clear that AI is used in these systems. But I think at least what I'm seeing, the sense that I'm getting is that the FMCSA is just spinning their wheels because they're just trying to prompt their way out of this rather than spending the money to hire experienced professionals to come in and make some real changes in the system and get the thing under control.

AI is only as good of a tool as the person that's using it. If you are experienced in what you're doing, if you know exactly how the system should be architected and you're providing those instructions to it and you're going through and you're reviewing the code yourself and you're signing off on these things incrementally, then absolutely. It's basically just a way to skip the process of writing out the code yourself. But what this seems to me is that this isn't just AI that's writing the code. AI is designing the system. They're designing the underlying architecture that's connecting these systems together, that's providing the functionality, and it's writing the code to implement that functionality. So in software development and especially in big systems, even if you were to create an entirely new system from scratch today that had no reliance on legacy systems, like the FMCSA says they have seven legacy systems that they're all trying to cobble together, the last thing I would want to do for something like that is use AI because what you need is people who are experienced with each of those platforms individually.

You need people who are essentially the middle layer that's kind of coordinating, okay, how are these things going to connect? What is that going to look like? When are these older systems going to be phased out? What information is critical to carry over to new systems? And then essentially you need to have a whole different team of experts that's just on the new architecture that's building things that are then going to talk to the intermediaries. The intermediaries are then going to talk to the legacy systems until eventually you can slowly phase out the legacy systems as everything new that's getting created is going into the new system. AI is an extremely useful tool, but not for this type of situation. Again, not for any kind of design or architecture, especially not something where, again, one small error, one small issue can unravel into this absolute nightmare of authorities getting revoked and can't sign in, can't link the DOT number, issues with even updating things when you get in there.This all speaks to underlying architectural issues with the system, not like, oh, there was one line of code that was wrong in here that an AI could have caught kind of thing.

This is race conditions. It's the way systems talk to each other. It's how the data's processed once information from one system is migrated to another. Again, the last thing I would use AI for is a job like this.

Speaker 2:

The biggest takeaways for fleets are to anticipate prolonged administrative delays under MOTUS, document every system error meticulously, and contact local representatives to hold regulatory agencies accountable.

Speaker 3:

Contact your local representative if you're having issues with MOTUS, if you're not getting a response from the FMCSA in a timely manner, especially if you're one of the people that's been affected by your authority being revoked involuntarily by the FMCSA because of a system issue, making your representatives aware of this so that they can hold someone responsible at the FMCSA or just hold the FMCSA responsible for these, I think is going to be critical. Personally, I think whatever money the FMCSA projects to save the industry with MOTUS by preventing fraud and all these other things that they claim, I think at this point is overwhelmingly outnumbered by the amount of money and the amount of business that people have lost because of the issues with the system. It's great that you want to protect the industry, that you want to get fraudulent people out, you want to prevent chameleon carriers, you want to do all these things, but you're throwing the baby out with the bath water.

You're shutting down companies that have been active, compliant and generating revenue for the industry and the economy for years or decades because you're trying to prevent future instances of fraud and error. I think that in my opinion, if I was the head of the FMCSA, if I was Ken Riddle, the registration department, as soon as I noticed that there was more legitimate carriers affected by these changes than what we were hoping to achieve, I would've immediately built some kind of off ramp like, "Hey, we're still going to keep working on this, but in the meantime, we're going to open up one of these other channels so that you guys can get some resolutions in the meantime so that we can address the problems that active valid compliance carriers have had to make sure that your business is not interrupted." But again, that's not the case and it continuously, at least based on the FMCSA responses that you included in your previous article, they're not in any kind of frame of mind to accept responsibility or really do anything other than what they already planned on doing, which was just continuing to quash bugs, which again, it's been months, what are we looking at?

Four months almost to the day that MOTUS has been out, so a third of a year and we're still having all of these issues. It's just insane to me. This has by far been the worst rollout of any FMCSA system and the worst response to any rollout of an FMCSA system.

Speaker 1:

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