Appendix C
Comments Received by the Committee

At the committee’s direction, TRB sent letters to 45 parties identified by the committee as having an interest in truck size and weight regulations. The letters asked for the parties’ views on what changes in federal regulations, if any, the committee should consider, what recommendations the committee should make, and what factors it should consider in evaluating proposals. Twenty-five organizations responded (Box C-1).

No attempt was made to have equal numbers of responses from each of the various categories of interested parties. The intent of the requests for comments was not to conduct a poll to determine which changes in regulations would be most popular, but rather to obtain information that would be useful to the committee in its evaluations. More responses were received from trucking industry groups than from any other category of organization, reflecting in part the specialized interests of segments of the trucking industry in particular features of the regulations that most affect their operations.

In addition to indicating the views of the respondents on particular options for changes in federal regulations, the responses read as a whole point out three general issues regarding federal truck size and weight regulation that are sources of concern:

1. The complexity of the regulations: The detailed and specialized nature of many of the responses demonstrates the complexity of federal and state motor vehicle size and weight regulations. This complexity has several causes: the inherent complexity of the engineering and economic system subject to the regulations (i.e., the highway transportation system); the multiple, often competing, interests and objectives of the interested parties; and the accumulated legacy of 85 years of state and federal rulemaking.

As explained in the Preface, the committee was not able to evaluate all the specific provisions of the existing federal law and regulations. Hence, issues of significant concern to some of the respondents were not addressed.



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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Appendix C Comments Received by the Committee At the committee’s direction, TRB sent letters to 45 parties identified by the committee as having an interest in truck size and weight regulations. The letters asked for the parties’ views on what changes in federal regulations, if any, the committee should consider, what recommendations the committee should make, and what factors it should consider in evaluating proposals. Twenty-five organizations responded (Box C-1). No attempt was made to have equal numbers of responses from each of the various categories of interested parties. The intent of the requests for comments was not to conduct a poll to determine which changes in regulations would be most popular, but rather to obtain information that would be useful to the committee in its evaluations. More responses were received from trucking industry groups than from any other category of organization, reflecting in part the specialized interests of segments of the trucking industry in particular features of the regulations that most affect their operations. In addition to indicating the views of the respondents on particular options for changes in federal regulations, the responses read as a whole point out three general issues regarding federal truck size and weight regulation that are sources of concern: 1. The complexity of the regulations: The detailed and specialized nature of many of the responses demonstrates the complexity of federal and state motor vehicle size and weight regulations. This complexity has several causes: the inherent complexity of the engineering and economic system subject to the regulations (i.e., the highway transportation system); the multiple, often competing, interests and objectives of the interested parties; and the accumulated legacy of 85 years of state and federal rulemaking. As explained in the Preface, the committee was not able to evaluate all the specific provisions of the existing federal law and regulations. Hence, issues of significant concern to some of the respondents were not addressed.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Box C-1 Organizations Asked for Comments Italics indicate that the party did not respond. Motor carrier industry and private carrier associations American Bus Association (membership includes carriers and manufacturers) American Trucking Associations Distribution & LTL Carriers Association Motor Freight Carriers Association National Automobile Transporters Association National Solid Wastes Management Association Western Highway Institute Association of Waste Hazardous Materials Transportation National Private Truck Council Construction industry associations American Road and Transportation Builders Association Associated General Contractors of America Independent driver association and labor union Owner-Operator Independent Drivers Association, Inc. International Brotherhood of Teamsters, AFL-CIO Vehicle and equipment manufacturer associations Truck Manufacturers Association Truck Trailer Manufacturers Association Transportation companies Federal Express Corporation J B Hunt Transport Schneider National Carriers United Parcel Service Vehicle manufacturers Motor Coach Industries, Inc. Freightliner Corporation

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Shipper associations National Industrial Transportation League Intermodal Association of North America National Small Shipments Traffic Conference Railroad industry association Association of American Railroads Motorist or safety advocacy organizations American Automobile Association Coalition Against Bigger Trucks Insurance Institute for Highway Safety Advocates for Highway and Auto Safety Surface Transportation Policy Project State transportation departments Connecticut Department of Transportation Florida Department of Transportation Georgia Department of Transportation Idaho Transportation Department Indiana Department of Transportation Michigan Department of Transportation New York State Department of Transportation Texas Department of Transportation Minnesota Department of Transportation New Jersey Department of Transportation Other government American Association of Port Authorities American Association of State Highway and Transportation Officials Commercial Vehicle Safety Alliance International Bridge, Tunnel and Turnpike Association National Governors Association

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 2. Goals of regulation: Chapter 2 argues that evaluation of possible changes in federal regulations ought to start with a stated philosophy of the purpose of size and weight regulation. There is great variety in the views of the respondents on this question. Some responses argue that the only justifiable purposes of any revisions would be to improve safety and passenger mobility and reduce infrastructure costs, while other responses refer primarily to shipper costs of freight transportation. 3. Definition of federal responsibility: The evolution of federal involvement in size and weight regulation is described in Chapter 1. Several alternative philosophies of federal responsibility for size and weight regulation are advocated in the responses. At one extreme, one respondent calls for a “minimal” federal role. A federally supervised permitting program would constitute a middle-of-the-road proposal: it would give states greater flexibility to decide their own limits on all roads but would retain federal oversight of the terms of permits. Proposals for federally planned national systems—specifying size and weight limits, road networks, and other requirements nationwide— embody a dominant federal role. This summary of the responses is organized by grouping responses under the options for change in federal regulations listed in Box C-2. The options listed in Chapter 1 are included, and several more were added to accommodate the responses. Many of the recommendations in the responses did not match the listed options exactly, and often a single proposal in a response pertains to several of the listed options, so the categorization of responses is somewhat arbitrary. This summary does not reflect every comment contained in the responses. Each summary of a response is a paraphrase, unless a quotation is indicated. Following the summary of the respondent’s position, the respondent’s arguments in support of that position are listed. I. POLICIES WITHIN EXISTING FRAMEWORK AND PRECEDENTS OF FEDERAL TRUCK SIZE AND WEIGHT REGULATION These do not entail changes in pavement and bridge design practices, basic truck design, or highway user fees. DOT 1998 Study Illustrative and Policy Scenarios (DOT 1998) 1. Uniformity: extend federal weight limits now applicable on Interstates to all roads on the 200,000-mi federally defined national network; eliminate grandfather provisions.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Box C-2 Options for Changes in Federal Weight, Length, and Width Regulations and Related Policies I. Policies Within Existing Framework and Precedents of Federal Regulation: these do not entail changes in pavement or bridge design practices, basic truck design, or highway user fees. DOT comprehensive study illustrative and policy scenarios (DOT 1998) Uniformity: extend federal weight limits now applicable on Interstates to all roads on the 200,000-mi federally defined national network; eliminate grandfather provisions. North American trade: heavier vehicles with added axles (six-axle tractor-semitrailer, four-axle truck, eight-axle double-33-ft-trailer combination) on national network. Longer combination vehicles nationwide: long double- and triple-trailer combinations on restricted networks with staging areas; eight-axle double-33-ft-trailer combinations on national network and access routes. H.R. 551: eliminate trailers over 53 ft on Interstates and some other federal-aid roads; freeze grandfather rights; freeze state weight limits (including permits) on federal-aid roads. Triples nationwide: triple-trailer combinations (seven axles; 132,000 lb) nationwide on 65,000-mi network and state-selected access routes. Current proposals, including industry proposals State option for longer combination vehicles. Peterson-Cook bill: 97,000-lb six-axle tractor-semitrailer as state option. Case-by-case legislative exemptions from federal standards (e.g., TEA-21 exemptions). Changes in weight limits [other than DOT scenarios, Peterson-Cook, or Truck Weight Limits (TRB 1990a)]. Increased vehicle width limits. Changes in federal length regulations. Changes in current federal size and weight law or regulations in general.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Recommendations of earlier TRB study committees New bridge formula from Truck Weight Limits. Turner Proposal (TRB 1990b): state option to allow nine-axle, 111,000-lb double-33-ft-trailer combinations with coordinated bridge management and fee changes. II. Approaches to Federal Size and Weight Regulation Outside the Existing Framework Permitting program recommended in Truck Weight Limits for heavier trucks on Interstates. Performance standards as the basis for certification of operator-proposed vehicles. Federal user fee reform to closely align fees with costs occasioned (possibly coupled with optimal pavement design). Devolution of regulatory responsibilities to the states. III. Policies to Mitigate the Effects of Large Trucks: such policies would provide a broader range of options for controlling the costs of truck traffic while allowing efficient freight transportation. Improved enforcement of size and weight limits and safety regulations. Improved bridge management targeted at reducing bridge costs of trucks. Changes in pavement design practices. Exclusive truck routes or lanes. Mitigation policies in general. Owner-Operator Independent Drivers Association, Inc. The committee should recommend that federal law be changed to eliminate all state grandfather exemptions from federal size and weight standards. Federal standards should apply uniformly across the country. No other change in federal standards should be enacted. Arguments: Nonuniformity impedes the free flow of interstate and foreign commerce.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Uniformity would promote healthy competition in trucking [presumably by eliminating the short-term advantage that large trucking companies are alleged to gain when standards are changed and by allowing all truckers to operate in all parts of the country unimpeded by regional equipment differences]. Larger trucks would uneconomically increase infrastructure costs. “The introduction of heavier and longer trucks would greatly compromise highway safety. Drivers simply have less control over heavier and longer trucks…. it is intolerable to consider creating circumstances that give drivers less ability to safely operate commercial motor vehicles.” If use of larger trucks were expanded, the trucks would be operated by drivers of all skill levels on all roads; limiting use to the best drivers and roads would be impractical. Michigan Department of Transportation The committee should not recommend abolition of existing state grandfather rights under federal size and weight laws. American Trucking Associations The committee should recommend provision of “a set of minimum truck size and weight standards for vehicles operating on the National Highway System.” Existing grandfather provisions should be retained. Provision should be made for access to points of loading. [See also ATA responses under Options 6 (LCV state option), 9 (gross weight limit), and 11 (length limits) below.] Argument: The ATA size and weight policy “supports reasonable size and weight standards consistent with highway capability and the need for an efficient, intelligent, productive transportation system that meets national, regional and local economic needs.” 2. North American trade: heavier vehicles with added axles (six-axle tractor-semitrailer, four-axle truck, eight-axle double-33-ft-trailer combination) on national network. Truck Trailer Manufacturers Association Recommends that “efforts be made to harmonize size and weight regulations throughout North America and especially within the U.S.” [See also TTMA response under Option 7 (97,000-lb tractor-semitrailers) below.] National Automobile Transporters Association Committee should consider elimination of the federal 80,000-lb weight limit “without instituting a permit program or a regionalization

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 concept.” [That is, presumably, a federally mandated nationwide rule establishing a higher gross weight limit or specifying that gross weight be limited only by the bridge formula and length limits. The outcome would be similar to the DOT study NAFTA scenario.] Heavier vehicles would pay appropriate taxes and would be required to be equipped with “the most modern and practical safety devices available.” Arguments: The experience of the automobile transporters industry shows that liberalizing limits leads to increased productivity and less truck traffic. Since federal law and regulation established nationwide minimum length standards for automobile haulers, the automobile hauler fleet size has decreased as the number of vehicles hauled has increased. Liberalizing limits will reduce congestion, pollution, and accidents while increasing productivity. Because of the shift in consumer demand toward SUVs, vans, and pickups, standard automobile hauling configurations today have space to carry an additional vehicle but are prevented from doing so by weight restrictions. Federal allowance for regional variation in application of the higher weight limits would result in inequitable variations in the limits. Western Highway Institute The committee should recommend changes such that federal law would provide a framework for promoting the efficient movement of freight, giving consideration to the effects of NAFTA and to the overall growth in freight. Present federal law sometimes is a barrier to efficiency. 3. Longer combination vehicles nationwide: long double- and triple-trailer combinations on restricted networks with staging areas; eight-axle double-33-ft-trailer combinations on national network and access routes. Truck Trailer Manufacturers Association The committee should consider recommending that LCVs be allowed as described in the DOT study. Arguments: The main freight problem of the future will be to maintain efficiency in spite of greatly increased traffic. Allowing larger trucks will reduce the number of trucks on the road and thereby reduce congestion, ease the driver shortage, reduce accidents, and reduce the need to build additional highway lanes.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 National Industrial Transportation League The committee should consider changes to limits allowing more liberal use of LCVs “if they can clearly be operated in a safe manner.” In general, limits should be relaxed in a way that does not compromise safety. Arguments: Relaxing size and weight limits would increase the productivity of the trucking industry. Relaxing limits would allow freight to be carried with fewer miles of truck travel, tending to reduce the number of accidents. The volume of rail traffic will for some years be constrained mainly by rail capacity [and hence, presumably, restricting truck sizes will be unlikely to affect rail’s share of traffic]. The effect of regulatory changes on rail and truck market shares is not in itself a relevant consideration in evaluating the changes unless the larger trucks would not be paying their fair share of highway infrastructure costs. The driver shortage increases the importance of truck productivity. Productivity growth can be attained without loss of safety by placing special requirements on the operation of larger trucks and on the qualifications of their operators. 4. H.R. 551: eliminate trailers over 53 ft on Interstates and some other federal-aid roads; freeze grandfather rights; freeze state weight limits (including permits) on federal-aid roads. Coalition Against Bigger Trucks Proposes consideration of enactment of H.R. 551 as one component of a package of changes in federal law to prevent further liberalizations of state size and weight limits, including repeal of the Symms amendment defining grandfather rights, and defining nondivisible loads in such a way as to close a present loophole in federal weight limits. Arguments: The 1998 DOT Comprehensive Truck Size and Weight Study found that allowing larger trucks would generate large costs for bridge improvements, for example, $300 billion in the case of extensive use of longer combination vehicles. The federal study concluded that longer combinations have fatal accident rates 11 percent higher than conventional combinations.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 The long-term consequences of adoption of larger trucks for land use and total highway traffic volume are potentially significant and have not been assessed. Larger trucks would likely lead to lower-density land use patterns and increased environmental costs of transportation. The stress and discomfort to automobile drivers from sharing the road with large trucks is a real cost that drivers are sensitive to and that has never been evaluated. The systemwide safety cost of changing truck operations on a road network has never been evaluated. Changes in the size, performance, or numbers of trucks change the behavior of drivers and probably affect the safety of the road system in ways that are not reflected in average truck accident rates. Proposals to counteract increased risk of larger trucks by new requirements concerning vehicle design, route restrictions, or driver qualification are of unproven effectiveness. The 1997 federal highway cost allocation study concluded that user fees collected from heavier trucks would be substantially less than their cost responsibilities. No practical tax change to eliminate the underpayment has been proposed. In light of the uncertainties, recommending an increase in limits would be unreasonable. Recommending a freeze until uncertainties are reduced would be prudent. 5. Triples nationwide: triple-trailer combinations (seven axles; 132,000 lb) nationwide on 65,000-mi network and state-selected access routes. Distribution and LTL Carriers Association The DOT study triples scenario uses a maximum weight (132,000 lb) that is above the optimum. Triples with 120,000-lb maximum weight have substantial productivity benefits and much lower pavement and bridge costs. [See DLTLCA response under Option 6 (state option for LCVs) below.] Motor Freight Carriers Association The committee should consider proposals for operations of triples on highways that can safely accommodate them and under conditions that foster safe operations. Such proposals would entail a more limited network of roads and lower maximum weight than the assumptions of the DOT study triples scenario. One contribution that the committee could make would be to develop criteria defining the high-

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 ways that can safely accommodate triples and conditions that foster safe operations of triples. Current Proposals, Including Industry Proposals 6. State option for longer combination vehicles. Distribution and LTL Carriers Association The committee should recommend federal legislation allowing states to create permit programs for operation of longer combination vehicles. The permit program option should be available to all states regardless of grandfather rights. Such legislation would have the effect of repealing the current federal LCV freeze. Vehicles allowed under the permit program should include seven-axle triple-trailer combinations up to 120,000 lb, as well as other LCVs with maximum weight limited by a federal bridge formula. The federal law should compel the state permit programs to have features similar to those of the permit program recommended in Truck Weight Limits (TRB 1990a) [which referred only to vehicle weights and not lengths or configurations], including safety requirements for vehicles, drivers, and carriers, and accident and mileage data reporting for safety monitoring. Arguments: The existing federal LCV freeze increases shipper costs, truck traffic volumes, pollution, and congestion, and does not enhance safety. The effect of size and weight limits on railroads is not a legitimate public policy issue. Protecting railroads’ market share and profits from competition is bad for the economy. Western Highway Institute The committee should recommend repeal of the LCV freeze. Arguments: See WHI arguments under Option 9 (weight limits) below. Federal Express Corporation The committee should consider recommending allowance of broader use of longer combination vehicles. Georgia Department of Transportation The committee should consider the importance of regional differences in traffic and terrain in its evaluation of larger and longer vehicles.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 National Solid Wastes Management Association The committee should consider recommending increased tandem and tridem axle weight limits, as an alternative to revising the bridge formula. [It is unclear whether the proposed limits would supersede bridge formula limits.] Arguments: See NSWMA arguments under Option 13 (bridge formula) below. Western Highway Institute The committee should recommend repeal of the federal 80,000-lb weight limit now in effect on Interstate highways. States should be allowed to set higher (but not lower) maximums or to leave weight governed only by the federal axle weight limits and the federal bridge formula. Arguments: The outcome of existing federal law [including the 80,000-lb weight limit as well as the LCV freeze, which WHI also advocates repealing] is arbitrary. Often, vehicles that are in compliance with the federal axle limits and the bridge formula and that can operate legally in a state cannot operate in adjacent states. The 80,000-lb limit is artificial [that is, presumably, there is no scientific or economic basis for the limit]. States are in the best position to decide on the suitability of gross weight limits and LCVs. In the western states in particular, government-industry organizations have been established to work cooperatively on size and weight matters. Present law results in substantial excess transportation costs, particularly in the western states; the money could be spent elsewhere in a productive fashion. Federal Express Corporation The committee should consider an increase in maximum gross vehicle weight. Connecticut Department of Transportation The committee should recommend that 23 CFR Part 658 (the federal regulations on truck size and weight) be changed to include a definition of trunion axles. Georgia Department of Transportation The committee should consider recommending changing federal law to give states the option of imposing tandem axle weight limits

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 greater than the current federal maximum of 34,000 lb on the Interstates. The committee should recommend that federal law or regulation impose uniform state permitting practices for overweight intermodal containers. AASHTO Policy Resolution 9-96 in 1996 called for the same action. Argument: Georgia allows 40,680-lb tandem axles on roads other than Interstates. States with grandfather rights can allow similar weights on their Interstates, but Georgia does not have the right to do so because it cannot claim a grandfather exemption. In such circumstances, states ought to have some leeway to judge appropriate limits. American Bus Association The committee should recommend that federal law specify weight limits for intercity motor coaches independent of those applying to trucks or exempt motor coaches from federal weight limits. The legal maximum weight for the tandem axle pair of a motor coach should be no less than 36,000 lb, and for the drive axle of the tandem axle pair, 22,400 lb. A tolerance of 15 percent above these limits should be considered. Arguments: Motor vehicle size and weight limits have been established with trucks in mind and are incompatible with the design and operation of motor coaches. There is no practical way for motor coach operators to monitor their weight or to adjust loading to balance axle weights, as trucks can do. Weight has no effect on motor coach safety because coaches are designed to be safely operated at higher weights than the legal maximum. The design of the air suspension of a motor coach results in far less infrastructure wear than that caused by typical truck suspensions for a given weight. Federally mandated wheelchair lifts and emission control equipment have added to the weight of motor coaches. Transit buses have received a temporary exclusion from federal weight limits.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Motor Coach Industries, Inc. The committee should recommend that intercity motor coaches be exempt from federal axle weight restrictions or given a 15 percent allowance over the current limits. Arguments: Similar to those of ABA above. National Automobile Transporters Association The committee should consider recommending weight tolerances for commodity-specific truck equipment such as car haulers. Argument: The combined effect of current weight and length restrictions often prevents car haulers from optimizing loads. Consequently, they must often travel with empty spaces where additional vehicles could be hauled. American Trucking Associations The committee should recommend elimination of the federal 80,000-lb weight limit on Interstate highways. Gross weight should be governed by appropriate axle weight limits and the bridge formula. The committee should consider weight tolerances for automobile haulers. 10. Changes in federal vehicle width limits. National Solid Wastes Management Association The committee should recommend redefinition of the federal vehicle width limit to exclude ladders, mirrors, and controls from the definition of width to which the limit applies. Argument: Steps are already excluded from the width definition; the same justification would apply to other appurtenances. Truck Trailer Manufacturers Association The committee should recommend federal action to allow 102-in.-wide vehicles on all highways. Arguments: Trailers 102 in. wide probably are already operating on all highways. Removal of 96-in. limits would allow construction of 102-in.-wide tractors and tank trailers, which would have improved rollover resistance. Idaho Transportation Department The committee should recommend that the definition of nondivisible loads in federal regulations be made consistent with the definition

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 adopted by the Western Association of State Highway and Transportation Officials, in particular as it applies to wide loads and the hauling of equipment. 11. Changes in federal length regulations. Federal Express Corporation The committee should consider recommending that federal law prevent states from establishing maximum trailer length limits of less than 53 ft for a semitrailer in a tractor-semitrailer combination. Connecticut Department of Transportation The committee should recommend that certain ambiguities in federal trailer length regulations (23 CFR Section 658.13) be clarified. First, the regulations “should be revised to include a maximum semitrailer length. As written, any length semitrailer would be allowable for motorsports competition.” Second, the regulations “should be revised to include a definition of those automobile transporters not considered specialized equipment.” The committee should recommend that a uniform nationwide federal standard for the kingpin-to-rear-axle dimension of 53-ft semitrailers be adopted. The committee should recommend that a federal standard be adopted for the dimensions and location of markings indicating the length of 53-ft semitrailers. American Bus Association The committee should consider recommending that the federal maximum length of motor coaches be increased from the present 45 ft to 50 ft. Motor coach bumpers should be excluded in measurement of length. Arguments: Trailers 53 ft long are legal on nearly all roads. Motor coaches 50 ft long are in use in Europe. Bumpers should qualify as safety devices, which are already excluded in the application of federal dimensional limits. Motor Coach Industries, Inc. Bumpers should be excluded in the definition of motor coach length for regulatory purposes.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Arguments: Bumpers are safety devices. Federal action would preempt inconsistent state length requirements. American Trucking Associations The committee should consider a federal minimum trailer length law for combinations that include tractors with dromedary boxes. “The committee should consider changes to the federally grandfathered longer combination vehicle … laws that allow for the measurement of combined trailer length … rather than the overall length of the combination.” 12. Changes in current federal size and weight law or regulations in general. Texas Department of Transportation The committee should not recommend changes in existing federal law or regulations governing vehicle weight, length, and width. Arguments: “Normally, demand drives the need for change and thus far in Texas we are hearing neither public nor business requests for any changes in the status quo. The economy is thriving within current guidelines, manufacturers are building cleaner and more fuel efficient trucks, truck safety is on everyone’s agenda, … and our communities appear well served by existing transportation modes.” Motor Freight Carriers Association The committee should consider the range of reasonable proposals that have been made in recent years for liberalizing limits to provide increased productivity, including the recommendations of earlier TRB committees on size and weight issues, including Truck Weight Limits and the Turner Proposal study (TRB 1990b). Arguments: The decision embodied in the 1991 LCV freeze to “freeze productivity improvements on a mode of transportation that is vital to a growing and diverse economy” was an irrational one. “With a growing economy—and its attendant increases in freight and truck traffic—we eventually must confront the reality that trucks are a large part of the equation. We will have to decide if we want more trucks of the same or smaller size or do we want to rationally consider sensible increases in sizes and weights.”

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 Truck Manufacturers Association Truck size and weight regulation is of interest to members of the association, but the views of members are diverse and the association has not developed a consensus position on the issue. New York State Department of Transportation Increases in length, width, and height limits should only be considered and agreed to by states within geographical regions. The federal government can consider revisions to weight limits, but on Interstate highways only. Recommendations of Earlier TRB Study Committees 13. New bridge formula from Truck Weight Limits. National Solid Wastes Management Association The committee should recommend a new bridge formula similar to the one recommended in Truck Weight Limits, either as a state option or as a federal mandate. Arguments: Waste-hauling costs would be reduced. Fewer truck trips would be required to remove waste, reducing traffic congestion, pollutant emissions, and accidents. Increasing the length of waste-hauling trucks to allow increased weight under the existing bridge formula is impractical and unsafe. Most states already have special limits for waste-hauling trucks off the Interstates, forcing heavier trucks onto the less-well-designed roads. Western Highway Institute Consideration should be given to a new bridge formula, although the present formula is adequate for the majority of industry’s needs. Provision should be made for large-scale testing of proposed new bridge formulas. 14. Turner Proposal (TRB 1990b): state option to allow nine-axle, 111,000-lb double-33-ft-trailer combinations with coordinated bridge management and fee changes. Michigan Department of Transportation The committee should consider changing regulations to encourage adding axles to vehicles to lessen pavement wear.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 II. APPROACHES TO FEDERAL SIZE AND WEIGHT REGULATION OUTSIDE THE EXISTING FRAMEWORK 15. Permitting program recommended in Truck Weight Limits for heavier trucks on Interstates. National Solid Wastes Management Association The committee should recommend a permitting program with features similar to the recommendation of Truck Weight Limits as a state option. Arguments: See NSWMA arguments under Option 13 (bridge formula) above. 16. Performance standards defined as the basis for certification of operator-proposed vehicles. Truck Trailer Manufacturers Association The committee should recommend creation of a federal special permit program for testing and demonstration of new industry-developed vehicle technologies. The committee should recommend that the federal government develop performance requirements (presumably for use at least as the basis for the permit program). Argument: State size and weight regulations today prevent testing and demonstration of industry-developed concept vehicles. The federal permit program would allow experience to be gained with such vehicles and would encourage innovation. The research base for defining performance requirements exists. National Automobile Transporters Association NATA is sponsoring research for design of automobile hauler configurations based on performance standards. Western Highway Institute The committee should recommend creation of a mechanism for testing of new types of operations, including new bridge formulas, the Argosy concept vehicle, and performance standards. 17. Federal user fee reform to closely align fees with costs occasioned (possibly coupled with optimal pavement design). Association of American Railroads Conclusions on appropriate changes in the regulations must include consideration of how costs are to be recovered from the parties involved.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 “[A]n efficient cost recovery system would eliminate the cross subsidization between highway users, ensuring that each category of highway user pays only for the costs it imposes on the highway system, thus providing the basis for an economically efficient allocation of freight among all freight transportation modes.” The relevant costs are direct infrastructure costs; social costs including safety impacts; and the full effects on shippers’ costs, including disadvantages of larger trucks to shippers (e.g., higher inventory costs) and the effect of higher rail rates that would result if rails lost traffic to larger trucks. National Automobile Transporters Association “The privilege of hauling additional weight should be indexed into the current heavy vehicle use tax.” Michigan Department of Transportation The committee should consider mechanisms to fund pavement, bridge, freeway interchange, and local road upgrades necessitated by any changes in commercial vehicle weights, lengths, and widths. New York State Department of Transportation If federal weight limits on the Interstates are increased, the trucking industry should pay for any improvements necessary to accept heavier loads on roads giving access to the Interstate system. A truck operating at a higher weight by permit should pay fees depending on its equivalent single-axle load (ESAL) rating. 18. Devolution of regulatory responsibilities to the states. Idaho Transportation Department The committee should recommend changes so that laws and regulations on the federal level concerning vehicle dimensions “should be minimal and more general.” Specific laws and regulations should be the responsibility of individual states, working in cooperation with other states. Arguments: The states differ greatly in the conditions that are relevant to selecting size and weight limits. These include population density, terrain, climate, and infrastructure condition. The federal government is not capable of assessing local conditions in setting size and weight limits. Examples of unintended and illogical consequences of federal divisible load regulations are cited.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 New York State Department of Transportation If federal weight limits on the Interstates are increased, the states must have total control of provisions giving the larger trucks access to and from the Interstates, without federal influence. III. POLICIES TO MITIGATE THE EFFECTS OF LARGE TRUCKS Such policies would provide a broader range of options for achieving the underlying goal of controlling the costs of truck traffic while allowing efficient freight transportation. 19. Improved enforcement of size and weight limits and safety regulations. New York State Department of Transportation Heavier trucks operating under permit should be required to display a plate showing the weight rating and horsepower of the power unit and other specifications. 20. Improved bridge management targeted at reducing bridge costs of trucks. Western Highway Institute Consideration should be given to use of a field diagnostic system to ensure that posted limits reflect bridges’ true carrying capacity. 21. Changes in pavement design practices. No comments were received for this option. 22. Exclusive truck routes or lanes. Truck Trailer Manufacturers Association “New intelligent highway construction should be planned” for major freight lanes to accommodate larger combinations. 23. Mitigation policies in general. Indiana Department of Transportation The committee should recommend revisions in federal law and regulations that will provide a safer infrastructure system for the traveling public. The committee should not recommend changes that would

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 increase vehicle weights, lengths, or widths. In evaluating alternatives, the committee should consider safety, costs, alternatives to trucking, and freight diversion. Insurance Institute for Highway Safety “Revisions to federal law and regulations regarding commercial vehicle weights, lengths, and widths should not be considered if they could worsen the current level of truck safety on U.S. roads. Reducing the losses associated with large truck crashes should be the primary concern of any revisions to federal laws and regulations concerning truck size and weight.” “Design changes to heavier trucks that may improve one aspect of performance can have a negative effect on another. For example, increasing the number of axles can reduce pavement damage from heavier trucks and their tendency to roll over; but this also degrades braking efficiency and the ability of a truck to evade obstacles.” Several studies indicate that multitrailer accident rates are higher than those of single-trailer configurations when confounding factors are controlled for. American Automobile Association The committee should evaluate vehicle weight, length, and width limits and related regulations that affect safety, infrastructure, and mobility. Examples of such regulations are truck driver licensing including requirements for particular vehicle configurations; enforcement of licensing requirements and other safety regulations and of size and weight limits; state permitting practices as they affect safety, infrastructure, and mobility; U.S. and foreign regulations that govern the dimensions of trucks entering the United States from Canada and Mexico; and the efficacy of hours of service regulations for various truck configurations. The committee should attempt to identify changes in regulations that would improve safety, mobility, and the economy of use of the infrastructure. New York State Department of Transportation In addition to weight, new regulations changing the federal weight limits would have to address suspension characteristics and performance, tire characteristics, maximum weights for axle groups, horsepower-to-weight ratio, and state permitting and fee requirements.

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Regulation of Weights, Lengths, and Widths of Commercial Motor Vechicles: Special Report 267 REFERENCES Abbreviations DOT U.S. Department of Transportation TRB Transportation Research Board TRB. 1990a. Special Report 225: Truck Weight Limits: Issues and Options. National Research Council, Washington, D.C. TRB. 1990b. Special Report 227: New Trucks for Greater Productivity and Less Road Wear: An Evaluation of the Turner Proposal. National Research Council, Washington, D.C. DOT. 1998. Comprehensive Truck Size and Weight Study: Draft Volume III Scenario Analysis. Dec. 30.