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54 8,000 7,000 Heavy Single-Unit Trucks 6,000 Registrations (000) 5,000 4,000 3,000 Combination Trucks 2,000 1,000 0 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Source: FHWA, Highway Statistics. Figure 5-2. Freight trucks registered in the United States. preserve the waterfront for marine industrial uses. However, Although trucks are essential to the modern economy, they because of Florida's state laws protecting working waterfronts, present challenges to urban policymakers. Challenges include the port has been able to use litigation and administrative congestion; safety risks to motorists and non-motorists (e.g., processes to counter the city's efforts to rezone the waterfront cyclists and pedestrians); physical damage to infrastructure; and for residential development. environmental impacts in the form of noise, vibrations, and Conversely, the Port of Baltimore features more promi- emissions. Such issues with freight delivery have likely chal- nently in the Baltimore economy and is run by the Maryland lenged governments as long as cities themselves have existed. Port Administration, a state agency. While it does not have the The oldest known example of a policy requiring off-peak deliv- same type of protections in state law that Florida ports have, its eries of freight is Julius Caesar's edict banning commercial economic clout, along with that of port-related companies, is deliveries during daytime hours in Rome.81 Given the difficulty sufficient to obtain protection of waterfront property through of increasing roadway capacity in urban areas and the expected city zoning. increases in truck traffic, policymakers will be faced with ever greater challenges in managing truck traffic on urban streets. Case Study 2: Local Truck Access and Parking Policies Stakeholders Setting Trucking companies are subject to a complex overlay of Federal, state, and local regulations regarding vehicle routing, Trucks are the primary means of transporting goods loading/unloading times, and parking. Federal regulations within urban areas. These vehicles are used to carry out a prohibit states from restricting commercial motor vehicles wide range of services, including parcel and courier serv- that do not exceed the Federal maximum size limits applica- ices; pickup and delivery of freight for retail establishments, ble to the National Network.82 These vehicles must be allowed homes, and offices; movement of household belongings; reasonable access between the National Network and freight and transport of all types of waste. The volume of freight terminals, as well as facilities for food, fuel, repairs, and rest.83 activity has increased over time because of its direct links States have authority to restrict truck travel on other routes, with growth in population and economic output, as well as provided that these restrictions do not violate the constitu- the adoption of practices in supply-chain management and tional ban on restrictions of interstate commerce. logistics that rely on smaller, more frequent, and more reli- able deliveries.80 As shown in Figure 5-2, the number of sin- gle-unit freight trucks registered in the United States has 81Jos Holguin Veras, "Necessary Conditions for Off-Hour Deliveries and the grown from 4.5 million in 1990 to 6.8 million today, an Effectiveness of Urban Freight Road Pricing and Alternative Financial Policies in Competitive Markets," presented at the TRB 2008 Annual Meeting, Washing- increase of more than 50 percent. ton, DC, January 2008. 82The National Network includes (1) the Interstate Highway System and (2) high- ways, formerly classified as Primary System routes, capable of safely handling 80 Anne G. Morris, Alain L. Kornhauser, and Mark J. Kay, "Getting the Goods larger commercial motor vehicles, as certified by states. The total National Net- Delivered in Dense Urban Areas: A Snapshot of the Last Link of the Supply work system is about 200,000 miles. Chain," Transportation Research Record 1653, 1999. 8323 CFR 658.19.

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55 With regard to truck routing, some states have designated between 10 P.M. and 6 A.M.84 In central business districts highway networks that large trucks must use until they reach (CBDs), cities may restrict loading and unloading during the appropriate local roads for getting to a shipper or receiver. peak travel periods as a way of easing traffic congestion. Similarly, if allowed by applicable state law, cities have desig- Recently, more attention has been given to the use of nated truck routes within their boundaries. In general, trucks variable pricing mechanisms to encourage traffic (includ- must remain on these designated routes except as necessary ing freight vehicles) to move to non-peak travel periods. to reach a pickup or delivery location. Local rules may also A prominent example is London's cordon pricing system, require trucks exceeding certain dimensions or weight to which applies to both passenger and freight vehicles. New obtain permits. York City proposed implementing a similar system, but the Parking and loading/unloading of trucks is typically regu- New York State legislature did not provide the necessary lated by local transportation or public safety agencies. Cities approvals. Individual freight facilities such as ports have typically prohibit or greatly restrict truck parking in residen- also begun to use variable pricing to encourage shifts in tial areas. For commercial areas, cities commonly designate freight traffic. For example, the PierPASS program at the acceptable times and areas for loading and unloading. Local Ports of Los Angeles and Long Beach offers financial incen- rules regarding truck activity are enforced by local police or tives to move cargo at night or on weekends. parking enforcement authorities. 2. Route and access restrictions by vehicle weight and size. Private-sector stakeholders with an interest in the regula- In cities such as New York, Chicago, Dallas, and Seattle, tion of truck activity in urban areas include trucks of certain dimensions or weight are required to remain on designated truck routes to the extent feasible. Trucks exceeding a city's size and weight limits often must Shippers and receivers. Shippers and receivers in urban obtain an oversize permit prior to traveling.85 Route restric- areas are interested in timely and cost-effective freight tions based on vehicle size and weight are often motivated delivery and want to be able to interact with carriers during by roadway characteristics such as pavement condition, their normal business hours and with minimal disruption road geometry, and bridge heights. The impacts of truck to their ongoing operations. traffic on residential areas are also an important factor in Freight carriers. Carriers doing pickup and delivery in the selection of truck routes. In some cities such as Los urban areas want the flexibility to select their routes and Angeles and Miami, the level of concern about the impacts pickup and delivery times. They also want adequate space of truck traffic has prevented the cities from designating for parking and loading and unloading of freight. official truck routes, although de facto truck routes already Residents and local advocacy groups. Communities, rep- exist.86 resented by local residents and/or advocacy groups, are typ- 3. Restrictions on loading and unloading. A major con- ically concerned with the noise, pollution, safety risks, and straint on loading and unloading freight in urban areas is parking issues associated with truck traffic. the availability of loading and unloading zones for com- Other urban travelers. All traffic on urban roads is affected mercial vehicles. Many cities restrict truck parking to desig- by congestion related to truck activity (e.g., traffic bottle- nated curbside loading zones and set time limits for parking necks from double-parking of trucks) or the safety risks of there. If carriers find the supply of designated loading and traveling in truck traffic. unloading areas to be insufficient, they often opt to park Local highway or public works agencies. These agencies illegally and pay any resulting fines. are concerned about truck traffic increasing the cost of Local land use planning and zoning authorities can maintaining local transportation infrastructure. also affect the ability of trucks to load and unload freight through specifications on the number and size of docking Policy Actions facilities at large buildings. Carriers may incur delays if the number of loading bays at commercial buildings is too The types of restrictions on freight transportation typically small to accommodate the volume of freight activity. In imposed by local authorities include the following: 84Edwards and Kelcey Engineers, Inc., Truck Route Management and Commu- 1. Time-of-day restrictions on freight activity. Trucks often nity Impact Reduction Study, Technical Memorandum 1: Traffic Policies and have restricted time windows for delivery and pickup in Regulations, March 2007, p.82, dense urban areas. Near residential areas, cities may pro- tm1trafpolicies.pdf 85For example, see New York City Department of Transportation, "Oversize/ hibit nighttime truck activity. For example, in Dallas, trucks Overweight Permits for Commercial Vehicles and Trucks," are not allowed to travel off a designated truck route on html/dot/html/motorist/oversize.shtml, accessed September 8, 2009. streets adjacent to single-family and duplex residences 86Edwards and Kelcey Engineers, Inc., Technical Memorandum 1, p.83.

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56 addition, carriers may find it necessary to break loads into assess a "New York arbitrary" congestion charge of at least smaller shipments or use smaller delivery vehicles if dock- $150 for each vehicle destined for the five boroughs, Long ing facilities cannot accommodate larger trucks or receive Island, and Westchester County.89 large pallets.87 Policies intended to push freight movement to off-peak periods can result in different types of freight system The effects of these types of policies on freight transporta- impacts. If these restrictions push deliveries outside the nor- tion can be exacerbated by urban development patterns. The mal working day, carriers may incur higher costs to provide CBDs in many U.S. cities were originally developed with evening, night, or weekend service. Carriers, particularly the networks of alleys and loading zones to accommodate urban private carriers, expeditors, and LTL firms, may have more goods movement. As the economic structure of many cities has difficulty finding drivers to work off-peak hours and may shifted from manufacturing to service industries, the value need to pay wage premiums as a result. In the case of off- placed on these access facilities has diminished. Urban redevel- peak incentive programs such as PierPASS at the Ports of opment efforts have often consolidated smaller parcels and Los Angeles and Long Beach, negative impacts have fallen eliminated alleys and other facilities for truck access, encour- primarily on drayage truck drivers (who work longer hours aged by changes in development practices that value rentable without a change in pay) and on warehouse operators (who space over truck access. must adjust hours and absorb higher costs), as noted in Section 4.90 Policy Impacts Cities impose truck access and parking restrictions to fur- Route and Access Restrictions ther goals such as congestion relief, traffic safety, improved Route and access restrictions may increase a carrier's costs air quality, reduced noise, and infrastructure preservation. by increasing the number of miles traveled and time required However, these policies impose direct and indirect costs on per goods movement. These restrictions may also impose actors in the freight transportation system. These costs are delay costs to the extent that they prevent trucks from seeking detailed below. less congested alternative routes. For example, a 2007 study determined that only 5 percent of New York City's streets were Time-of-Day Restrictions designated as truck routes and that most of the truck routes were operating at or near capacity. The study also found that Time-of-day restrictions may require trucks to operate dur- New York City had experienced a 35 percent increase in truck ing more congested travel periods than carriers would other- volumes during the preceding 20 years but had not added any wise choose to deploy their vehicles. Congestion-related delays miles to its truck routes.91 increase the cost of labor and fuel per goods movement. A A carrier can avoid having to comply with route and access study by the American Transportation Research Institute restrictions by using smaller vehicles, but the carrier will face (ATRI) estimated that the marginal costs for the trucking higher operating costs to break down shipments and transfer industry were $1.73 per mile and $83.68 per hour in 2008. This them to the smaller vehicles. As mentioned above, a carrier's includes an average labor cost of about $25 per hour.88 There- operating and capital costs will also increase if it purchases fore, a conservative estimate for the average cost of 1 hour of more vehicles to make the same number of goods movements. delay each day per truck would be more than $20,000 per year Using ATRI's figures for vehicle operating cost per hour and (assuming 250 working days). assuming smaller vehicles, each vehicle added to the fleet Carriers' capital costs may also increase if they opt to use would cost over $100,000 more per year to operate. more vehicles to make the same number of goods movements. Carriers face the same types of decisions when dealing with Carriers offering time-definite delivery services would be most urban customers who have docking or curb space that cannot likely to invest in additional vehicles and drivers. Given that accommodate large pallets or large trucks. To handle deliveries congestion is likely to affect all carriers operating in a particu- lar city, these costs probably are passed on to a carrier's cus- 89Anne G. Morris, Alain L. Kornhauser, and Mark J. Kay, "Urban Freight Mobil- tomers. For example, it is common practice for carriers to ity: Collection of Data on Time, Costs, and Barriers Related to Moving Product into the Central Business District." Transportation Research Record 1613, TRB, National Research Council, Washington, DC, 1998. 87Anne G. Morris, Alain L. Kornhauser, and Mark J. Kay, "Urban Freight 90Genevieve Giuliano and Thomas O'Brien, "Impacts of Impacts of the Long Mobility: Collection of Data on Time, Costs, and Barriers Related to Moving Beach and Los Angeles Ports PierPASS Program," Presentation at the National Product into the Central Business District." Transportation Research Record, Urban Freight Conference, December 5, 2007. 1613, 1998. 91Edwards and Kelcey Engineers, Inc., Truck Route Management and Community 88ATRI, "An Analysis of the Operational Costs of Trucking," 2008. Impact Reduction Study, Executive Summary, Prepared for New York City, 2007.

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57 12 Loading Bays per Million Square Feet 10 8 6 4 2 0 Atlanta Boston Chicago Dallas New York Seattle Source: Anne G. Morris, "Developing Efficient Freight Operations for Manhattan's Buildings." Prepared for the Steven L. Newman Real Estate Institute, Baruch College, CUNY, Spring 2009. Figure 5-3. Minimum number of loading bays required for large commercial buildings. to these customers, carriers need to break loads into smaller administrative costs of paying them. In addition, trucks that shipments and use smaller vehicles for the last leg of the deliv- obstruct a moving lane when parking illegally impose delays ery, which increases operating costs.92 on other road users, including other trucks. Another option for carriers is to subcontract the last leg of Local land use planning and zoning authorities affect the the trip to local niche carriers who have smaller trucks and ability of trucks to load and unload freight through specifica- understand the gamut of restrictions on truck activity in a par- tions regarding the number and size of docking facilities at large ticular city.93 This option requires transfer of the freight as well buildings. As shown in Figure 5-3, a 2009 survey of zoning offi- as the administrative costs of engaging another company in the cials found a relatively wide range in the minimum number of delivery process. loading bays that cities require for new commercial buildings. New York City, the most densely populated of the cities sur- Restrictions on Loading and Unloading veyed, had the lowest requirement for the minimum number of loading bays at large commercial buildings.96 Researchers have Parking restrictions may make it harder for trucks to find cited the insufficient number of loading bays and an inadequate parking or may require drivers to park farther from their number of freight elevators as major contributors to increases destinations, thus increasing operating costs by adding to the in freight turnaround times at New York City properties. The amount of time needed for each pickup or delivery. Another authors surmised that commercial real estate developers do not option frequently chosen by truck drivers is to park illegally provide more loading bays because they would rather use the and risk receiving parking tickets. In the 12-month period end- valuable street-level space for commercial tenants.97 ing June 30, 2006, commercial delivery companies received Pickup and delivery activities of large trucks can exacerbate an average of 7,000 parking tickets per day in New York City, traffic delays if the trucks are parked in ways that impede the resulting in more than $102 million in fines. UPS received flow of traffic. A 2004 study estimated that lane-blocking about 15,000 tickets a month and paid nearly $19 million in pickup and delivery activities in urban areas resulted in nearly fines. FedEx was second with fines totaling $8.2 million.94 one million vehicle-hours of delay in 1999. However, this These two carriers also incurred the most parking tickets in impact was minuscule when compared to the traffic impacts San Francisco during the same period. In that city, UPS paid of roadwork, weather, accidents, and other causes of traffic $673,334 in fines and FedEx paid $434,046.95 In addition to delays. According to the study, truck pickup and delivery activ- the cost of the tickets themselves, carriers also incur the ities caused less than 0.03 percent of total vehicle-hours of 92Anne G. Morris, Alain L. Kornhauser, and Mark J. Kay (1998). "Urban Freight delay, the smallest impact from any source in the study.98 Mobility: Collection of Data on Time, Costs, and Barriers Related to Moving 96 Product into the Central Business District." Transportation Research Record 1613, Anne G. Morris, "Developing Efficient Freight Operations for Manhattan's TRB, National Research Council, Washington, DC, pp. 2732. Buildings," prepared for the Steven L. Newman Real Estate Institute, Baruch 93Morris, et al., 1999. College, CUNY, Spring 2009. 94The Associated Press, "Parking Fines a Big Cost for Delivery Firms," Septem- 97Ibid. 98Oak Ridge National Laboratory, "Temporary Losses of Highway Capacity and ber 1, 2006. 95Rachel Gordon, "Parking Tickets by the Truckload: 18 S.F. Businesses Rack Up Impacts on Performance: Phase 2," prepared for the U.S. Department of Energy, Thousands of Citations, Pay City on Monthly Plan," San Francisco Chronicle, November 2004, p.87. The study assumed that 20 percent of all pickup and deliv- February 24, 2007. ery events involve illegal parking that blocks a lane.